2025 U.S. Healthcare Policy Changes: Federal and State

Navigating U.S. healthcare policy in 2025 can seem challenging, but you’re not alone. With a new Congress and Administration, we’ll keep you on top of potential changes and opportunities to watch in healthcare.

In Brief: Federal Healthcare Policies Amid Political Shifts

• The Trump administration’s approach to decentralization allows agency leaders to prioritize and pursue policies independently, while states and courts are taking a more active role in healthcare policy.

• Rising medical costs and external factors like inflation and supply chain issues are increasing pressures, but there is room for innovation and improved experiences.

• Transparency and AI offer significant opportunities to cut costs and demonstrate support for consumers.

Despite the unfamiliar road ahead, there is a solid foundation of federal healthcare policies and programs that remain strong, including price transparency, the No Surprises Act, and policies on data, AI, and cybersecurity/privacy.

What 2025 Means for Core U.S. Healthcare Programs 

Medicare Advantage (MA)

• CMS increased benchmark payments to MA insurers for 2026 by more than five percent.

• CMS Innovation Center’s (CMMI) MA payment models will focus on preventive services and value-based reimbursement.
• MA plans may face Congressional discussions and hearings about claims denials and use of prior authorization later in the legislative session. 
  

Legal and Legislative Impacts on the Affordable Care Act (ACA)

• ACA is not facing serious repeal efforts.However, Trump administration is cutting the budget for ACA navigators and shortening enrollment periods.

• Congress deciding whether to continue Biden-era ACA subsidies.

• ACA enrollment may drop significantly in 2026 if subsidies are not continued. 
  

Impact on Medicaid

• GOP Congress likely to make changes to Medicaid, shifting costs to states

• Expect changes to eligibility requirements and decrease in enrollment 
  

Transparency in Coverage 2025

• President’s executive order on healthcare price transparency 2025 spurred new guidance and a Request for Information (RFI)

• Healthcare policy advisors are influencing focus and priorities 
  

No Surprises Act in 2025

• Bipartisan support for No Surprises Act

• Further regulations unlikely, though agency/administration is working on IDR process improvement

• States addressing balance billing, particularly in ground ambulance space 
  

Legal and Legislative Impact on ACA Policies

• U.S. Supreme Court considering ACA requirement for plans to cover preventive care at no cost to patients

• Congress’ budget discussions may impact federal fiscal responsibility under ACA’s Medicaid Expansion 
  

Role of Artificial Intelligence in Healthcare Regulation

• Trump administration allowing commercial sector to lead on AI innovation through deregulation.

• States introducing AI legislation at a rapid pace   
  

Implications for Cybersecurity/Privacy in Healthcare

• Proposed rule to modify HIPAA security rule unlikely to be finalized soon

• Reorganization of HHS Office of Civil Rights, regulating entity for HIPAA Privacy and Security  
  

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