IHPP - Weekly, December 1, 2025

Summary

Last week, President Trump indicated that the White House was preparing a proposal to extend the enhanced premium tax credits (EPTCs) for two years that also featured: 1) limiting subsidies to individuals up to 700 percent of the federal poverty level (FPL); 2) implementing a minimum premium for enrollees, and; 3) allowing enrollees to contribute some of their subsidy to a health savings account (HSA).

The potential proposal faced immediate backlash from both Democrats and Republicans, with House Democrat leaders describing the proposal as “another unworkable attempt to undermine the nation’s health care system and hike costs on millions of people,” and House Speaker Mike Johnson (R-LA) asserting that House Republicans do not support extending the subsidies. However, the Main Street Caucus, which consists of 86 House Republican members pushed back against speaker Johnson and expressed their support for President Trump’s effort to address the expiring subsidies.

On the Senate side, the Health, Education, Labor, and Pensions Committee Chair Bill Cassidy announced a hearing to be held on Wednesday, which will examine the rising health care costs and subsidy reform options. This comes ahead the Senate’s planned vote next week on a clean one-year extension of the EPTCs, which will likely result in a partisan vote.

MAHA Update

On November 24^th, HHS announced five new agency leaders chosen to advance the goals of the Make America Healthy Again (MAHA) movement. Four of the five appointees have been confirmed by the Senate. These individuals include:

• Brian Christine, Assistant Secretary for Health – Dr. Christine is a urologist and a leader in men’s health issues. As Assistant Secretary for Health, he will lead the U.S. Public Health Service Commissioned Corps and focus on restoring trust in public health, radical transparency and chronic disease.
• Alex Adams, Assistant Secretary for Family Support at the Administration for Children and Families – Adams comes from the Idaho state government as a budget and regulatory director and Department of Health & Welfare director. In this role he worked to improve the child welfare system by extending the age of foster care to 23 and supporting foster homes.
• Gustav Chiarello, Assistant Secretary Financial Resources – Chiarello previously served as Senior Special Counsel to the House Committee on the Judiciary and on the Subcommittee on the Administrative State, Regulatory Reform, and Antitrust. Before the Hill, Chiarello worked as an attorney at the Federal Trade Commission (FTC). At HHS, Chiarello will focus on reducing health care spending, enhancing access to care and medicines, and revitalizing science.
• Michael Stuart, General Counsel – Stuart is a former U.S. Attorney who led the prosecutions of elder fraud, Medicaid fraud, and drug takedowns. Stuart is also Chair of the West Virgina Republican Parter and is a partner at two major law firms. At HHS, he will focus on fraud, waste, and abuse.
• Alicia Jackson, Director of the Advanced Research Projects Agency for Health (ARPA-H) – Dr. Jackson founded and acted as CEO of Evernow, a company focused on women’s health in longevity, following her departure from being Deputy Director of the Defense Advanced Research Projects Agency (DARPA) Biological Technologies Office. Dr. Jackson was chosen to lead ARPA-H to biotechnology breakthroughs and address major health challenges.

Regulatory Update

The Calendar Year (CY) 2025 Home Health Prospective Payment Rate Update final rule was released over the Thanksgiving break and Impact Health will be sending a summary out shortly.  The Office of Management and Budget (OMB) also completed its review of a rule to repeal the minimum staffing standards for long-term care facilities.

The OMB is currently reviewing the following:

• *NEW* ACA Marketplace: The HHS Notice of Benefit and Payment Parameters for 2027 proposed rule
• Medicare:
  • Procurement of Domestic PPE. An advance notice of proposed rulemaking that would detail program incentives and requirements for Medicare providers and suppliers to invest and phase-in the procurement of American made personal protective equipment (PPE) and essential medicine to secure our nation’s health and safety.

• Medicaid:
  • Gender-Affirming Care.
    • A proposed rule titled, “Medicaid Program; Prohibition on Federal Medicaid Funding for Sex Trait Modification Procedures Furnished to Children and Youth.”
    • A proposed rule titled, “Medicare and Medicaid Programs; Hospital Condition of Participation: Limiting Participation Based on the Performance of Sex Trait Modification Procedures on Children.”
  • State Directed Payments. A proposed rule titled, “Medicaid Managed Care-State Directed 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.”
  • *NEW* Medicaid Tax Waivers. A proposed rule titled, “Preserving Medicaid Funding for Vulnerable Populations – Closing a Health Care-Related Tax Loophole.”

• Prescription Drugs:
  • A proposed rule titled, “Improving Transparency into Pharmacy Benefit Manager Fee Disclosure” and a proposed rule addressing Transparency in Coverage requirements.
  • CMMI Drug Pricing Models. A proposed rule for a Global Benchmark for Efficient Drug Pricing (GLOBE) Model and a proposed rule for Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model

• Nutrition:
  • Head Start. A notice from the Administration for Children and Families titled, “Publish Request for Information: Nutrition Services in Head Start Programs

• Immigration:
  • Unaccompanied Children. An interim final rule titled, “Unaccompanied Children Program Foundational Rule; Update to Include Proof of Identity and Income Verification Standards.”