Discover the three critical signals every healthcare leader and payer needs to watch — before reform efforts possibly unravel.
The question Will Post-Brian Thompson Reforms Go the Way of DEI? requires a precursor: Which way has DEI gone?
HR Daily Advisor, a companion site to HealthLeaders Media, covered these developments extensively throughout 2024 (February, April, July, September, October). This coverage included the creep of government anti-DEI sentiment into the corporate sector. The list of companies now abandoning their DEI posts is long and growing — from Big Retail and Big Auto (Walmart, Target, Ford) to Big Tech (Amazon, Google, Meta) to Big Macs (McDonalds).
Sarah Reynolds, CMO of HiBob and a nonbinary C-suite leader, notes: "For employees who identify as members of marginalized groups, an organization's focus on DEI&B — or lack thereof — can impact every stage of the employee lifecycle."
Similarly, for patients who identify as members of marginalized groups, a focus on health equity — or lack thereof — can affect every stage oflife in general.
The backlash against DEI initiatives in the United States has intensified, driven by a combination of legal decisions, political actions, and cultural debates. So has the backlash against health equity initiatives. While DEI is largely a workplace reform, threats to sustained healthcare reform may not be far behind.
Looking for signals
KFF has identified several ways that eliminating federal diversity initiatives could affect racial health equity in the U.S.:
Dismantling Equity-Focused Health Programs. Ending DEI-driven efforts like CMS's Health Equity Advisory Committee and FDA diversity guidance could weaken efforts to reduce health disparities, especially those linked to systemic racism.
Suppression of Health Equity Data and Research. Cutting or changing public health data and questioning equity-related research makes it harder for the government to spot healthcare disparities, measure progress, or guide policy.
These scenarios may help answer the overarching question of this series — "Will Post-Brian Thompson Reforms Go the Way of DEI?" — using the lens of the social drivers of health (SDOH). These drivers are the non-medical factors that influence health outcomes and include stable access to food, housing, transportation, employment.
Before exploring this connection, it's important to note that DEI and SDOH are not the same.
"DEI initiatives start with race, ethnicity, gender, identify the inequities that exist among groups and aim to close those gaps and make healthcare more equitable. SDOH work includes identifying social risks and needs for a person or and/or intervening and helping to address those needs regardless of a person's gender, race, ethnicity or other criteria."
Even so, commitments to DEI, SDOH or the lack thereof could help predict the trajectory of other reforms that arise from traumatic events — and how likely they are to persist.
Signal #1: Threats to federal funding
As noted above, KFF reported that cutting federal diversity initiatives could dismantle equity-focused health programs. We may already be seeing one of the first examples.
On Apr. 10, CMS announced that it would end spending "that duplicates resources available through other federal and state programs or isn't directly tied to healthcare services [emphasis added]." Examples provided were $241M for non-medical in-home services like housekeeping and a $3.8M diversity medicine initiative — both linked to designated state health and investment programs (DSHP/DSIP) in New York.
DSHP/DSIP are examples of innovative 1115 waiver programs that address SDOH needs with services that Medicaid does not normally cover. CMS noted that this kind of spending "distracts from the core mission of Medicaid."
Signal #2: Threats to data
KFF also noted that suppressing equity-based data and research could suppress health equity itself. This data and research:
has shown that 80% of medical outcomes are based on non-medical factors
put social drivers of health in the national vocabulary
helped fund and create programs to address them
Other research from the CDC shows that non-White populations are more impacted by adverse SDOH and health-related social needs (HRSN). This includes Black, multiracial, Hispanic, Latino, and American Indian/Alaska Native (AI/AN) populations with the disparities ranging from lack of social and emotional support to food, housing, and transportation insecurity to less access to medical coverage and care.
As suggested by KFF, the CDC notes that SDOH and HRSN data can help "monitor needed social and health resources in the U.S. population and help evaluate population-scale interventions."
Population health is central to another bellwether of healthcare reform: the Triple Aim.
Signal #3: Threats to the Triple Aim
Healthcare's Triple Aim is to improve population health, enhance patient experience, and reduce costs. Many of the reforms that UnitedHealth Group and The Cigna Group proposed after Brian Thompson's murder are related to these aims, including:
Cost: United has proposed a 100% pass-through of PBM rebate discounts to health plan members while Cigna wants to make prescription drug costs more predictable.
Experience: Both United and Cigna have proposed better access to and navigation of healthcare, including fewer prior authorization (PA) hurdles.
James Clear, author of Atomic Habits, wrote: "You do not rise to the level of your goals, you fall to the level of your systems."
It remains to be seen whether healthcare's reform goals will also fall to the level of their systems — because the industry very clearly has a systems problem, a topic HealthLeaders will explore next. Read the first part of this article here.
What happens when violent events amplify calls for reform?
Let’s take a trip back in time.
It’s the pandemic, May 25, 2020. George Floyd is murdered on the sidewalk in broad daylight by Minneapolis PD, led by Derek Chauvin. Floyd’s murder “triggered a reckoning on race and policing” with calls for reform ranging from defunding the police to White Privilege book clubs to the strengthening of the Black Lives Matter movement.
Fast forward, December 4, 2024. UnitedHealthcare CEO Brian Thompson is also murdered on a sidewalk in broad daylight, this time in Manhattan. Accused assailant Luigi Mangione is in custody, with an evidence trail that includes his manifesto and shell casings inscribed with “Deny,” “Defend,” “Depose”.
What do these events have in common? A violent event that fixed a razor-sharp spotlight on the need for systemic solutions to painful, long-standing problems.
A reckoning
It was well-known, long before the pandemic, that 80% of healthcare outcomes are based on social drivers. It is also well-known that U.S. healthcare is a profit-driven, patchwork system in desperate need of reform. These reforms must answer key questions: How can healthcare be accessible, affordable, and equitable while leading to better outcomes?
Though these questions have never stopped, they’ve been swirling anew for more than a quarter now, the unit of time the market uses to measure value. The preference for short-term ROI over long-term investment and solutions begs another question:
Will post-Brian Thompson proposals last or will they suffer the fate of another call for change instigated by violence: the once-amplified, now-waning commitment to Diversity, Equity and Inclusion (DEI) following the death of George Floyd.
The question might suggest that healthcare reform is also waning. Far from it. But what’s next? How can the nature of systems change help us predict it?
Health plans respond to the death of one of their own
Thompson’s murder has sparked significant discussion on how to solve the industry’s systemic challenges. Proposals range from eliminating employer-sponsored insurance (Oscar Health CEO Mark Bertolini) to curbing one of healthcare’s biggest hobgoblins: prior authorization (PA).
The first reform came the day after Thompson’s murder. Facing backlash, Anthem Blue Cross Blue Shieldreversed a policy that would have limited anesthesia coverage based on arbitrary time limits.
UnitedHealth Group: “The health care system is flawed. Let’s fix it.”
UnitedHealth Group CEO Andrew Witty acknowledged public outrage with America’s broken healthcare system in a Dec. 13, 2024, op-ed in The New York Times.
“[T]the health system does not work as well as it should, and we understand people's frustrations with it. No one would design a system like the one we have. And no one did. It's a patchwork built over decades."
Witty expanded on these comments in the company’s Q4 2024 earnings call, noting that there are “so many areas that can be enhanced, reworked, reengineered, or even scrapped to make the health system work better.” He highlighted three:
Enhancing and standardizing AI/digital tools to improve healthcare navigation, data collection, and value-based care (VBC) delivery
Ensuring 100% pass-through of PBM rebate discounts to health plan members
Speeding up approvals “to materially reduce the overall number of prior authorizations used for certain Medicare Advantage services”
A Forbes contributor piece has called for United to compete “on health, not denials” and to “lead the future of healthcare” in three areas:
Capitated (“fixed”) provider payments
Primary and preventive care
Advanced chronic disease management through generative AI
One of UnitedHealth Group's most recent reforms is to end PA requirements for home health services managed by Home & Community, a post-acute healthcare services company owned by its Optum business. The change applies to MA and Dual Special Needs Plans (D-SNP) in 36 states and the District of Columbia and became effective Apr. 1, 2025.
The Cigna Group: “We owe it to our customers to make the health care system work better”
Easier Access to Care: Making customer processes “simpler, easier and faster.” PA is one of these process categories. Here, Cigna is “accelerating and simplifying” provider claim and PA requests by expanding digital options that help ensure completeness and accuracy at point of submission. Noting that "more can be done to reduce the administrative burden on clinicians,” a Cigna representative added that PA “is required for less than 4% of services for Cigna Healthcare customers” and that the company “has removed the prior authorization requirement for about 1,100 services and devices” since 2020.
Delivering Better Value: Making prescription drug costs more predictable and implementing more tools to resolve claims/PA challenges. Examples include enhancing existing digital status trackers and — per a Cigna media representative — engaging with clinicians “to align on care delivery goals and outcomes and continue to evaluate whether there are other changes we can make without compromising patient safety.”
Better Support: Doubling the number of My Personal Champions, who help customers with more complex needs navigate the healthcare system.
Accountability: Implementing “governance processes at the highest levels to successfully ensure positive changes.” This will include tying leadership compensation to customer satisfaction and creating a new Office of Excellence and Transformation (OET).
Transparency: Sharing how The Cigna Group “is continuously improving” via an annual Customer Transparency Report.
Cigna has announced what appears to be the most detailed public reform plan so far: “Let’s Make It Better”SM. Its goal is to regain trust “through the results people will see” per Dr. David Brailer, Cigna Health Group’s EVP and Chief Health Officer, who will oversee the OET.
Cigna should be commended. If reform efforts aren’t met with optimism — albeit cautious and supported with results — they will be undermined by cynicism. When asked ‘Why now?’ on its reforms, a Cigna representative noted that CEO David Cordani’s had addressed this question on the company’s Q4 2024 earnings call:
“In early December, we were all witnesses to the tragic murder of Brian Thompson, a leader at the UnitedHealth Group. The past several weeks have further challenged us to even more intensely listen to the public narrative about our industry. At the Cigna Group, we are further accelerating improvements in innovations to increase transparency, expand support and drive even greater accountability.”
This returns us to the original question. Will commitments to post-Brian Thompson reforms persist? Or will they go the way of other reforms instigated by tragedy?
Cost shares have as much as doubled as plans get a payment rate hike.
A new analysis by eHealth of more than 250,000 applications submitted during the 2025 Medicare Advantage (MA) Annual Enrollment Period found that plan deductibles have more than doubled ($315 vs. $132). In addition, Medicare Part D premiums are also 24% higher than the 2024 plan year. The first and one of the largest health insurance exchanges in the U.S.
Meanwhile, it's Christmas in April for MA insurers, who will receive a 5.06% increase ($25 billion) in the average MA plan benchmark payment in 2026. This increase — finalized April 7 via CMS's Rate Announcement — is higher than the 4.33% increase ($21 billion) proposed at the tail end of the Biden-Harris Administration.
This Tale of Two Cities for members and payers comes as the industry responds to the Rate Announcement and CMS issues additional MA guidance on risk adjustment, Star Ratings, GLP-1 coverage for weight loss.
Rate increase reactions unsurprising
Responses to the Rate Announcement largely followed "party lines" across payers and providers.
Analysts note that the payment increases will help payers expand benefits along with profitability, with the stock prices of publicly traded insurers (UnitedHealth Group, Elevance Health, CVS Health) rising from 6-19% after the announcement.
Conversely — and even before the final Rate Announcement — AMA president Dr. Bruce A. Scott, MD lamented the plan payment increase "while physicians are in their fifth consecutive year of payment cuts."
"The stark contrast between highly profitable insurance companies that are receiving annual payment increases above inflation and physicians," Scott added, "ought to raise eyebrows of policymakers and taxpayers — as it has for physicians."
Plan rate increases amidst a bevy of new MA guidance
Paired with his eHealth's MA member cost-sharing analysis, CEO Fran Soistman added:
"Over the past two years, CMS rate adjustments for Medicare Advantage have not kept up with medical cost inflation or the pent-up demand for healthcare following COVID. That's why enrollees are being asked to take on significantly higher out-of-pocket costs, as our new report shows."
Soistman's quote came prior to the CMS Rate Announcement, and he is bullish on the Medicare Advantage program under CMS's new Administrator, Dr. Mehmet Oz.
"It's too early to say what the future holds for Medicare Advantage but Dr. Oz has been a vocal supporter of the program," says Soistman, adding: "Medicare Advantage is burdened by significant regulations and we look forward to a period of positive change."
An eMed media representative clarified that eHealth "is not against CMS targeting bad actors and supports anything that truly protects consumer interests." CEO Soistman has expanded on this position, noting that not all licensed agents and independent brokers are created equal.
Select agent and broker market guardrails were one of many requirements CMS deferred when finalizing another Medicare Advantage regulation, the Contract Year 2026 MA and Part D rule, including:
most proposed Star Ratings changes
artificial intelligence oversights
coverage of GLP-1s for weight loss by Medicare Part D plans and Medicaid
In line with the Trump Administration's anti-DEI policies, CMS announced that the name of the MA Star Ratings Health Equity Index will change to Excellent Health Outcomes for All (EHO4all) and that its current reward factor will be removed.
CMS giveth and taketh away
The Rate Announcement did, however, continue phase-in of the MA risk adjustment model, which most insurers requested be paused.
As HealthLeaders examined last fall, CMS changed the algorithm that assigns diagnostic codes to address coding variability across MA payers. Depending on new data and analysis — including demographics like age and gender — payments for conditions like heart disease might be higher or lower (overall and compared to MA).
"This is so health plans don't just pick healthy people who cost less as members," noted KFF Associate Director-Program on Medicare Policy, Jeannie Fuglesten Biniek. "The plans get higher payments for people who are sicker."
Coding manipulation to increase reimbursement from CMS is a private payer strategy, which Fuglesten Biniek described as plans receiving "higher payments than are justified and from a payment system that is set up to incentivize this because CMS pays more for people who are sicker."
What's next for MA plans under the Trump Administration?
Medicare Advantage plans are likely to find a friend in Trump's second term, perhaps from policies detailed in Project 2025 from conservative think tank the Heritage Foundation.
For Medicare Advantage, Project 2025 proposes "critical reforms [that] are still needed to strengthen and improve the program" such as making MA the default enrollment option when beneficiaries age-in to Medicare coverage and removing "burdensome policies that micromanage MA plans"
Forbes notes that while Trump "has publicly disavowed Project 2025 and has not changed his stance since taking office," his first months in office "have featured a slew of executive orders that reflect proposals outlined in the policy blueprint."
NAMI Chief Innovation Officer Darcy Gruttadaro shares insights for employers based on her organization's latest survey data.
Employers are struggling more than ever to control and predict rising healthcare costs, which could surge to historic highs of 8% in 2025.
New data from the National Alliance on Mental Illness (NAMI), the nation's largest grassroots mental health organization, shows that mental health challenges like stress and burnout impact workplace morale, productivity, profitability, and retention. These challenges also diminish the value of employer healthcare spending when employees don’t understand their mental health benefits, how to access them or how to use them.
In an exclusive interview with HealthLeaders, NAMI Chief Innovation Officer, Darcy Gruttadaro details the mental health benefit strategies that employers can deploy as healthcare headwinds intensify.
First, the latest data . . .
What the results show
NAMI’s 2025 survey included full-time employees at companies with 100+ workers, with these key findings:
80% report that mental health support helps create a positive workplace culture.
26% of employees don't know whether their employer offers these supports and only 53% know how to access them.
More than 75% of employees want training on this access and other mental health topics like burnout.
Through Gruttadaro’s insight, five strategies emerged to help employers assess the access, use, and value of the mental health benefits they pay for.
Ask the right questions
To understand how well their mental health benefit is working, employers must ask fundamental questions such as:
Are we offering a full range of mental health support and services?
Are employees aware of them and how to access them?
How many phone calls does it take for an employee to get an appointment with a mental health provider?
Gruttadaro understands the challenges employees face.
“I don't want to lose the fact that all of this can be extremely distressing to employees who need and are trying to access mental health care either for themselves or a family member.”
Engage employees and get their feedback
To get answers to these questions, Gruttadaro recommends employee engagement surveys, even tapping into the important conversations that happen in Employee Resource Groups (ERGs).
“HR departments and benefit leads should create feedback loops to learn more from employees about how they are doing accessing the company’s mental health benefits — because at the end of the day, that's what really matters most.”
It is through these feedback loops that employers can identify needs, gaps, and hidden access challenges — each addressed in the next three strategies.
Meet growing need with diverse, expanded resources
“It’s important that employees have mental health supports they can tap into,” Gruttadaro stresses. “Workplace mental health is not just a nice to have. The last thing you want to do is have an employee walk out the door because they did not have their expectations met.”
The NAMI executive adds: “Younger employees have a strong expectation that businesses will make mental health a priority, will make it visible, that leadership will set a culture that shows the importance of it, and that mental health at work impacts all aspects of work — our engagement, our interaction, our performance, our productivity.”
Making mental health visible in the workplace means making sure an employee understands the resources their employer offers. Per Gruttadaro, this support package should include not only traditional mental health benefits, but an Employee Assistance Program (EAP), and digital supports that connect employees to everything from online therapy to meditation apps.
Gruttadaro notes that employees don’t know what their options are because organizations are not doing a very good job on the mental health training side.
“One thing that came through loud and clear in our 2024 and 2025 national polling is that employees really want mental health training — 82% recognize that it is important to a positive work culture. The more employers offer mental health training, the more we raise the visibility of mental health in the workplace.”
Other mental health resources include those outside of the workplace, offered by community organizations like NAMI.
“We offer support groups, free education programs, a whole array of workplace and mental health resources. Sometimes people may not want to access certain kinds of support from their employer,” Gruttadaro notes.
The NAMI website includes education and support programs, access to the NAMI HelpLine for resources and referrals, and a sister site, NAMI Stigma Free, that advances mental well-being in the workplace.
Strengthen health plan oversight to prevent access obstacles
Historically, it has been difficult for employers to obtain data from their health plans. This includes information on health plan practices when it comes to employees. In past interviews, HealthLeaders has learned that some health plans steer employees toward their workplace EAP before facilitating use of their benefits.
When asked about this, Gruttadaro states: “I don’t know how prevalent the practice is, but employers should be asking whether their health plan is requiring EAP first. For acute needs, that wouldn’t be appropriate. If large employers are paying for robust mental health provider networks, they must be accessible to employees.”
“I've done workplace mental health for many years and have been amazed at what I hear. I think employers and benefits leads should be asking much more direct questions and seeking more data from their vendors.”
Gruttadaro recommends that employers write parameters into their health plan contracts and — again —get employee feedback on health plan practices.
Treat mental health supports as a moral and business imperative
NAMI survey shows employees are worried about their finances, physical and mental health, and the state of the world. Yet only a slight majority believe that their company and its senior leadership prioritize employee mental health or care about them personally.
Gruttadaro emphasizes that employer investment in mental health resources isn’t just the right thing to do — it’s a business imperative.
In a press release linked to the NAMI survey, Gruttadaro added: “It takes a commitment for companies to implement mental health education and establish mental health benefits. By doing so, organizations will see the individual and organizational impact of increased productivity, connection, and satisfaction amongst employees who are connected to resources.
Gruttadaro adds: “Our workplaces are a community. They are where we spend the majority of our time. We know that performance and productivity improve when people have a sense of belonging and purpose. Employers must make it very clear that they care about the mental health and well-being of their employees as much as they care about physical health and all aspects of life.”
Eligibility, enrollment, and affordability are at risk for millions of Americans who now rely on the Marketplace for health insurance.
On Mar. 10, HHS proposed the Administration’s first major healthcare rule with a companion press release and fact sheet. In them, the agency articulates how the rule will save money and prevent fraud, waste, and abuse.
There is no question that all undermine affordable healthcare and that all stakeholder groups contribute to high costs, even consumers. But among its policy positions, HHS communicates contradictory ideas: that the current ACA Marketplace is stable — yet artificially inflated, open to adverse risk selection, and no longer in need of cost- and access-friendly premium policies.
Health Affairs has a slightly different conclusion, noting in its two-partanalysis: “The proposed rule is significant and would, if finalized, restrict marketplace eligibility, enrollment, and affordability . . . or erode the value of marketplace coverage.”
“HHS acknowledges as much,” the analysis adds, detailing each of the areas impacted and how up to 2 million people — mostly in Southern states — could lose coverage if the Marketplace’s advance premium tax credits (APTC) and enhanced subsidies are cut, beginning with the next plan year.
Affordability
Health Affairs notes that HHS — along with just about everyone else — “assumes that Congress will not extend the enhanced premium tax credits that expire at the end of 2025. As a result, most marketplace enrollees will see increased premiums.
Further increases could come from premium adjustment methodologies, reinstated from the first Trump Administration, which would raise premiums another 4.5% for subsidized benchmark plans. The new rule also proposed to raise maximum out-of-pocket costs (MOOP) by 15% to $10,600 (individuals) and $21,200 for families.
Enrollment
The Biden-Harris Administration extended the Marketplace Open Enrollment Period (OEP) to roughly 75 days — from November 1 to January 15 — and created a monthly Special Enrollment Period (SEP) for people at or below 150 percent of the federal poverty level.
The new HHS proposed rule would:
again limit the annual OEP to 45 days from November 1 through December 15 and extend this federal requirement to state-based exchanges
eliminate the monthly SEP for eligible low-income Americans — including those transitioning from Medicaid or CHIP — and impose SEP income verification requirements for at least 75% of new enrollees
Any kind of administrative change can adversely affect enrollment. This was one of the primary concerns of the Medicaid unwinding through 2024. HHS’s proposed Marketplace rule raises similar worries.
Eligibility and administrative burdens
HHS has already significantly reduced Marketplace and Medicaid consumer navigator funding from a Biden Administration annual high of $100 million to $10 million. If finalized, the HHS proposed rule could:
eliminate Marketplace eligibility for Deferred Action for Childhood Arrivals recipients. These are the “Dreamers,” or undocumented immigrants who were brought to the United States as children
prohibit gender-affirming care as a Marketplace essential health benefit
deny guaranteed issue to enrollees with past-due premiums
In addition to the above, new/reinstated administrative requirements could also negatively impact eligibility, enrollment and affordability including:
New upfront cost for auto-re-enrollment. $0 premium plans with no coverage changes would incur a $5 monthly premium at re-enrollment until enrollees confirm their eligibility.
Loss of coverage due to premium underpayment. Marketplace premium payments are based on income, which can be difficult to estimate accurately for self-employed and gig workers. Those who underpay their premiums by even a small amount could lose coverage if they do not re-verify income and within a tighter time frame. Citing fraud concerns, HHS notes that this action would reduce federal APTC spending by $820 million in 2026.
Loss of coverage due to premium tax credit reconciliation. Consumers who don’t meet reconciliation requirements could also lose coverage, even though administrative errors and IRS delays could wrongly classify them as non-compliant.
HHS estimates that these measures could save $1.16–$1.86 billion annually, but this would come at the expense of consumers. Hundreds of thousands could lose their APTC eligibility and become uninsured. Health Affairs notes that these changes are likely to impact young, healthy consumers disproportionately — worsening the insurance risk pool and likely driving premiums higher.
Timing
Components of the HHS rule would take effect with differing deadlines, many of which would be unrealistic and unfair per Health Affairs. For example, the elimination of the monthly SEP for low-income consumers would be effective with the final rule versus the end of the 2025 plan year, when enhanced premium subsidies could very likely expire.
We’ll all know a lot more after 30 days, when the comment period ends and HHS works to finalize the rule.
A 'dizzying array' of actions in the first seven weeks of President Donald Trump's second term.
In prior years, the Medicaid unwinding dominated healthcare headlines. Would the resumption of post-pandemic eligibility verifications trigger the disenrollment of millions of Americans? In the words of the Magic 8-Ball: "It is (was) decidedly so."
In the first few months of 2025, there is a new unwinding — the reversal of wide swaths of U.S. healthcare policy now that Administration has transitioned from Biden-Harris to Trump-Vance. As Health Affairs notes, the first 50 days of Trump's second term represent a "dizzying array" of executive orders and announcements in the multiple areas. HealthLeaders has coalesced these into eight major policy areas:
Cost: Hospital and prescription drug transparency
Public Health: Global and domestic policy
Chronic Conditions: The Make America Healthy Again Commission
Reproduction and Gender/Sexuality: Fertility, discrimination
Telehealth: Controlled substances
Prevention and Prescription Drugs: ACA litigation and price negotiation
SDOH: Funding for Medicaid waivers
ACA: Navigator funding and the first Marketplace regulations
The nitty-gritty of this list ranges from cost transparency and negotiation to public, reproductive and social health to what the future holds for the ACA and its now-booming Marketplace.
Cost: Hospital and prescription drug transparency
A new executive order and fact sheet continues actions from both Trump's first term and the Biden Administration.
During the first Trump Administration, an executive order and HHS rule required hospitals to post their prices publicly. For health plans, HHS, Department of Labor, and Department of Treasury rules required consumer-facing pricing tools.
The second Trump Administration seeks tougher hospital oversight. This includes the posting of actual versus estimated prices, which are to be standardized and comparable across hospitals, health plans, and insurers.
The new administration also requires health plans to publish prescription drug price with possible new enforcement actions.
Public Health: Global and domestic policy
The Trump Administration is shifting U.S. public health agenda significantly and in multiple areas:
Global public health: The planned withdrawal from the World Health Organization and the dismantling of the United States Agency for International Development (USAID). The latter affects everything from HIV, malaria and other transmissible diseases to food security.
Vaccine funding and research: A variety of actions that have slowed FDA and CDC vaccine recommendations, could fund CDC research into a vaccine-autism link despite existing lack of evidence, and cancel development a $590 million Moderna bird flu vaccine.
Public information: Access is being restored to multiple public health websites and datasets — HHS, CDC, FDA, the Youth Risk Behavior and National Assisted Reproductive Technologies Surveillance Systems, as well as HIV and LGBTQ youth health disparity pages — after a Trump Administration pulldown with litigation still in progress.
Chronic Conditions: The Make America Healthy Again Commission
A February 13 executive order established the Make America Healthy Again (MAHA) Commission to understand and reduce chronic conditions, including among children. MAHA Commission requirements include a Make Our Children Healthy Again Assessment and Strategy that will assess "threats" posed by prescription medications (e.g., anti-depressants, weight-loss drugs). It will also assess how effective certain federal health data and metrics are (e.g., National Survey of Children's Health).
New HHS Secretary Robert F. Kennedy, Jr. will chair the cabinet-level MAHA Commission, which will include leaders from the FDA, CDC, and the National Institutes of Health (NIH).
Reproduction and Gender/Sexuality: Fertility, care, discrimination
Multiple executive orders look to affect the following:
In Vitro Fertilization (IVF): Added protections to "aggressively reduce out-of-pocket and health plan costs for IVF treatment" — policies that may not extend to same-sex couples or single Americans.
Gender dysphoria treatment: A disruption of evidence-based gender-affirming care, particularly for minors, which "could enable health care discrimination against transgender people."
Federal definitions: HHS proposals for sex and related terms going forward, which "could have widespread implications for agency operations."
Telehealth: Controlled substances
HHS and DOJ extended the effective dates of two Biden Administration rules that will clarify when providers can prescribe select controlled substances to patients via telehealth. One rule pertains to Buprenorphine and other drugs used to treat opioid use disorder, the other to schedule II-V prescriptions by Veterans Affairs providers. The new effective date is Mar. 21, 2025.
SDOH: Funding for Medicaid waivers
HHS rolled back Biden Administration guidance that funded social drivers of health (SDOH) benefits in Medicaid and CHIP. Existing waivers may continue but the approval of future waivers is unclear. Medicaid waivers have become a proving ground for SDOH benefit expansion and could continue to be for even more enrollees. KFF reports that — even after the eligibility redeterminations that disenrolled more than 25 million people — overall Medicaid and CHIP enrollment is 10 million higher than before the COVID-19 pandemic.
Prevention and Prescription Drugs: ACA litigation and price negotiation
The Trump Administration is defending some Biden-era lawsuits. The most significant examples are the:
ACA's preventive services coverage mandate, with a Supreme Court decision expected this summer
Medicare drug price negotiation program, currently with the Third Circuit Court of Appeals.
The Administration is holding on other lawsuits, including those related to short-term, limited duration health insurance (STLDI). HealthLeaders previously covered the Obama-Trump-Biden do-si-do over STLDI term lengths and differing opinions about the effect these policies could have on the ACA Marketplace risk pool.
ACA: Navigator funding and the first Marketplace regulations
Speaking of the ACA, it will be one of the most closely watched healthcare policy areas of the second Trump Administration. Before last week, it was suspected though not yet known how Trump's "concepts of a plan" for U.S. healthcare coverage would play out. Now we know.
First was the announcement that HHS would significantly reduce funding for Marketplace and Medicaid navigators who help consumers select plans — from a Biden Administration annual high of $100 million to $10 million. Next came the first major healthcare regulation of Trump's second term, one that Health Affairs characterizes as a move to "restrict marketplace eligibility, enrollment, and affordability.
More on that next week as HealthLeaders digs into the HHS proposed Marketplace Integrity and Affordability rule.
Aetna’s Medicare CMO outlines the potential of Medicare Advantage “to keep people happy, healthy and at home.”
Is our healthcare system well-equipped to support healthy aging? There are many ways to answer the question, from access and affordability to disease and mortality rates to Star Ratings. Answering well would require volumes.
How does the role of supplemental benefits and Special Needs Plans in the aging-care healthcare ecosystem of the country’s fourth-largest MA plan? We interviewed Dr. Ali Khan, Chief Medical Officer of Medicare at Aetna, a CVS Health company. Khan is also a practicing physician providing primary care for older adults on Chicago’s west side at Oak Street Health, also a part of CVS Health.
The ”whole ecosystem” of aging care
HealthLeaders asked Khan about one aging care model — patient-centered medical homes for seniors, with care coordinated by geriatricians — and how Medicare was performing in this respect and what it could do better.
“This is the active talk track for a lot of my day. I wish we had enough geriatricians and gerontologists to staff that kind of work,” says Khan.
“But any great clinician is thinking about more than just a patient’s lab numbers. They’re thinking: ‘What about the whole ecosystem of care, of health, and how do we put that together?” Khan said. “Is the patient trying to get to a doctor’s appointment? Do they have security challenges?’”
Khan adds: “Our goal from a Medicare Advantage perspective is to fill in those gaps, the missing pieces in a member’s day-to-day life — the places where their clinical teams are so busy taking care of patients, that they need a secondary player like us to come in and connect those dots.”
Khan provides a few examples of how Medicare Advantage “can unlock private sector innovation beyond traditional Medicare.” These include fitness benefits and social isolation support.
“We are making sure that every Aetna member has access to Silver Sneakers across 1,500 locations” says Khan. Silver Sneakers is a fitness benefit that expands behind exercise classes to include online/digital app education and support.
“We also know that 33% of older adults feel lonely. It’s the biggest health risk factor in our time. As a result, we spend a lot of time on social care connectivity programs.”
Khan also cited Aetna’s Resources for Living® Program, which connects members and/or their caregivers with community services and resources.
“Resources for Living helps members figure out how they want to live their lives and navigate related resources with an omni-channel approach [e.g., interaction via digital apps, phone, email, traditional mail]. Being able to offer these core services through our supplemental benefits program becomes really powerful.”
How supplemental benefits support aging care
Supplemental benefits are a key differentiator of Medicare Advantage. They represent extra benefits — dental, vision, and hearing, as well as SDOH services like transportation and in-home services — that original Medicare does not offer.
Khan noted that Aetna members “are excited about supplemental benefits and what they provide.” This includes care innovation.
“Over the past 10 years, there has been great innovation across all health plans to support people with food insecurity, to give them access to healthy meals — whether that's right after hospitalization or on a more regular basis.”
In addition to Silver Sneakers and Resources for Living, Khan cited the Aetna/CVS Health Extra Benefits Card, which provides a monthly allowance toward every day expenses like food, transportation, even durable medical equipment.
“Members make those decisions, and that helps give them autonomy.”
In addition to autonomy, supplemental benefits must deliver “real clinical impact” and support healthy aging while offering “a proactive journey for members.” Here Khan applauds the power of proven programs outside of Aetna. One example is Capable, a Johns Hopkins University School of Nursing program that launched in 2009 and sends teams of nurses and carpenters into patient homes to identify needs and make repairs in real time.
“Capable was profoundly useful in reducing medical costs and improving quality of life for patients with low incomes,” says Khan. “So today at Aetna, we’re asking: How do we do that same kind of work? We don't have any carpenters in homes yet, but how are we proactive? How do we prevent problems before they start?’”
Khan asks these questions from personal experience, specifically his grandfather who had been a professor.
“We didn't catch my grandfather’s hearing loss. Two years later when his dementia became very abruptly noticeable, we realized that my grandmother had been covering for him for a long time. The biggest thing that his team said is that if we'd caught his hearing loss earlier, it probably would have enabled him to stay more socially connected.”
How Special Needs Plans support aging care
Supplemental benefits in Medicare Advantage help address the needs of specific members, including those enrolled in Special Needs Plans (SNPs). These plans cover those who are chronically ill (C-SNPs) and those who are dually eligible for Medicare and Medicaid (D-SNPs).
Two examples at Aetna include fall prevention services, which are a standard plan benefit for D-SNP members, and in-home supports for C-SNP members with congestive heart failure. The latter includes wireless scales that do not require member WiFi but can provide remote monitoring data on weight and fluids without a hospital or office visit.
These aren't just nice-to-have benefits. They can make a real difference,” says Khan.
“The shift is toward keeping people healthy at home,” says Khan. “That’s true across the board, but it gets really interesting within different cohorts of patients across different generations, even people who are potentially in their last year of life.”
How Aetna’s CVS connections support aging care
Aetna is not the only partner in these efforts. As a CVS Health company, it collaborates with the pharmacy-clinic retailer and its other companies. They are Signify Health, a technology and services company with a network of 10,000 clinicians who support in-home care in 50 states, and Oak Street Health, a network of comprehensive primary-care centers for older adults.
Khan details how all four companies work together.
“Now, Aetna can leverage reminders from CVS pharmacists right at point of care. Or identify high fall risk based on Signify Health’s home health assessments. Or deliver high-value primary care through provider networks like Oak Street.”
“We're here to shift care from reactive to proactive,” says Khan, adding that “the potential of Medicare Advantage is to show how benefit and resource coordination come together to keep people happy, healthy and at home.”
The Aetna Medicare CMO concludes: “The more we are doing to provide common sense benefits and ensure members understand what they're eligible for, the more we're connecting the dots. That's the work we're here to do.”
A 'renewed call to action to address affordability' leaves all options on the table.
Per the University of Michigan Value-Based Insurance Design Center, VBID aims to lower or remove "financial barriers to essential, high-value clinical services" (e.g., increased use of preventive and essential chronic care. It also seeks to decrease spending on low-value services that provide "little or no benefit to patients, have potential to cause harm, incur unnecessary cost to patients, or waste limited healthcare resources" (e.g., prescribing branded drugs over available generics).
As noted in Part I of this series, VBID improved outcomes but cost CMS $4.5 billion in model years 2021 and 2022. But for those ready to write the model off, consider these 2025 statistics:
67% of Americans are concerned about healthcare affordability — a 10% jump from 2024 (Pew Research Center)
medical costs that are the highest in 13 years per PwC, which further cited . . .
an 8% spike in group insurance medical spend
In an environment where healthcare costs present considerable risk, can any option be taken off the table? Part II summarizes how the VBID model could succeed, the MA model lessons learned, and why value-based care in general must somehow achieve the impossible.
'Not to save money'
A Health Affairs post-mortem notes that CMS’s termination of the MA model "should be interpreted as an assessment of the specific design of this program as opposed to a conclusion about the general cost (or potential) of VBID as a concept."
"The primary goals of V-BID programs in general, and the MA-VBID model specifically, are to increase access to care, enhance equity, and ultimately improve the health of Medicare beneficiaries – not to save money."
Did we misunderstand what VBID was supposed to accomplish — perhaps value-based care (VBC) in general — or do we need to accept that improving both cost and quality is nearly impossible? How can we, given unabated healthcare inflation?
How VBID can succeed — and more reasons it didn’t in MA
Health Affairs adds that VBID has demonstrated its ability to "increase adherence to high-value services, reduce disparities, improve patient outcomes, and in some instances decrease expenditures. The latter is where VBID failed spectacularly in MA, due to the risk adjustment and rebate payment spikes mentioned in Part I of this series — and three other reasons:
The use of more high-value services (i.e., more good things still increase spending)
The lack of specific deterrents for low-value services (e.g., payment/benefit design changes)
Uncounted downstream savings due to a short evaluation period (e.g., lower long-term disease management costs)
"Instead," note the authors from U of M and its VBID Center, "assessments of whether the gains in health achieved are worth the additional money spent should be conducted on the same level playing field as other health care interventions."
MA lessons learned and those 2030 goals
VBID’s failure in MA did create some successes and lessons learned. Health Affairs notes that
MA plans can now offer many of VBID’s supplemental benefits more broadly (e.g., Special Supplemental Benefits for the Chronically Ill, or SSBCI).
CMS’s press release on VBID’s MA termination cited lessons that will inform "broader MA program policies, including strategies to improve:
population health outcomes and health equity through the continued screening of health-related social needs linked to supplemental benefits
understanding of benefit use through better data collection and reporting
medication adherence through reduced Part D cost sharing
These lessons learned and continued strategies will be important for CMS to meet its goal of having all Medicare beneficiaries in a value-based arrangement by 2030.
Can value-based care be an either/or proposition?
Value-based care has been the unattained gold standard in healthcare for more than a decade. But expecting it to deliver like the consumer electronics industry — innovation that makes products better and cheaper — has proven unrealistic.
The Health Affairs post-mortem for MA VBID MA noted: "There are practically no health programs or clinical services — including almost all health quality metrics — that save both lives and money."
Improving outcomes while lowering costs may be notoriously difficult to do. But with rising inflation and sinking consumer confidence, does the industry have a choice left but to try?
What's next when policy can't fix what policy created?
Last December, CMS announced that it would terminate the Medicare Advantage Value-Based Insurance Design (MA VBID) model due to “substantial and unmitigable costs to the Medicare Trust Funds.”
How substantial? More than $2 billion annually in both 2021 and 2022. Why these spikes? That is a more complicated question, as are others on whether VBID can succeed more broadly and what that will require.
What is VBID?
First conceptualized in 2005 by the University of Michigan Center for VBID (UM VBID Center), Value-Based Insurance Design “is built on the principle of lowering or removing financial barriers to essential, high-value clinical services.” In its response to CMS’s termination of the model, the Center added that VBID “aims to lower out-of-pocket costs for high-value services while discouraging spending on low-value care.”
Low-value care includes services “that provide little or no benefit to patients, have potential to cause harm, incur unnecessary cost to patients, or waste limited healthcare resources.” High-value services include the increased use of preventive and essential chronic care.
But there is also a fine line between low and high value. For example, PSA screening for prostate cancer saves lives (high value) but becomes low-value for older men (age 70+). This per the Task Force on Low-Value Care, which in 2017 included this screening in its Top Five List of low-value services:
Vitamin D screening tests
Diagnostic tests before low-risk surgery
Imaging within six weeks of low-back pain onset
Branded drugs when identical generics are available
From January 2012-May 2019, waste from low-value care — a/k/a “overtreatment" — totaled $12.8-28.6 billion.
VBID: Outcomes versus cost in MA
It’s not unusual for CMS and its Innovation Center (CMMI) to retire models. In fact, it’s required if models do not generate savings or improve outcomes with cost neutrality for Medicare within a specified time.
Launched in 2017, the MA VBID model sought to enhance healthcare access for chronically ill and underserved populations by reducing cost-sharing and offering supplemental benefits. These benefits are often associated with the social drivers of health (SDOH), such as lack of access to healthy food or transportation to medical appointments. The model also sought to increase health improvement activities (e.g., preventive screenings, care management and/or disease management (CM/DM)
The MA VBID model didimprove outcomes, specifically patient adherence to cholesterol and diabetes medication, as well as breast cancer screening.
It also cost Medicare an additional $2.3 billion in 2021 and another $2.2 billion in 2022.
This spike — after three-plus years of relative cost neutrality, if not savings — was a bridge too far, for CMS. Its press release terminating VBID, the agency noted that its excess costs “were unprecedented in CMS Innovation Center models” and that “no viable policy modifications” could address them.
How bad does a model have to be to earn those assessments? Or is there simply a limit to
what a model can and cannot achieve if cost and quality expectations are not realistic? Are the conclusions different for VBID when applied to Medicare Advantage versus other programs and populations?
Let’s assess.
VBID: A glass half full or half empty?
In a Health Affairs post-mortem, UM personnel — including VBID Center director Dr. A. Mark Fendrick — note that CMS’s termination of the MA model “should be interpreted as an assessment of the specific design of this program as opposed to a conclusion about the general cost (or potential) of VBID as a concept.”
The article adds that a “robust evidence base demonstrates that V-BID interventions increase adherence to high-value services, reduce disparities, improve patient outcomes, and in some instances decrease expenditures.” The article concludes that “the primary goals of V-BID programs in general, and the MA-VBID model specifically, are to increase access to care, enhance equity, and ultimately improve the health of Medicare beneficiaries – not to save money.”
VBID wasn’t required to save money for the Medicare program. But costing it $4.5 billion in two years is another matter.
The problem is that at least some of the problems that plagued the VBID MA model plague the MA program in general — namely risk code and rebate finagling. Per Health Affairs:
Substantially higher risk scores increased CMS payments to MA plans for VBID enrollees. Higher scores help if more patients who need more care are identified. They hurt if they represent upcoding, an MA plan practice that inflates patient risk scores artificially to bilk money from Medicare.
Higher rebates increased these payments further. Every year, MA plans submit bids for how they will cover the expected costs of providing Medicare Part A and B services. Bids below benchmarks earn plans a percentage of money back based on their Star Ratings (rebates). Higher rebates under MA VBID were thus attributed to higher quality care.
Such is the paradox of value in healthcare and why few to no models can improve cost and quality unilaterally.
In Part II of this series, HealthLeaders will explore what the high cost of VBID in Medicare Advantage means for the model — and for value-based care — in general.
More answers from the KFF Marketplace webinar and a plea that five years of progress not be undone.
In its Feb. 10 webinar, the Kaiser Family Foundation (KFF) posed the question “What’s Next for the Affordable Care Act?” — and attempted to answer it with three more. Based on the impact of premium subsidies and their possible expiration:
Is the Marketplace broken or largely successful?
If the Marketplace is broken, how will future reforms succeed where past attempts have failed?
Are continued subsidies part of the problem or part of the solution?
The KFF event and its panel explored these questions from divergent viewpoints
Is the Marketplace broken or largely successful?
When asked how to prevent uninsured without premium subsidies, Brian Blase — President-Paragon Health Institute — made a blanket declaration,
“The Biden administration policies really juiced enrollment along with the expanded subsidies . . . They also created a Special Enrollment Period (SEP) for anyone claiming income between 100-150% of FPL to sign up at any point in time during the year.”
Blase added: “Now, if you combine that with the fact th
greatly reduced funding for navigators who help people enroll
at they're also not checking income, I don’t think this is a well-run approach to a government program.”
Refuting these claims was Sarah Lueck, VP Health Policy-Center on Budget and Policy Priorities, who added that a “series of policy changes” made the Marketplace “a lot harder to access under Trump.” These included:
shorter open enrollment periods
more restrictions placed around SEPS
“I don't want to see that happen again,” Lueck added. “There were a lot of things changed for the better . . . just opening the door and giving people more opportunities and time to enroll was extremely important.”
The debated hinged on how the panelists viewed the Marketplace. Blaser cited the importance of stabilizing a deteriorating market during Trump’s first administration, while Lueck replied:
“We’re not talking about Marketplace stabilization anymore. We have to be careful and recognize where we are versus the environment of 2017. The Marketplace is working pretty well. There is record enrollment, and we don’t see huge drop-offs of enrollment during the year that we used to.”
If the Marketplace is broken, how will future reforms succeed where past attempts have failed?
Blase indicated he would want to “eliminate enhanced premiums subsidies entirely and focus on regulatory reforms.”
“Americans should have the right to spend their own money financing healthcare as they think best meets their needs.”
Here, Blasé includes short-term limited-duration insurance (STLDI) plans and his belief that they offer greater value via provider choice, benefits and affordability.
[STLDI has pros and cons, particularly as a replacement for comprehensive coverage and its adverse effects on the Marketplace. The first Trump Administration expanded STLDI options, lauded in Trump’s 2020 budget. The Biden Administration narrowed them again, For a refresher, revisit our two-partseries.]
Blase also defines value as having skin in the game.
“Full subsidization discourages insurers from designing plans that enrollees actually value enough to pay a small fraction of the premium. This modicum of value helps protect against fraud.”
Lueck again rebutted: “Fraud is always raised as reason to tighten programs and cut spending by federal government. The Trump Administration is already looking at healthcare and other programs as a way to fund other initiatives.”
After the September debate between candidate Trump and then-Vice President Kamala Harris, Larry Levitt — EVP of KFF and moderator of its panel — noted the attempts of the first Trump Administration’s to look at healthcare.
“He did, in fact, propose the concept of an ACA replacement plan in his 2020 budget, though it has never gotten much attention . . . [It] would have repealed the ACA’s premium subsidies and Medicaid expansion, replacing them with a block grant to states. It also would have capped federal Medicaid spending. All told, Trump’s plan would have reduced federal spending on the ACA and Medicaid by over $1 trillion over a decade.”
Are continued subsidies part of the problem or part of the solution?
Here, Blase answers: “Proof that the ACA is broken is that affordability requires substantial subsidies that health plans then profit from. Insurers make more from government than the private market.”
“I think that’s a problem,” he continues. “Too much subsidization.”
Blase only supports continued subsidies at 400% FPL “until there are some broader ACA alternatives — especially for middle- and upper-income people.”
Neither Lueck nor the third panelist — Cynthia Cox, VP-KFF — cited specific alternatives. Confident that the Marketplace is working well, Lueck stressed that the tremendous progress of the past five years should not be undone.
“I think there's such a strong case to be made, even just thinking about the last election, that people want more financial security. They want lower costs out of their pocket.”
“We're in a place where we've made a lot of progress, and we certainly have a lot of work to do. But I think making more people uninsured, raising people's costs, reducing program eligibility, and making people go through more red tape to get coverage is going to be the wrong direction.”
