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On April 1, CMS released the proposed rule for skilled nursing facility (SNF) payments for FY 2026. Under the proposed rule, SNF payments would increase by 2.8% for FY 2026. This includes hospital market basket percentage would increase by 3.0%, with a 0.8% reduction for productivity, and 0.6% increase for a market basket forecast error adjustment. The update is lower than last year’s update of 4.6%. The American Health Care Association lauded the increase while also warning Congress that this increase wouldn’t make up for proposed Medicaid reform this year. CMS estimates that the overall economic impact of this proposed rule is an estimated increase of $997 million in payments to SNFs for FY 2026. Comments on the rule are due June 10, 2025.
PAYMENT UPDATES
The final case-mix adjusted rates (pp. 21-22 of the rule) can be found here.
CMS also released new wage index tables for FY2026 – they can be found here.
PROPOSED CHANGES IN PATIENT-DRIVEN PAYMENT MODEL (PDPM) ICD-10 CODE MAPPINGS
In FY 2020, CMS implemented the Patient-Driven Payment Model (PDPM) to focus on the needs of the whole patient, rather than focusing on the volume of services provided. CMS is proposing several changes to the PDPM ICD-10 code mappings
Interestingly, a large portion of these codes are for behavioral/mental health disorders – that have been moved off the primary diagnosis list because “treatment for these diagnoses would typically occur on an outpatient basis and not require an inpatient SNF stay in and of themselves. as reasons for a SNF admission.
SNF VALUE-BASED PURCHASING (VBP) PROGRAM
As CMS has done in all other payment rules, CMS is proposing to remove the SNF VBP Program’s Health Equity Adjustment from the VBP methodology beginning in FY 2027.
CMS also released the performance standards for the remaining VBP measures for FY 2028.
SNF QUALITY REPORTING PROGRAM (QRP)
Aligning with changes the new Administration is making on equity and social determinants of health in all proposed rules, CMS is proposing to remove four standardized patient assessment data elements beginning in FY 2027, including: one item for Living Situation (R0310); two items for Food (R0320A and R0320B); and one item for Utilities (R0330). CMS has stated that removing these reporting requirements will save SNFs $2,228,563.12 annually. SNFs will not be required to collect this data beginning with patients admitted on or after October 1, 2025.
CMS also seeks input on several RFIs, specifically: 1) future measure concepts on the topics of delirium, interoperability, nutrition, and well-being; 2) revisions to the current data submission deadlines for assessment data from 4.5 months to 45 days; and 3) advancing digital quality measurement and the use of Fast Healthcare Interoperability Resources® in the SNF QRP. For the latter, a detailed list of questions starts on page 59 of the rule.
FEEDBACK
CMS is also asking for input on many aspects of the rule from stakeholders. Below we highlight some of their requests for feedback:
- For the overall Medicare program, CMS is putting out an RFI asking stakeholders to identify areas that are redundant or burdensome in Medicare regulations, including in conditions of participation, value-based purchasing, quality and safety reporting, telehealth and digital health. The deadline for comments is June 10, 2025.
- For SNF quality, CMS would like feedback on RFIs on:
- Future measure concepts for the SNF QRP;
- Potential revisions to the data submission deadlines for assessment data collected for the SNF QRP; and
- Advancing digital quality measurement in SNFs.
Medicaid, the joint federal and state program that provides health care for low-income individuals, has long been a critical part of the U.S. health care system. Since the 1990s, the federal government and states have grappled with the rising costs of health care while simultaneously seeking to extend and ensure access to coverage and care within their communities.
With recent polling showing that more than a half of Americans believing that over 25% or more of federal spending is wasted, the voices for increased accountability for federal spending that have existed for years have grown to a crescendo with the Trump administration. As many Americans see their dollars going to programs they view as highly questionable, spending on Medicaid and Medicare is being swept up into these discussions. In FY2024, the federal government spent over $584 billion on Medicaid and the Children’s Health Insurance Program (CHIP).
The establishment of the Department of Government Efficiency (DOGE) and a new push for aggressive oversight have renewed attention on program integrity. Supporters of work requirements argue that, unlike Medicare, Medicaid serves a population that has not necessarily contributed to payroll taxes, raising questions about eligibility and personal responsibility.
The Case for Work Requirements: Promoting Work and Employment
With the expansion of Medicaid in the 2000s, some lawmakers have encouraged individuals, especially those seen as able-bodied and without children, toward full employment. In the 1990’s, bringing work requirements to welfare was an effort that enjoyed the support of not only a Republican-majority in Congress but also of a Democratic president. While Medicaid has traditionally been viewed as separate from the safety nets of Temporary Assistance for Needy Families (TANF) and Supplemental Nutrition Assistance Program (SNAP), the expansion of the program over the past decade-plus has caused it to be viewed—by some at least—as more along the lines of these programs.
The Case Against Work Requirements: Administrative Burden and Confusion
Arkansas’ brief implementation of work requirements revealed serious flaws in adding work requirements to Medicaid. In just nine months, 18,000 enrollees lost coverage, largely due to confusing or inaccessible reporting systems. Nearly one-third of those subject to the rules were unaware of the requirement altogether.
The Case Against Work Requirements: Barriers to Access to Coverage and Care
The experience in Arkansas showed that the additional administrative burden resulted in a loss of coverage and ultimately a loss of care. Delayed care, skipping medications, and the burden of medical debt were all reported.
Under the Georgia “Pathways” waiver, the experience has played out differently but with a similar net result. By expanding to 100% of the Federal Poverty Level, the state of Georgia thought that more individuals would enroll in Medicaid, but in the Georgia waiver’s first year, only a little more than 4,200 people signed up, falling far below the state’s projection of adding 100,000 new enrollees.
The Case Against Work Requirements: Most Medicaid Enrollees under 65 Are Working
The challenge posed by work requirements would be deciphering which individuals might truly be avoiding work without imposing barriers for those enrollees who are employed.
Most Medicaid enrollees under the age of 65 are currently working or otherwise unable to work because of other responsibilities, such as being a caregiver, or having a disability. In 2023, the Kaiser Family Foundation found that 64% of Medicaid enrollees were either working full- or part-time, and 29% were not working because of caring for one or more dependents (12%), having a disability or illness (10%), or attending school (7%). Eight percent of individuals were retired, unable to find employment, or not working for another reason.
Working does not necessarily mean you have access to health care coverage. Employed Medicaid enrollees often work for small employers that do not provide health coverage, or the cost of coverage their employer does offer is simply too much for them to afford.
Medicaid and the Budget Debate in Congress
With the federal debt exceeding $36 trillion and no apparent slowing in sight, a significant voice of the Republican majority in Congress will continue the push for savings and cost-cutting measures as part of this year’s congressional budget and as part of the budget reconciliation process.
The House-passed budget called for $880 billion in savings from programs within the jurisdiction of the House Energy & Commerce Committee. As Medicaid accounts for 90% of the Committee’s outlays, programmatic changes in Medicaid are in the offing.
In 2023, House Republicans sought to add Medicaid work requirements, also known as “community engagement” requirements, in H.R. 2811, the Limit, Save, Grow Act of 2023. Community engagement was defined as participating in work-related activities for at least 80 hours per month. Based largely on the experience of Arkansas, the Congressional Budget Office (CBO) estimated adding work requirements would save the federal government $109B over 10 years. CBO also estimated the number of people without health insurance would increase by 900,000, the employment status of and hours worked by Medicaid recipients would be unchanged, and state costs would increase by $65B.
In December 2024, then President-elect Donald Trump asked Congress to include an increase of the debt ceiling in their continuing resolution spending bill. At that time, Congressional leaders balked at the idea. But, with the federal government set to hit the debt ceiling again in July 2025, Congressional Republicans announced at the end of March 2025 that they had agreement to include a debt ceiling increase in the budget reconciliation package.
Fights over the debt ceiling have become increasingly common in recent years, and once again, lawmakers find themselves squabbling over what to do so the federal government is able to pay its bills. If there’s anything Congress can’t do, it’s to take no action at all, as it would mean disastrous implications for both the US and global economies.
A Brief History of the Debt Ceiling
The debt ceiling, set by Congress, is a cap on the total amount of money the Department of the Treasury can borrow. The ceiling applies to nearly all debt accrued by the federal government, including over $28 trillion in debt held by the US public, and $7 trillion in debt the federal government owes itself for programs like Medicare and Social Security.
It should be noted that debt and deficit have different meanings. The deficit refers to the difference between revenue the federal government takes in from taxes and other sources across each fiscal year, while the debt refers to deficits accrued across multiple years.
The debt ceiling wasn’t always around. Originally, Congress signed off on all debt by authorizing individual bonds through legislation. However, the cost of financing America’s involvement in World War I led Congress to establish a debt limit though the Second Liberty Act to simplify the borrowing process and allow the Treasury Department to issue as many bonds as needed instead of waiting for Congress to approve every single bond.
In recent years, rising national debt and an increasingly polarized Congress have made the process of raising the debt ceiling much more contentious. Parties have occasionally sought policy concessions from one another in exchange for agreeing to raise the debt limit, leading to a few occasions where political brinkmanship has actually caused the federal government to hit the debt limit and trigger debt ceiling crises in 1995-1996, 2011, and 2013, when the government became uncomfortably close on defaulting on its debt.
The last time the debt ceiling was raised was on June 2, 2023, to its current level of $36 trillion in the Fiscal Responsibility Act.
What Happens If the Debt Ceiling Isn’t Raised?
Hitting the debt ceiling would mean the federal government would eventually be unable to make its debt payments after a certain period of time. This would result in the government defaulting on its debt obligations, something that has never happened in US history.
With the government unable to pay its debts, millions of daily obligations including Social Security payments, salaries for federal civilian employees and military servicemembers, veterans’ benefits, utility bills, and others, would have to be at least temporarily defaulted. Next, global financial markets would enter a state of turbulence, as both international and domestic markets rely on the stability of US financial instruments and the economy. Additionally, interest rates would rise and the demand for Treasury securities would fall as investors begin to reconsider the safety of Treasuries and either pull back or stop investing entirely. Higher interest rates would in turn have strong reverberations across the economy, impacting credit cards, mortgages, car loans, and other forms of borrowing and investment.
Even if the government doesn’t actually default on its debt obligations, the mere threat of default could result in some negative economic consequences. During the debt ceiling crisis of 2011, Standard & Poor’s downgraded the US credit rating from AAA to AA+ with the rationale that the debt limit fight was a sign of “America’s governance becoming less stable, less effective, and less predictable.” During the 2013 debt ceiling crisis, credit agency Fitch warned it may cut the US credit rating due to political gridlock, and Chinese rating agency Dagong downgraded the US from A- to A. In 2014, Fitch did however restore the US credit rating to AAA.
“Extraordinary Measures” to Stave Off Default
If the federal government does hit the debt ceiling in July, it won’t immediately default on its debt. That’s because the Treasury Department can take so-called “extraordinary measures” that were previously deployed during the debt ceiling crises in 2011 and 2013. Extraordinary measures are accounting maneuvers that allow the federal government to continue to borrow money and pay bills without exceeding the debt ceiling. These measures usually involve not fully investing federal employees’ Thrift Savings Plan and civil service retirement plan funds in special Treasury securities. For example, if federal employees have invested $100 billion in the Thrift Savings Fund, the Treasury could opt to issue only $90 billion to the fund, creating $10 billion that could be used to auction more debt to the public and raise more money for the Treasury. After the debt ceiling is raised or suspended, investments in those funds would resume and lost interest is credited back to the accounts, leaving the savings and pensions plans unaffected.
But extraordinary measures only provide a temporary means for the government to pay its bills after the debt ceiling is reached, and it’s not clear how long the Treasury Department can exercise extraordinary measures after July. For example, a March 2025 report from the Congressional Budget Office (CBO) projected that extraordinary measures would probably run out sometime at the end of September 2025. However, CBO said it could be as soon as August 1, 2025, if borrowing levels remained the same.
What Will Congress Do?
As in the lead-up to previous debt crises, lawmakers in both parties generally agree on the need to increase the debt limit but have yet to settle on any specific proposals, i.e. the amount of the limit.
The debt ceiling debate has now made its way into budget reconciliation. The compromise budget resolution includes instructions for a $5 trillion debt limit increase. During the debate, Sen. Rand Paul (R-KY) offered an amendment to strike the proposal and replace it with a $500 billion increase, providing a limited, 3-month extension to force Congress to vote again on the debt ceiling before what he called “continuing down the road of fiscal irresponsibility.” His amendment was shot down 5-94, with fellow Republicans Sens. Lee and Curtis from Utah voting for it.
The debt ceiling is a bipartisan problem that should involve a bipartisan solution. That said, Republicans have teed up resolving the debt ceiling using the partisan budget reconciliation process. What happens if reconciliation fails, or is delayed to the point that the federal government comes close to defaulting on its obligations? How will Democrats react if Congressional Republicans and the Trump administration need their votes to raise the debt ceiling when they’ve been left out in the cold during the budget negotiations?
We barely had the chance to see the cherry blossoms with all the activity going on in DC! House Republican leaders are seeking to move quickly on the compromise budget resolution that the Senate passed over the weekend, so work can begin on reconciliation legislation. Meanwhile, the administration is making moves on Medicare Advantage and Medicare Part D. So, with that, let’s get into it. Welcome to the Week Ahead!
The Administration
The Centers for Medicare and Medicaid Services released its contract year 2026 Medicare Advantage and Part D final rule within 24 hours of CMS Administrator Oz being confirmed. Ironically, the final rule removes a provision from the Biden administration to expand Medicare coverage of GLP-1s, the obesity drugs of which Administrator Oz has been a proponent.
Speaking of rules, we are still waiting on the 5 calendar year payment rules, still under review at the Office of Management and Budget.
And don’t forget that Federal agency heads have until April 19 to submit deregulation plans in accordance with a February 19 Executive Order. We could see several health care regulations rolled back as part of this effort, including the nursing home staffing mandate and the Medicaid Managed Care Access rule implemented by the Biden administration. But Congressional Republicans have their eye on repealing the nursing home staffing rule to count toward their budget reconciliation savings goals.
The Senate
Despite impassioned arguments that the resolution would cut Medicaid and Medicare, and several votes on the subject, the Senate passed the compromise budget with only two Republicans, Sens. Collins (R-ME) and Paul (R-KY), voting against the bill. Movin’ on.
A couple key takeaways: Republicans passed an amendment with language they say will keep President Trump’s promise for no cuts in “patient benefits” for those on Medicare and Medicaid. Senate Democrats countered that the language was too vague to be of value.
Sen. Collins (R-ME) consistently voted for Democratic amendments related to Medicaid and Medicare and voted against the final budget. Sens. Murkowski (R-AK) and Hawley (R-MO) joined her in supporting many of these amendments, but in the end, they came home and voted yes on the budget.
How should we interpret that Hawley cosponsored the Sen. Ron Wyden (D-OR) amendment to strike the $880B savings directive to the House Energy and Commerce Committee? He’s paying close attention to Medicaid and Medicare in this bill; that’s all we can say for sure for now.
Looking ahead: The Senate Committee on Health, Education, Labor, and Pensions (HELP) plans to markup S.932, Give Kids a Chance Act, which would reauthorize the rare pediatric disease priority review voucher program at the Food and Drug Administration (FDA) and gives the agency more authorities regarding molecularly targeted drugs.
The House
House Republican leadership wasted no time after the Senate passed its amended version of the budget resolution, sending a letter to their caucus saying they plan to vote on the budget resolution the week of April 7.
However, a lot still needs to happen before President Trump can sign his “big beautiful bill.” First, House Republican leadership will need to pass the amended budget resolution through the narrowly divided House. Only then can the door be unlocked for Republicans to pass a reconciliation bill that President Trump can sign. And as arduous as passing a budget resolution can be, it pales in comparison to the work of getting a final reconciliation bill passed. Especially one that will satisfy deficit hawks looking for large spending cuts and members who are wary of how said cuts will impact their constituents. We are already hearing about dissatisfaction from a significant number of House Republicans about the Senate version of the budget resolution, which complicates an already complicated situation.
House Health Hearings
- April 8: Ways and Means Health Subcommittee hearing on the biosimilar market
- April 9: Oversight and Government Reform Committee hearing on the FDA and rooting out illicit products
- April 9: Appropriations Labor-HHS, and Education Subcommittee public witness day hearing
There You Have It
We’ve reached the final night of “the big dance,” with two teams facing off tonight in Texas for the championship. Who are you rooting for? Let us know. Make it a great week!