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On September 19, 2025, President Donald Trump signed a Proclamation imposing a $100,000 fee on all new H-1B visa petitions, effective September 21. While initially described as an annual fee, the White House has since clarified it is a one-time payment that applies only to new applicants—not to renewals or extensions for current visa holders.
This policy shift has immediate and profound implications for the U.S. health care system, which has long relied on international physicians, nurses, and researchers to meet patient care needs.
Clarifications That Matter for Health Care Employers
- The $100,000 fee applies only to new petitions filed after September 21, 2025.
- Current H-1B physicians and other health care workers will not be charged for renewals, extensions, or reentry into the U.S.
- However, health care employers seeking to hire new international medical graduates, specialists, or researchers through H-1B will face this unprecedented financial barrier.
Enforcement and Wage Changes
The Department of Labor (DOL) is simultaneously launching Project Firewall, a new enforcement program under which the Secretary of Labor will personally certify H-1B investigations. DOL has also been directed to propose new regulations to raise prevailing wage levels. For hospitals, community health centers, and research institutions that already operate on tight budgets, this could make sponsorship even less viable.
The Physician Workforce at Risk
The timing of this policy is especially challenging given persistent physician shortages:
- The U.S. is projected to face a shortfall of up to 86,000 physicians by 2036, according to the Association of American Medical Colleges.
- Rural and underserved areas are particularly dependent on foreign-trained doctors, many of whom come to the U.S. under H-1B status.
Recognizing this, the American Medical Association (AMA) and more than 70 other medical groups have formally petitioned DHS to exempt physicians, residents, and fellows from the $100,000 fee. They argue the policy could “cripple access to care” in communities already experiencing provider shortages.
Narrow National Interest Exception
The Proclamation does allow for a waiver if employing an H-1B worker is deemed to be in the “national interest” and poses no threat to U.S. security or welfare. Early reports suggest the White House is considering a specific exemption for doctors, though no formal guidance has been issued. Without such an exemption, hospitals and academic medical centers may be forced to reduce their reliance on international medical graduates—leaving critical gaps in specialty care, research, and teaching.
The Bigger Picture: Health Care Brain Drain
Beyond discouraging new applicants, the policy is creating anxiety among existing H-1B health care workers. Despite assurances that renewals and reentry are unaffected, many fear that the climate of enforcement could worsen. This may lead some to leave the U.S. for more welcoming destinations such as Canada, the UK, or Australia. For health care systems already struggling with workforce shortages, this could trigger a damaging brain drain at a time when patient demand is rising.
A Second Fee on the Horizon
Adding to the challenge, beginning October 1, 2025, the U.S. will impose a new $250 “Visa Integrity Fee” on most nonimmigrant visa categories, including H-1B. For hospitals sponsoring multiple clinicians or researchers, these fees quickly add up.
Conclusion: Health Care Caught in the Crossfire
While the $100,000 H-1B fee was pitched as a way to curb program abuse and protect U.S. workers, its blunt application risks undermining the health care workforce. Without an explicit exemption for physicians and other essential health professionals, hospitals, academic medical centers, and community providers could face severe staffing challenges—hurting patients most of all.
On September 5, 2025, the Medicare Payment Advisory Commission (MedPAC) convened for the second day of its September meeting. Staff presented findings on the relationship between shifts in Medicare Advantage (MA) enrollment and hospital finances. Commissioners responded positively to the analysis and offered suggestions to strengthen and expand the research.
Association Between Changes in MA Enrollment and Hospital Finances
MedPAC staff examined how rising MA enrollment is affecting hospitals’ finances. Between 2014 and 2025, MA enrollment grew from 31% to 55% of Medicare beneficiaries, driven by beneficiary preferences for added benefits and employer retiree coverage shifts. Hospitals have expressed concern that MA patients often generate lower payment-to-cost ratios than fee-for-service (FFS) patients, and MA plans actively use tools like prior authorization and narrow networks to manage utilization, which can reduce hospital volumes or shift care to lower-paid settings. Additionally, MA plans negotiate rates, downgrade admissions, and deny claims in ways that can reduce hospital revenue.
Using 2013–2023 cost report data, MedPAC found that higher MA penetration is not significantly associated with changes in hospital profit margins, but it is linked to declines in both revenues and costs (about 1.3% and 1.2% for every 10-percentage-point increase in MA penetration). Effects differ by ownership: financially integrated hospitals did not experience significant revenue or cost declines, while non-integrated hospitals did. Critical Access Hospitals saw no statistically significant effects, partly due to cost-based reimbursement and MA per diem structures. Another emerging issue is uncompensated care (UC) payments—because MA plans often mirror FFS add-ons, a decline in FFS discharges raises the UC payment per discharge, potentially increasing hospitals’ UC payments as MA grows.
Overall, the findings suggest that MA growth shifts financial dynamics but does not broadly erode hospital profit margins, with effects moderated by whether hospitals are integrated with MA plans. Policymakers may need to consider integration differences and downstream effects on FFS-related payments when evaluating MA’s hospital impact.
Commissioner Discussion
The Commissioners’ discussion focused on the financial and operational impacts of MA growth on hospitals, with particular attention to integration, utilization management, and methodological considerations. Several Commissioners raised questions about how new services and prior authorization denials affect hospital operations, emphasizing that, while hospitals often maintain profit margins, they must divert resources to manage administrative burdens. Concerns were also raised about retiree health plan enrollees in MA, the role of broker incentives, and whether beneficiaries and taxpayers are truly getting value for money under the current system.
Others highlighted the importance of examining differences between financially integrated and nonintegrated hospitals, noting the leverage and pricing differentials created by integration. Commissioners suggested expanding the analysis to include dollar amounts, stratifications based on MA market characteristics, and thresholds in penetration levels. They also encouraged looking at other sectors, such as post-acute care and skilled nursing facilities, where effects may differ. There was recognition that hospitals owning MA plans tend to be larger and structurally different, and that regional market dynamics and timing of MA penetration may produce varying effects. Overall, while the analysis was well received, Commissioners urged refinement with more current data, stratified analyses, and a clearer picture of how MA growth translates into real-world financial pressures and adaptations by providers.
On September 3, 2025, the House Energy and Commerce Health Subcommittee held a hearing on advancing health care through artificial intelligence (AI). Discussion included the potential applications of AI in prior authorization, rural health care delivery, and the pharmacy sector. Members of both parties agreed that AI holds promise for improving efficiency and access in the health care system. However, they emphasized that human oversight remains essential to address errors and ensure patient safety.
Opening Statements
Witness Testimony
- TJ Parker, Leader Investor, General Medicine – Testimony
- Andrew Toy, Chief Executive Officer, Clover Health – Testimony
- Dr. Andrew Ibrahim, MD, MSc, Chief Clinical Officer, Viz.ai – Testimony
- Dr. Michelle Mello, JD, PhD, MPhil, Professor of Law, Stanford Law School, and Professor of Health Policy, Stanford University School of Medicine – Testimony
- Dr. C. Vaile Wright, PhD, Senior Director, Health Care Innovation, American Psychological Association – Testimony
Member Discussion
Prior Authorization
During the hearing, Ranking Member Frank Pallone (D-NJ) underscored his concern that AI could embed and even magnify existing biases in prior authorization systems if Congress does not establish sufficient guardrails. He recalled that, under the Trump administration there were efforts to incorporate AI into prior authorization processes and warned that, if left unchecked, such initiatives could lead to higher denial rates for Medicare and Medicare Advantage beneficiaries. Rep. Pallone asked how policymakers could ensure AI is deployed in a way that enhances patient care rather than creating new barriers to access. Dr. Mello responded that prior authorization is already a system with high denial rates and significant flaws. She explained that layering AI onto a broken process risks simply “amping up” existing problems rather than fixing them. According to Dr. Mello, the central question is whether AI will serve as a corrective tool that streamlines care or whether it will exacerbate inequities and inefficiencies—something policymakers and regulators cannot yet answer with certainty.
Rep. John Joyce (R-PA-13) built on these concerns, noting that he has already heard from physicians in his congressional district who report that AI-based systems are increasing denial rates, particularly within Medicare Advantage. Rep. Joyce argued that AI should only be used as a supportive tool to assist clinical decision-making, and never as the final determinant of coverage. He called for Congress to establish clear guardrails that preserve physicians’ ability to make patient-centered judgments and protect beneficiaries from automated denials. Dr. Toy sought to reassure the subcommittee, testifying that his organization does not use AI in prior authorization decisions and stated unequivocally that AI should never be deployed to deny care. Instead, Toy emphasized that AI’s proper role is to help clinicians deliver services more efficiently, reduce administrative burdens, and ultimately improve patient outcomes.
Finally, Rep. Lizzie Fletcher (D-TX-7) questioned whether the current statutory framework is adequate to govern prior authorization in an era where AI tools are increasingly being integrated into health care. Dr. Mello was direct in her response: the existing legal framework is not sufficient. She argued that without updated oversight and regulation, patients and providers will remain vulnerable to harm, underscoring the need for congressional action to modernize policies around AI and prior authorization.
Rural Health Care
The hearing also explored how AI could support care at rural hospitals and the communities they serve. Chairman Morgan Griffith (R-VA-09) opened the discussion by asking what type of software is needed to bring AI into rural settings and whether such systems are prohibitively expensive. Dr. Toy explained that, while the cost of infrastructure is indeed higher in rural areas, smaller towns can sometimes deploy new systems more quickly, enabling AI solutions to reach patients faster than in large, complex urban health systems.
Rep. John Joyce (R-PA-13) pressed further, questioning whether rural hospitals have a stable environment to invest in new technologies. Dr. Mello acknowledged that most do not, noting that rural facilities often operate with razor-thin margins and require outside assistance to adopt advanced tools. She pointed out that certain technologies, such as radiation tools, have shown promise when paired with AI but emphasized that these opportunities are largely out of reach without federal support. Dr. Ibrahim added that some of the most impactful research on stroke care has been conducted in rural areas, underscoring the potential for innovation outside urban centers. However, he cautioned that reimbursement remains a decisive factor: hospitals are unlikely to invest in AI if payment models do not recognize and support its use.
Rep. Troy Balderson (R-OH-12) asked what steps Congress could take to support wider adoption of AI in rural health care. Witnesses highlighted the need for stronger reimbursement policies, targeted grant funding, and infrastructure investments to give rural hospitals a stable base for innovation. Rep. Kat Cammack (R-FL-03) shifted the focus to physician training, asking how AI could play a role in preparing doctors for practice in rural communities. Dr. Ibrahim responded that rural hospitals are already positioned to serve as training hubs and could leverage AI to expand education and mentorship opportunities for providers who might otherwise face isolation. Dr. Toy stressed the importance of connectivity. He argued that something as simple as linking patients and providers through consumer-friendly devices, like iPads, could make a significant difference in overcoming geographic barriers. In his view, AI is not just about cutting-edge algorithms but also about creating practical tools that connect people and care in underserved areas.
Pharmacy and Drug Development
Rep. Diana Harshbarger (R-TN-01) asked how AI could reshape the pharmacy sector. Mr. Parker answered that AI offers significant opportunities for pharmacists, particularly by applying advanced logic to streamline workflows and build stronger infrastructure for dispensing, monitoring, and counseling. When Rep. Harshbarger pressed further on rural challenges, Dr. Toy observed that limited coordination between pharmacists and physicians remains a barrier in these settings. He argued that AI should be leveraged to strengthen collaboration across the care team to ensure patients in rural areas receive consistent, high-quality services.
Rep. Troy Balderson (R-OH-20) noted that a lack of coordinated care often prevents providers from catching early warning signs of health complications. Dr. Toy responded that a stronger AI-enabled health care ecosystem could close these gaps, with pharmacies playing a central role in connecting patients to the broader system.
Rep. Buddy Carter (R-GA-01) broadened the discussion to the scale of the U.S. pharmacy system, asking how AI could improve services across such a vast network. Mr. Parker explained that AI has the potential to collect and synthesize full historical patient records, giving pharmacists a more comprehensive view of patient needs. Rep. Carter then asked about drug development, and Dr. Ibrahim emphasized that AI excels at detecting data patterns, which can accelerate the identification of promising compounds and support more efficient clinical trials.
The clock keeps ticking toward September 30, and the stakes are particularly high given that Congress is out next week for the Rosh Hashanah holiday. This week, the stakes feel particularly high. All eyes are on Senate Minority Leader Chuck Schumer (D-NY) as he has taken a strong stance on what he wants for his support on must-pass government funding legislation. The central question: Will Congress find a path forward on critical health care provisions, or are we headed toward yet another shutdown showdown? So – let’s get into it, welcome to the Week Ahead!
The Administration
It’s politics and prose with the administration this week. On the political side, President Trump and Vice President Vance are expected to continue focusing on the brutal murder of political activist Charlie Kirk. Both will be attending Kirk’s funeral, and the President has announced he will honor Kirk with a posthumous Presidential Medal of Freedom. In addition to eulogizing the fallen leader, the President has taken to excoriating progressive politicians and organizations and has said he will launch investigations into “groups of interest” that may have fed into the torment that led to the assassination.
On the prose front, the Centers for Medicare and Medicaid Services are pouring through stakeholder comments to the calendar year payment rules, including hospital outpatient, physician fee schedule, home health, and end-stage renal disease. While CMS often includes policies that health care providers seek to tone down during the comment period, of particular focus is the home health rule that takes $1 billion in payments away from home health providers, according to the National Home Care Alliance.
In other exciting news, CMS released guidance on September 15 for states to submit their applications for the $50B Rural Health Transformation Program. This guidance provides states with the official roadmap for accessing a major new federal investment aimed at strengthening health care in rural areas.
The Senate
The Senate is bracing for a fierce battle over advanced premium tax credits (APTCs), a cornerstone of affordable health coverage for millions of Americans. Schumer is holding firm, insisting that any continuing resolution (CR) to keep the government open must include an extension of these subsidies.
Schumer, who faced intense backlash from his caucus after siding with Republicans on a funding measure in March, is determined not to repeat that mistake. He has already made it clear to reporters—no APTCs, no CR.
Republicans, meanwhile, are pushing for a “clean CR” that would extend all existing programs and funding, including health extenders such as Medicare add-on payments for rural hospitals, funding for community health centers, the Teaching Health Center Graduate Medical Education program, and delays to Disproportionate Share Hospital (DSH) cuts.
Under normal circumstances, compromise might be within reach. But with the political climate highly charged, APTCs looming large, and open enrollment around the corner, Schumer appears unlikely to back down. The result? A heightened risk of a government shutdown—one that could leave both APTCs and health extenders hanging in the balance.
Senate Hearings this Week
- September 17: Senate Committee on Aging Hearing on Drug Safety, Supply Chains, and Risk to Aging Americans
- September 17: Senate HELP Hearing on “Restoring Trust Through Radical Transparency: Reviewing Recent Events at the Centers for Disease Control and Prevention and Implications for Children’s Health”
- September 17: Senate Committee on Veterans’ Affairs Hearing on Strengthening Services for Veterans with Spinal Cord Injury and Disorder
The House
Over on the House side, the question is whether leadership will try to force the Senate’s hand by moving its own appropriations bill. Democratic Leader Hakeem Jeffries (D-NY) has remained tightly aligned with Schumer, keeping the focus squarely on APTCs.
At the same time, Congress is feeling pressure from stakeholders to avoid any lapse in health extenders. Hospitals, health centers, and other providers depend on predictable funding to plan services, retain staff, and keep doors open—especially in rural and underserved areas. A disruption, even a temporary one, could have real-world consequences for patients.
Word is that some time on September 15 we will see the text of a “clean” CR that would run through November 20 or 21. House Republican leaders were said to be close to putting the final touches on a CR. The CR is said to extend expiring health provisions through the length of the CR and not include the APTC extension the Democrats have been calling for. House Republicans are reportedly eyeing September 17 for a vote on the CR.
Later this week, attention will be on the Medicaid and CHIP Payment Access Commission (MACPAC) as they meet for the first time since Congress passed the One Big Beautiful Bill Act. The meeting will include a review of the legislation and start to explore the work and community engagement requirements in Medicaid.
House Hearings this Week
- September 16: House Ways and Means Hearing on “Virtue Signaling vs. Vital Services: Where Tax-Exempt Hospitals are Spending Your Tax Dollars”
- September 18: House Energy and Commerce Health Subcommittee Hearing on Legislation to Expand Seniors’ Access to Innovative Medical Care
There You Have It
September marks Healthy Aging Month—a perfect reminder to celebrate every stage of life and enjoy the fall season. Make it a great week!