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January 22, 2026 – Earlier this week, we released a +Insight called “Healthcare in 2026: A preview” that lays out major legislative and regulatory healthcare actions that we expect to see in 2026. While Congress certainly has a lot on its plate, especially with January 30, 2026, continuing resolution deadline coming up and a new funding bill and healthcare package to consider, the administration will be equally busy on the regulatory side. As laid out in our +Insight, here are some of the key regulatory areas we are monitoring this year.
The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, introduces significant changes to the healthcare landscape, with provisions impacting Medicaid, Medicare, the Affordable Care Act (ACA), and other healthcare programs. Implementation of significant OBBBA provisions is set to take place in 2026 and 2027, so the Centers for Medicare & Medicaid Services (CMS) will likely release regulations throughout 2026, including:
Subregulatory guidance, such as informational bulletins and state Medicaid director letters, also is expected.
OBBBA also created the Rural Health Transformation Program (RHTP), a five-year $50 billion program that awards funds to states to invest in transformational rural health initiatives. Under the law, $10 billion will be available each fiscal year (FY) from 2026 to 2030. On December 29, 2025, CMS announced that all 50 states received first-year awards. Award amounts ranged from $147 million to $281 million. CMS also launched the Office of Rural Health Transformation (ORHT) to oversee the RHTP, assist states in implementing their plans, provide technical assistance, and coordinate federal and state partnerships. Expect to hear more this year from the ORHT and from states directly regarding the implementation of their plans, including at the CMS Rural Health Summit scheduled for March 2026.
During 2026, CMS will propose and finalize policies for 2027 for Medicare fee-for-service (FFS) providers and facilities and Medicare Advantage (MA) plans.
Regulations impacting Medicare FFS providers and facilities follow either FY or calendar year (CY) schedules.
| Regulatory calendar | Examples | Proposed | Finalized | Effective date |
|---|---|---|---|---|
| FY | Hospital inpatient, skilled nursing facility, and hospice payments | Around April 2026 | By August 1, 2026 | October 1, 2026 |
| CY | Physician and hospital outpatient payments | June or July 2026 | By November 1, 2026 | January 1, 2027 |
Some of these Medicare FFS payment regulations may expand upon policies and priorities that CMS included in the 2026 rulemaking cycle, such as:
For MA, the 2027 rate notice cycle will begin with CMS’s release of the 2027 MA and Part D advance rate notice, expected by early February 2026. Key issues in the notice will include the size of the proposed increase to benchmark payment rates, given concerns about rising utilization and costs for payers, and whether CMS proposes changes to the risk adjustment model or methodology. CMS will finalize payment rates and policies for 2027 in early April 2026. CMS also is expected to finalize its November 2025 proposed policy and technical changes to the MA and Part D programs in advance of the 2027 bid deadline of June 1, 2026.
In 2025, the CMS Innovation Center expanded its model portfolio, demonstrating an aggressive posture toward continued testing and incubation. The center released nine new models spanning multiple clinical domains, payment approaches, and participant types. We detailed many of these and other model developments in a recent Regs & Eggs blog post. 2026 will see the launch of many of these models, as well as additional model announcements.
The Trump administration began to articulate its artificial intelligence (AI) strategy at the end of 2025. On December 11, 2025, the White House issued an executive order (EO) attempting to restrict state-level AI laws. The administration’s stated goal is to maintain “global AI dominance” through a “minimally burdensome” framework. The EO sets out several measures and efforts in furtherance of the administration’s desire to avoid a patchwork of state laws and regulations, to reduce barriers to innovation, and to ensure consistent oversight of interstate commerce.
Several agencies are currently seeking stakeholder feedback on specific issues related to AI use in healthcare. For example, CMS has asked for comments on how to appropriately and adequately address Medicare reimbursement for the use of AI in healthcare through the annual Physician Fee Schedule (PFS). The US Department of Health and Human Services (HHS) Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP) issued a request for information (RFI) in December 2025 asking for feedback on accelerating the use of AI in clinical care. Several models recently announced by the CMS Innovation Center also heavily emphasize the use of AI. In 2026, we should start to see how the administration will tackle these issues and whether stakeholder feedback will impact the direction of any new regulatory efforts.
On the technology front, ASTP is in the process of refining standards for what counts as “certified electronic health record technology” and heightening enforcement of information blocking requitements. At the end of 2025, ASTP issued a proposed rule, the Health Data, Technology, and Interoperability: ASTP/ONC Deregulatory Actions to Unleash Prosperity (HTI-5), which could be finalized this year. ASTP also published a separate notice withdrawing yet-to-be finalized proposals from the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule. Together, the proposed changes would reduce the circumstances under which actors may deny requests for access, exchange, or use of electronic health information (EHI), suggesting this administration will push to provide broader access to EHI.
The Trump administration took many actions in 2025 on prescription drug pricing. One such action included negotiating price agreements directly with drug manufacturers. We expect to learn more about these agreements in 2026. President Trump also announced a new TrumpRx website intended to connect patients with direct-to-consumer purchasing programs offered by drug manufacturers. TrumpRx is expected to launch in January 2026. To date, nine drug manufacturers have agreed to offer some of their drugs at a reduced price when patients buy them directly from the manufacturer through TrumpRx. Negotiations with additional drug manufacturers are ongoing. These agreements are separate from agreements made with the same drug manufacturers to offer most-favored nation pricing to state Medicaid programs.
In 2026, the administration’s drug pricing strategy will move from policy to execution. In particular, the administration, through the CMS Innovation Center, will test a coordinated set of drug pricing models:
President Trump also included drug pricing as one of his major policy priorities in his January 15, 2026, Great Healthcare Plan announcement. As part of the plan, he called on Congress to codify the most-favored-nation deals.
Every year, CMS establishes policies for the Affordable Care Act (ACA) marketplace, and the agency will soon release the ACA proposed Notice of Benefit and Payment Parameters for 2027. This rule could focus on the Trump administration’s ongoing effort to crack down on perceived fraud and abuse within the marketplace, and explore ways to drive down health insurance premiums and out-of-pocket costs. It will be interesting to see if the rule references the Great Healthcare Plan, since the plan aims to drive down premiums by promoting policies that would send “money directly to eligible Americans to allow them to buy the health insurance of their choice.”
The administration also may finalize the Transparency in Coverage rule that was proposed in December 2025. The rule would impose on health plans new requirements that aim to improve the standardization, accuracy, and accessibility of information by addressing three main barriers to full price transparency:
Price transparency in general will remain a top priority, as the Great Healthcare Plan would also require certain health plans to publish:
Congress may need to adopt these additional requirements, which cannot be included in the final Transparency in Coverage rule since they were not explicitly proposed.
HHS Secretary Robert F. Kennedy, Jr., will likely continue to pursue MAHA policies to address chronic disease through lifestyle medicine and structural changes. In 2025, an EO created the MAHA Commission and directed the release of its first report, which focused on identifying key drivers of children’s declining mental and physical health, including poor diet, chemical exposure, lack of physical activity, chronic stress, and overmedicalization. The commission released its MAHA strategy later in the year. Several HHS policy initiatives throughout 2025 included MAHA priorities, and HHS likely will continue to find ways to implement the concept further in 2026.
CMS included several RFIs in formal rulemaking, signaling future action. In the CY 2026 Medicare PFS proposed rule, CMS sought feedback on expanded treatment options and flexibility for insurance coverage, as well as on benefits around lifestyle changes and disease prevention. Although CMS did not finalize specific policies related to the RFI, the topic will likely come up again in CY 2027 rulemaking. CMS also included an RFI on well-being and nutrition in the CY 2027 MA and Part D proposed rule. Comments are due on January 26, 2026. The CMS Innovation Center included MAHA initiatives in various models that will be implemented throughout 2026.
This month, HHS and the US Department of Agriculture (USDA) released revised dietary guidelines. The accompanying scientific review emphasized the need for a uniform definition of highly processed foods. A joint USDA and US Food and Drug Administration effort is underway to establish this definition and may see progress in 2026.
These are just some of the areas we are monitoring for 2026, and our +Insight goes into a lot more detail! Please give it a read, and feel free to reach out if you have any questions or want to discuss any issues further.
Until next week, this is Jeffrey saying, enjoy reading regs with your eggs.
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