IHPP - Impact Weekly, March 23, 2026

Summary

Congress remains focused on the expired Department of Homeland Security (DHS) and the SAVE Act, which are increasingly becoming intertwined. While support is building for passing a DHS funding package that carves out Immigration and Customs Enforcement (ICE) funding, President Trump refuses to sign any DHS funding bill until the SAVE Act is passed. Republican leadership is also preparing for a $200 billion supplemental funding request from Pentagon, which will likely require reconciliation and significant offsets to garner party support. Congress has until the end of the week before it recesses for two weeks.

Final Rule for Health Care Attachment and Electronic Signature Standards

On Friday, the Centers for Medicare and Medicaid Services (CMS) published the Administrative Simplification; Adoption of Standards for Health Care Claims Attachments Transactions and Electronic Signatures Final Rule (text; press release; fact sheet). The rule finalizes a proposal made by the Biden Administration in 2022 that is intended to help the health care system move to more streamline electronic transactions. The final rule establishes Health Insurance Portability and Accountability Act (HIPAA) standards for health care claims attachment and enables the secure exchange of claims-related supporting clinical documentation such as medical records, x-rays, imaging, clinical notes, telemedicine documentation, and laboratory results. The rule finalizes to use Version 6020 of the X12N 275 and 277 standards for administrative transactions; and HL7 Consolidated Clinical Document Architecture (C-CDA) Implementation Guide (IG) Volume One, HL7 C-CDA Volume Two, and HL& Attachments IG for attachment information. Additionally, the rule establishes requirements to authenticate electronic signatures. The final rule is effective May 26, 2026, and compliance dates begin 24 months after the effective date.

CMS highlights that the rule is projected to save the health care industry $781 million annually, reduce administrative burden, speed up care delivery, enhance security, and improve efficiency for providers and payers.  Importantly, the final rule excludes the proposed inclusion of prior authorization attachments and focuses only on claims, a decision made in response to public feedback about misalignment with the current X12 standard for prior authorization and conflicts with other CMS rulemaking.

MAHA Update

The Centers for Disease Control and Prevention’s (CDC’s) Advisory Committee on Immunization Practices (ACIP)  March meeting was cancelled following a court injunction finding that Department of Health and Human Services (HHS) Secretary Robert F. Kennedy JR.’s appointments to the committee are likely invalid under the Federal Advisory Committee Act. The judge said that the appointments did not follow requirements that advisory committees be composed of experts on the relevant subject matter with balanced perspectives. The lawsuit was brought by the American Academy of Pediatrics alongside other medical organizations. The ruling temporarily reverses changes made by the new ACIP as the court case moves forward. HHS is now deciding whether to appoint new members in order for the committee to meet or to focus on challenging the ruling.

According to a leaked report, ACIP had planned to discuss claims that COVID-19 vaccines caused widespread injuries, with a vote on recommendations to create new diagnostic coding, publish diagnostic guidelines, and establish a new centers of excellence program to research COVID-19 vaccine injuries and long COVID. This leaked report shows work that goes far beyond ACIP’s typical purview of making vaccine recommendations.

Relatedly, a CDC committee voted to advance an International Classification of Diseases (ICD-10) code related to adverse effects from COVID-19 vaccines which could be implemented as early as 2027 once it is included in proposed rulemaking. A code would make it easier to track and study report injuries. Opponents say that there is not enough understanding of COVID-19 vaccine injury to add a new code and that it would make more sense to conduct other surveillance first.

Regulatory Update

The Office of Management and Budget completed its review of the following:

 

• Immigration Status. A Department of Labor proposed rule titled, “Improving Wage Protections for H-1B and PERM Employment in the United States.”

 

OMB is also reviewing:

• Coverage and Payment:
  • Medicaid:
    • State Directed Payments. A proposed rule titled, “Medicaid Managed Care State Directed Payments and Medicaid Fee-For-Service Targeted Medicaid Practitioner Payments.” The proposed rule appears intended to advance a presidential memorandum released on June 6, which directs HHS to “eliminate waste, fraud, and abuse in Medicaid, including by ensuring Medicaid payments rates are not higher than Medicare, to the extent permitted by applicable law.” On February 27, the title of the proposed rule was revised to include Medicaid FFS targeted Medicaid practitioner payments.
    • Medicaid Tax Waivers. A proposed rule titled, “Amending the Indirect Hold Harmless Threshold of Health Care-Related Taxes.”

• • FY 2027 payment proposed rules for hospitals and long-term care hospitals, inpatient psychiatric facilities, hospice facilities, and skilled nursing facilities.
  • Medicare Advantage:
    • Policy and Technical Changes.The Contract Year 2027 Policy and Technical Changes to Medicare Advantage, Medicare Prescription Drug Benefit, Medicare Cost Plan, and Programs of All-Inclusive Care for the Elderly Programs final rule.
    • Payment: Announcement of Calendar Year 2027 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies (the “CY 2027 Rate Announcement”) notice.
• No Surprises Act. A final rule titled, “Independent Dispute Resolution Operations.” Thing long-awaited rule was proposed in November 2023 by the Biden Administration.
• Prescription Drugs
  • Prior Authorization. A proposed rule on interoperability standards and prior authorization for drugs.
  • Price Negotiation. A proposed rule titled, “Medicare Drug Price Negotiation Program.”

• Oversight and Integrity
  • Fraud and Abuse. A proposed rule titled, “Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH).”
  • Accrediting Organizations. A final rule titled, “Strengthening Oversight of Accrediting Organizations (AO), Burden Reduction, and Related Provisions.”

• Nutrition
  • Work Requirements. A proposed rule titled, “Supplemental Nutrition Assistance Program: Modification to Work Requirements for Able-Bodied Adults.”
  • Categorical Eligibility. A proposed rule titled, “Supplemental Nutrition Assistance Program: Reforming Categorical Eligibility.”
• Other Topics:
  • An interim final rule titled, “Unaccompanied Children Program Foundational Rule; Update to Include Proof of Identity and Income Verification Standards.”
  • Medication-Assisted Treatment. A final rule titled, “Implementation of the SUPPORT Act: Dispensing and Administering Controlled Substances for Medication-Assisted Treatment.”