The current policy environment is both highly uncertain and uniquely impactful on health system finances, with a wide range of potential changes ahead that will layer on top of recent disruptions. Regulatory proposals like Medicaid work requirements and site-neutral payments could decrease revenues, while executive action on tariffs and immigration enforcement could increase costs.
Health system leaders need to assess the impact of a range of different policies — and their severity — on their organizations. We propose a three-step model to size the range of potential impacts on your organization.
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Because executive and congressional decisions are still in flux, health system leaders need to account for a range of possibilities within each category. For example, Medicaid cuts are likely to happen in some form but may be limited to work requirements, which would have a comparatively smaller impact on health systems since they affect mostly healthier beneficiaries. Broader cuts would impact sicker and higher-use populations in addition to health segments and therefore have a deeper impact on financial performance. Health system leaders need to understand the range of possibilities across all categories.
We’ve categorized policies into mild, moderate, and severe scenarios based on their impact on health system finances. Increasing severity corresponds to larger cuts to revenue or expense increases.
Policy category | Mild scenario | Moderate scenario | Severe scenario |
---|---|---|---|
Medicaid cuts | Work requirements in place for a subset of Medicaid beneficiaries. | Combination of work requirements and elimination of the Medicaid expansion federal match rate. | Combined work requirements, elimination of the Medicaid expansion federal match rate, and immigration penalty. |
Medicare cuts | Under S-PAYGO, reductions in Medicare spending amount to a 1% cut. | Under S-PAYGO, reductions in Medicare spending amount to a 2% cut. | Under S-PAYGO, reductions in Medicare spending amounts are limited to a 4% cut. |
340B cuts | Following an HHS survey of hospital acquisition costs, CMS reduces drug reimbursement rates by 28.5% for 340B hospitals. | Following the results of the survey, CMS reduces drug reimbursement rates by 34.7% for 340B hospitals. | Following the results of the survey, CMS reduces drug reimbursement rates by 36% or more for 340B hospitals. |
ACA Marketplace cuts | Mild cuts to ACA health insurance exchange subsidies (e.g., Deferred Action for Childhood Arrivals (DACA eligibility, excess subsidy recapture). | Multiple cuts to ACA subsidies (e.g., DACA eligibility, excess subsidy recapture). | Multiple cuts to ACA subsidies (e.g., DACA eligibility, excess subsidy recapture) and wider marketplace reform including increasing administrative barriers to enrollment and beneficiary cost sharing. |
Tariffs | Negotiated reductions to April 4th tariffs or targeted exemptions to drugs and/or medical supplies. | April 4th tariffs stand across categories. | Retaliatory tariffs raise prices beyond April 4th tariff rates. |
Federal grants | Cuts to HHS, NIH, and other grant-making agencies amounting to 25% of funding for research and community services. | Cuts to HHS, NIH, and other grant-making agencies amounting to 50% of funding for research and community services. | Cuts to HHS, NIH, and other grant-making agencies amounting to 100% of funding for research and community services. |
The impact of policy changes will vary depending on the health system. For example, health systems with higher exposure to Medicaid patients will see a larger impact than those with a payer mix dominated by commercial payers. We group those internal factors into three categories, which amplify or mitigate the impact of different federal policies:
To arrive at a range of scenarios, health system leaders should model mild, moderate, and severe impacts on their key financial metrics (outlined in steps 1 and 2), and then amplify or moderate those impacts based on their specific organizational characteristics (step 3).
This scenario planning exercise should focus on the discrete policies with the greatest direct impact on financial performance drivers for health systems. This allows leaders to understand the different impacts of potential policy changes so they can plan for market- and organization-specific implications and begin to map out mitigatory steps or corrective actions.
Note that this approach accounts for the direct impact of health policy changes on health system finances. It does not account for the impact of larger economic changes, or the interaction of these forces with policy changes. For example, this approach captures the impact of work requirements on health system revenue based on historical precedent in loss of Medicaid insurance but does not anticipate a larger unemployment rate simultaneously increasing the population covered by Medicaid.
After constructing the range of scenarios, health system leaders should plan their response based on the impact of each policy change as well as when it will affect their organization. Some changes may take effect sooner than others, while some changes may compound or increase in impact. For example, in the House’s version of the budget bill, Medicaid cuts aren’t scheduled to arrive until 2026, whereas federal grants are already being cut by the executive branch. To help you get started, we’ve compiled a series of resources to strengthen organizational resiliency. You can think of these resources as no-regret moves for hospitals and health systems amidst policy uncertainty. They fall into five different categories:
To dive deeper into any of these, please reach out to your client services team.
The Advisory Board data and analytics team has constructed a scenario planning model to estimate the impact of different policy drivers on hospitals and health systems of different sizes. We use data from Syntellis Market Insights to model the impact of scenarios on median operating margin. We will continue to refine our assumptions as policy changes take shape.
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