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Blog

CMS Provider Tax Guidance Places New Pressures on Medicaid Budgets

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The Centers for Medicare & Medicaid Services (CMS) issued a letter on November 14, 2025, which provides preliminary guidance on healthcare-related taxes affected by Sections 71115 and 71117 of the Budget Reconciliation Act of 2025 (OBBBA, P.L. 119-21)—the portion of the legislation that focuses on new limitations on provider assessments.

Although this letter does not change federal regulations, it signals an important policy shift that will affect how states fund their Medicaid programs. CMS is working to incorporate these interpretations into rulemaking through the federal notice and comment process.

Health Management Associates (HMA) reviewed the letter specific to these provisions and in the context of other policy and financing changes that are affecting the Medicaid program. This article highlights key clarifications in the letter, the impact of the preliminary guidance on states, and the potential for the guidance to shape Medicaid budgets, financing strategies, and future policy reforms.

Guidance Clarifies the Meaning of “Enacted” and “Imposes”

OBBBA prohibits states from establishing new provider taxes after July 4, 2025. Existing provider taxes may be grandfathered if they meet specific criteria, but most taxes in expansion states—except those on nursing and intermediate care facilities—will be phased down starting October 1, 2027. To qualify for grandfathering, a tax must be both “enacted” and “imposed” by July 4, 2025, as defined by CMS.

CMS interprets enacted and imposed in the following way.

  • Enacted: CMS defines enacted based on two components. First, the state or local government must have completed the legislative process to authorize the tax by July 4, 2025. Second, any necessary tax waiver of the broad-based and uniformity requirements must be approved no later than July 4, 2025. This interpretation will present challenges for some states as any pending tax waiver requests and approvals issued after July 4, 2025, will not qualify for grandfathering.
  • Imposed: In addition to the enacted requirements, a state must have been actively collecting revenue for the new tax as of July 4, 2025. CMS does appear to allow for instances in which a state’s routine collection and billing practices require the tax be paid on a delayed schedule—a common practice across states.

CMS may continue to approve pending state proposals for new and revised tax structures; however, with the approvals, CMS is also notifying states that any tax structure that is ineligible for grandfathering must be revised by October 1, 2026, to comply with Section 71115 of the OBBBA.

Guidance Sets Preliminary Timeline for Compliance with New Broad-based and Uniformity Requirements in Section 71117

The OBBBA and a separately proposed rule published in May 2025 provide CMS with additional flexibility to tighten requirements for waivers that allow states to impose provider taxes that are not broad-based and uniform (i.e., the tax is levied on providers in a class at a common rate). CMS believes states have used a strategy to pass the prescribed statistical test for these waivers while shifting a disproportionate share of tax burden to high Medicaid providers.

The November 14 letter also includes a preliminary timeline for states to restructure their taxes to comply with the new requirements related to waivers of the broad-based and uniformity tests.

  • MCO taxes: States that levy a higher tax rate on Medicaid managed care organizations (MCOs) than on other MCOs must submit a revised tax structure applicable to the state fiscal year (SFY) starting in calendar year (CY) 2026.
  • Taxes on all other provider types: States with a similar tax structure on another provider class would need comply by the conclusion of the SFY, ending in CY 2028.

CMS notes that the preliminary timeline for the MCO taxes is the minimum transition period, and the final rule may allow for a transition period of up to three fiscal years.

What It Means for States

All states except Alaska rely on one or more provider tax(es) to fund their Medicaid programs. These additional limitations on the uses of provider taxes—including those now in place—will put a significant strain on state budgets, beginning as early as October 1, 2026. States may need to reduce provider reimbursement and/or enrollee benefits to address these losses.

States and providers should start planning for the changes in revenue now. Strategic planning for provider tax sustainability and close monitoring of upcoming CMS rulemaking are essential.

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The potential impact will vary by state, and each tax structure should be individually assessed to fully understand the implications of this new guidance. HMA has designed, developed, and helped implement provider taxes across the country and is uniquely positioned to support states, MCOs, and providers as they navigate the evolving landscape.

For details about the federal guidance and considerations for your organization, contact our experts below.

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We deliver timely, expert-driven updates to help you stay informed and ahead of the curve.

Webinar

Webinar Replay – Redefining Revenue: Building Financial Resilience in an Era of Policy and Payment Change

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This webinar was held on December 11, 2025.

As healthcare organizations face sweeping shifts in Medicaid funding, workforce costs, and payer expectations, leaders must think beyond short-term cuts and find sustainable ways to protect access, quality, and mission.

During this webinar, HMA experts Jose Robles, Juan Montanez, and Kristina Ramos-Callan discussed how hospitals, health systems, and providers can reimagine revenue strategy for the next decade.

Learning Objectives:

  • Understand the financial and operational implications of OBBBA and related regulatory changes on healthcare delivery.
  • Identify strategies to stabilize payer mix, manage revenue volatility, and mitigate the effects of coverage loss.
  • Explore technology and operational levers that enhance financial performance, including data analytics, automation, and care delivery redesign.
  • Examine how innovation and mission-driven decision-making can strengthen organizational resilience and maintain equity in care.
  • Apply insights to develop forward-looking plans that align fiscal responsibility with community health priorities.
Blog

25th annual KFF state Medicaid budget survey released

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The 25th annual Medicaid Budget Survey conducted by KFF and Health Management Associates (HMA), in collaboration with the National Association of Medicaid Directors (NAMD), was released on November 13, 2025in the report A View of Medicaid Today and a Look Ahead: Balancing Access, Budgets and Upcoming Changes: Results from an Annual Medicaid Budget Survey for State Fiscal Years 2025 and 2026

Following years of significant changes in Medicaid spending, enrollment, and policy during the COVID-19 public health emergency and the subsequent Medicaid unwinding period, state Medicaid programs returned to more routine operations in state fiscal year (SFY) 2025 and were focused on an array of other priorities, including improving access to care or addressing social determinants of health.  

Heading into SFY 2026, however, states were facing a more tenuous fiscal climate and beginning to prepare for another major set of policy changes to the Medicaid program. The 2025 federal budget reconciliation law (OBBBA) includes substantial Medicaid policy changes and reductions in federal funding, though the impacts vary by state. While many of the provisions do not take effect until FY 2027 or later, states are anticipating the upcoming changes, assessing budgetary and programmatic impacts, and preparing for the implementation of multiple and complex policy changes.  

In addition to navigating state budget challenges and implementing new federal policies, the report also addresses other Medicaid program priorities including expanding access, implementing initiatives that target specific populations (e.g., pregnant individuals, justice-involved), continuing delivery system efforts, and improving administrative systems and functions. 

Serving over one in five people living in the United States and accounting for nearly one-fifth of health care spending (and over half of long-term care spending), Medicaid represents a large share of state budgets and is a key part of the overall health care system. 

The report was prepared by Kathleen Gifford, Aimee Lashbrook, and Carrie Rosenzweig from HMA; and by Elizabeth Hinton, Elizabeth Williams, Jada Raphael, Anna Mudumala, Robin Rudowitz from KFF. The survey was conducted in collaboration with NAMD. 

Read the report

Other links: 
2025 Press Release  
Medicaid Enrollment & Spending Growth: FY 2025 & 2026 

Blog

Evaluation of the CareSource JobConnect program quantifies ROI for States

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HMA recently released a report analyzing the impacts of the CareSource JobConnect Program, which provides employment assistance to non-elderly adults enrolled in Medicaid. CareSource is a national, nonprofit managed care organization dedicated to transforming healthcare for those served by government-sponsored health care programs. The program helps individuals prepare for a job search, obtain employment, and succeed in the workplace. HMA was engaged due to our significant expertise in Medicaid to evaluate the program’s impacts in 3 of the 6 states where it is currently active: Indiana, Georgia, and Ohio. HMA conducted an economic impact analysis to assess outcomes for members participating, a cost–benefit analysis, and a return-on-investment (ROI) assessment, examining the direct and indirect financial benefits to participants, the broader economic impact on the state and healthcare spending, and the total program operation costs incurred by CareSource.

The recently enacted OBBBA law established new federal standards that require states to verify that certain Medicaid enrollees are meeting minimum work or community engagement hours as a condition of continued coverage. Past efforts by states to establish work requirements as a condition of enrollment in Medicaid have resulted in coverage losses because of bureaucratic hurdles that made it difficult for people to comply. A program like CareSource JobConnect can provide support and assistance to those enrolled.

The analysis aimed to help CareSource understand the advantages of this program on those participating, as well as the broader impact on the state’s economy, and demonstrates potential gains for the state, the job seekers, and CareSource’s program if more people took advantage of the program’s benefits.

The report shows significant economic and workforce outcomes, particularly in Ohio and Indiana.

  • Ohio led with the highest number of participants and employed workers, generating a return-on-investment of 13:1.
  • Indiana showed impressive efficiency, with a strong return-on-investment of 12:1.
  • Georgia’s results were still positive with a 5:1 ROI, but there are opportunities for improvement in employment success and economic return that could improve the success for the Georgia program.

HMA examined direct benefits to those newly employed through the program, including annual earnings and earnings supplements such as tax credits; indirect benefits, such as key elements of social determinants of health like food security and safe and affordable housing; new spending: new worker spending due to employment enhanced by the multiplier (defined as the ripple effect that occurs as new jobholders spend a large portion of their earnings, which creates income for local businesses and nonprofit organizations); the Benefit-to-Cost Ratio: The sum of direct and indirect benefits and the multiplier effect, divided by the cost incurred by the organization making the investment. These things together help determine the full ROI for the program.

As more participants receive job placements over time and their incomes increase, earning supplements will decrease, and other indirect benefits will decrease as participants earn more than the maximum amounts for eligibility.  Each of the three states saw a net gain to their state budgets in the form of state sales and income taxes as members earn more and are able to spend their wages on goods and services.  

 IndianaGeorgiaOhio
2024 Participants with Employment through the Program8728198
2024 Participants in the Program220188566
Aggregate New Worker Spending$1,688,001$537,923$3,110,462
Multiplier Effect555
Aggregate Benefit to Participants and the Local Economy (new worker spending times multiplier)$8,440,004$2,689,615$15,552,308
Estimated Cost Per Participant$2,938$2,230$1,988
Benefit—Cost Ratio13:16:114:1
Return-on-Investment12:15:113:1

To learn more about the program and to download the whitepaper, click here.

HMA has more than 40 years of experience in helping to shape and improve Medicaid programs, and supports organizations nationwide to develop, implement, and evaluate programs for state agencies, local governments, health plans, and other community-based partner organizations.  Learn more about how HMA supports Medicaid and our efforts in Housing and Health.

Related resources:

Blog

States Submit Applications for Rural Health Transformation Program: Trends and Opportunities

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On November 5, 2025, the Centers for Medicare & Medicaid Services (CMS) announced that all 50 states had submitted applications to be considered for participation in the Rural Health Transformation Program (RHTP) created under the Budget Reconciliation Act of 2025. States proposed a range of initiatives to strengthen innovation, modernize rural health infrastructure, and address persistent disparities in healthcare access, workforce, and outcomes in rural communities. Funding decisions are expected by December 31, 2025.

The RHTP represents a major federal investment in rural health transformation. For providers, community partners, and other interest holders, applications offer valuable insight into state priorities, partnership models, and the types of initiatives likely to receive funding.

Many state feedback processes are ongoing for providers, community organizations, and other partners. Even after submission, states are refining their proposals and negotiating with CMS. Organizations should review available materials and take advantage of open comment periods or stakeholder meetings to help states prepare for a strong program launch in early 2025.

Health Management Associates (HMA) reviewed state overviews and applications, where available. In this article we highlight key takeaways from this review and the information available through HMA’s Information Services (HMAIS).

Key Issues and Trends

  • Breadth of initiatives and focus areas. State initiatives meet the specific categorical CMS requirements and include a range of innovative models, ideas, and investments in building out pilots and infrastructure. The number of initiatives that states have planned also vary, with most proposing four or five, but at least one state has developed 11 planned programs. Many initiatives involved remote patient monitoring and telehealth, including tele-specialty clinics, tele-psychiatry hubs, tele-intensive care unit support, among others. Several states proposed to establish and enhance models involving emergency medical services (EMS). Proposals also include a range of investments in electronic health records (EHRs), data infrastructure, and interoperability to specific provider types and generally in rural communities.
  • Subgrant and Partnership Opportunities: Many applications include subgrant programs or call for partnerships with hospitals, clinics, community-based organizations, Tribal entities, and educational institutions. Reviewing state applications can help organizations understand the timelines for upcoming funding and partnership opportunities as well as expectations associated with the state initiatives.
  • Diverse governance and implementation models: The tracker reveals a range of governance structures, from state-led advisory boards and interagency task forces to regional hubs and cross-sector partnerships. States are leveraging advisory councils, technical assistance partners, and community engagement frameworks to guide implementation and oversight.

Some states have yet to submit their full applications but still have opportunities to engage and shape state efforts through various methods. Many states have kept open public feedback mechanisms even as they negotiate with CMS on budgets and program details. This situation creates an evolving landscape wherein stakeholders must monitor multiple channels for updates and opportunities.

Why This Matters

HMAIS’ RHTP Inventory provides states, rural communities, and their partners an actionable road map for state initiatives. This inventory covers focus areas for state initiatives, governance models, funding requests, partnership opportunities, and other key information. This tool helps organizations monitor trends and identify where to engage. HMA will continue to follow state activity in this program as states move forward.

Beyond the tracker, HMA offers deep regional market expertise—our consultants understand state-specific priorities and can provide tailored analysis and strategic planning to position your organization for success. Whether you’re exploring telehealth investments, building partnerships, or preparing for new initiatives in rural health transformation, our team can help you navigate the details and seize opportunities.

For questions about the HMAIS RHTP Inventory and to connect with our state-market leads, contact our experts below.

Blog

Where Duals Integration Is Headed: State-by-State Intelligence

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Dually eligible individuals are those who qualify for both Medicare and Medicaid. This population accounts for a disproportionately small share of the total Medicaid or Medicare population, but they account for a disproportionately large share of spending across both programs.

Medicare Advantage Dual Eligible Special Needs Plans Play a Key Role

Over the last several decades, federal and state policymakers have developed and implemented a range of programs, demonstrations, and approaches to improve care for this population and strengthen alignment between Medicare and Medicaid, improve outcomes, and manage costs. Medicare Advantage (MA) Dual Eligible Special Needs Plans (D-SNPs) are a key vehicle to accomplish federal and state goals.

What to Expect in Medicare Advantage Contract Year 2026

In 2026 and beyond, we can expect significant state and local shifts in plan enrollment, due to new federal requirements and state demonstration program transitions. We will see states focused on advancing aligned plan enrollment and setting higher expectations for Medicare-Medicaid integrated programs.

A New Inventory to Stay on Top of State Markets

Health Management Associates (HMA) has published the Duals Integration Environmental Inventory, a state-by-state view of state Medicaid program structures and regulations shaping integration and D-SNP markets. This resource is designed to help state policymakers, insurers, and healthcare organizations track trends, identify opportunities, and inform strategic planning in an evolving policy landscape.

Looking Ahead at the Changes in 2026 and Beyond

Federal rules for the Medicare Advantage 2026 contract year—and state Medicaid contractual agreements with plans—strengthen D-SNP integration standards and coordination between states and plans. Examples include:

  • D-SNP Look-Alike Plans: In 2026, the threshold for identifying MA plans as D-SNP look-alikes will decrease from 70 percent to 60 percent. This 10-percentage point drop marks the second of two planned phasedowns in the threshold percentage. Look-alike plans are MA plans that are marketed to dually eligible individuals, but they are not required to comply with D-SNP integration requirements. Stronger federal standards will require MA look-alike plans with high dual enrollment to convert or exit the market, which is expected to lead to shifts in dually eligible enrollment into D-SNPs and other integrated products.
  • Financial Alignment Initiative Demonstration Transitions: The Centers for Medicare & Medicaid Services (CMS) has worked with several states operating capitated Financial Alignment Initiative (FAI) demonstrations to transition Medicare-Medicaid Plans (MMPs) to integrated D-SNPs by January 1, 2026. These states include Illinois, Massachusetts, Michigan, Ohio, Rhode Island, South Carolina, and Texas will end their FAI demonstrations on December 31, 2025.
  • 2027 D-SNP Rules: Beginning in 2027, D-SNPs affiliated with Medicaid managed care organizations (MCOs) must restrict enrollment to Medicaid MCO enrollees. In addition, federal rules will limit the number of D-SNP plan benefit packages, which will require additional coordination with Medicaid affiliates and planning in designing benefit packages and network.

State Medicaid Program Adjustments

States are working to align new federal D-SNP requirements with existing Medicaid managed care contracts, long-term services and supports carve-in strategies, and service-area mappings. Because State Medicaid Agency Contracts (SMACs) must be updated annually, all SMACs will need to incorporate the new D-SNP provisions as the new requirements take effect. This effort will require close coordination among state agencies, plans, and CMS to manage enrollee transitions, data-sharing, and communications.

Data-Informed Integration Insights

HMA’s Duals Integration Environmental Inventory is a single hub for insights into requirements, approaches to scope of integration programs, and enrollment data. The inventory will help plans and other types of organizations such as providers and community-based organizations to prepare for future contracting, compliance, and operational transitions.

This inventory is designed to answer the four major questions top of mind:

  • What is the state’s integration model and D-SNP type. The inventory identifies each state’s approach to integrating care for dually eligible populations, including states with Fully Integrated Dual Eligible Special Needs Plans (FIDE-SNPs), Highly Integrated D-SNPs (HIDE-SNPs), coordination-only models, and Exclusively Aligned Enrollment (EAE) initiatives or comparable rules
  • Does the state’s program integrate LTSS and/or Behavioral Health? The inventory details whether long-term services and supports and behavioral health are carved into or out of managed care and how those benefits interact with Medicare coverage within D-SNP structures
  • What is the state’s enrollment policy? The inventory captures enrollment in HIDE/FIDE products, identifies Applicable Integrated Plan (AIP) states, and gauges overall alignment maturity
  • What is the state’s procurement and contract timeline? The inventory also tracks state procurement timelines, upcoming RFPs, and effective contract dates

Connect with Us

HMA experts are tracking state integration strategies, procurement timelines, and future state planning activities. Beyond the tracker, HMA colleagues provide tailored analysis and planning for state-specific initiatives. Our team can help health plans prepare for enrollment shifts, compliance requirements, and integration opportunities in 2026 and beyond. For information about subscription access to the HMA Information Services (HMAIS) inventory and to connect with HMA consultants who can address your integration questions, contact our experts below.

Brief & Report

The Impact of the CareSource JobConnect Program: A Benefit–Cost and Return-on-Investment (ROI) Analysis

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A new report prepared by HMA, The Impact of the CareSource JobConnect Program, evaluates the outcomes of 3 of the 6 states where it is currently active: Indiana, Georgia, and Ohio. It provides employment assistance to non-elderly adults enrolled in Medicaid, helping individuals prepare for a job search, obtain employment, and succeed in the workplace.

HMA conducted an economic impact analysis to assess outcomes for members participating in the CareSource JobConnect program who expressed interest in employment assistance. This Return-on-Investment (ROI) analysis shows the impact the CareSource JobConnect Program has on its participants as well as the broader impact on the state’s economy and local communities.

In 2024, the CareSource JobConnect program delivered strong economic and workforce outcomes, particularly in Ohio and Indiana. Ohio led with the highest number of participants and employed workers, generating a return-on-investment of 13:1. Indiana showed impressive efficiency, with a strong return-on-investment of 12:1. Georgia’s results were positive but highlighted opportunities for improvement in employment success and economic return.

Additional contributions to the report from Jack Meyer.

Please fill out this form to receive a copy of the report.

Blog

States need to move quickly on Rural Health Transformation Program

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As of November 5th, states have submitted their applications for the Rural Health Transformation Program (RHTP) – a major federal initiative aimed at addressing persistent healthcare challenges in rural communities. Authorized by the 2025 budget reconciliation bill (OBBBA), the RHTP will distribute $50 billion over the next five years to help rural communities improve healthcare access, quality, and outcomes. All 50 states are eligible. 

This submission marks a key milestone, but it’s just the beginning. The Centers for Medicare & Medicaid Services (CMS) is reviewing applications, and ongoing conversations between states and CMS will shape the final design and implementation of each state’s program. Awards are expected by December 31, 2025, and states – and their partners – must be ready to move quickly early in 2026. 

States must now prepare for a fast-moving design and implementation phase, building on initiatives already underway and refining plans and budgets based on CMS feedback. States will need to staff up quickly and launch new projects in early 2026. With tight fiscal timelines and the risk of forfeiting funds, agencies and community organizations must act decisively. It will be crucial to demonstrate impact on health outcomes within the first half of 2026 will be critical.

Organizations across the healthcare industry should closely monitor how states plan to operationalize their proposals, as these strategies will shape funding flows and partnership opportunities. 

Many state agency leaders will be attending the National Association of Medicaid Directors (NAMD) annual conference November 18-21, 2025. The RHTP applications will be a big topic of conversation, with states sharing ideas and stakeholders discussing challenges and opportunities that could be addressed with RHTP funding. HMA will have a strong presence at NAMD and will be gathering important insights on the federal expectations, program content, and operational strategies that states put in their applications.  

Organizations interested in learning more about their state’s direction – or in becoming part of the implementation conversation – can reach out to HMA experts listed below.

What’s next with the RHTP?

Any state that is approved for RHTP funding requires:

  • A strong management structure at the state level, including dashboards and oversight of programs funded through this award
  • Defined goals and sustainable initiatives in chronic disease management, primary care, behavioral health, maternal health, digital innovation, workforce initiatives, and other topics
  • Demonstrated outcomes that evidence improvements in rural access and health outcomes, as well as the care experience of rural residents

HMA is ready to help. Our team brings deep expertise in tackling the complex challenges of delivering quality healthcare and human services to rural communities. We understand the challenges rural providers face—from workforce shortages and service gaps to transportation hurdles and socio-economic barriers—and can help states and organizations navigate complexities of implementation.  

With broad experience, HMA is a national leader in healthcare consulting, with a multidisciplinary team of over 700 experts experienced in policy, finance, clinical services, analytics, and community engagement. We help rural organizations act decisively and efficiently, meeting the strict deadlines set by the RHTP and minimizing risks such as funding claw-backs. From actuarial and financial skills to clinical and operational expertise, policy, and analytics, HMA can support successful implementation of your State’s Rural Health Transformation program.

Related resources:

Blog

Cross-Sector Collaboration: Unlocking the Full Potential of Community-Based Services in a Challenging Funding Climate

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Lessons Learned from State-Led Transformation Efforts

As federal and state healthcare policy continues to evolve, the need for cross-sector collaboration has never been more urgent. The 2025 budget reconciliation act (OBBBA, P.L. 119-21) introduces significant changes to Medicaid eligibility and financing, prompting a shift in strategy for policymakers and advocates working to advance whole-person care and address social determinants of health (SDOH). The new policies reflect a reorientation of Medicaid financing, with a greater emphasis on state flexibility, targeted benefits, and value-based care.

In this environment, enhanced partnerships and strategic alignment across sectors will be essential to sustain community-based services and workforce investments. In this article, Health Management Associates (HMA), experts highlight key observations from multiple state transformation programs, including actionable strategies for leveraging these assets and meeting the needs of at-risk populations.

Revisiting SDOH Initiatives in a New Policy Context

Whole-person care models have long called for integrated, multidisciplinary approaches. These models—once buoyed by COVID-19 pandemic-era funding and broad federal support—must now be recalibrated to align with new federal priorities. Current federal priorities emphasize streamlined benefits, fiscal discipline, and state-led innovation, which presents both challenges and opportunities for advancing integrated care. This shift has heightened the need to clarify roles and responsibilities across clinical and community settings, focusing on how to maintain essential linkages to primary and preventive care, especially for individuals for whom access remains fragile.

In addition, the ongoing healthcare workforce crisis intensifies the need for creative approaches to whole-person care models. Solutions must go beyond traditional payment models, leveraging existing social care networks, shared hub functions, alternative payment strategies above base rates, and braided funding streams.

State and federal initiatives can be used to sustain momentum and test emerging models. For example, the Rural Health Transformation Program (RHTP) offers a critical opportunity to support these efforts. With $50 billion in funding over five years, RHTP is designed to help states implement innovative models that improve rural health outcomes, strengthen workforce capacity, and address SDOH. States will be finalizing their applications to meet the November 5 deadline. HMA is tracking how these applications align with the strategies outlined below, using the program’s baseline and performance-based funding to invest in infrastructure, workforce development, and cross-sector partnerships.

Key Lessons from State Transformation Programs

Drawing on recent transformation programs, HMA experts identified several key lessons, including:

  • Prioritize Intensive, Community-Based Outreach: States and health plans should invest in community-based outreach strategies that reach populations facing the greatest SDOH barriers, including funding models that support navigation and engagement beyond traditional clinical settings and leveraging shared infrastructure to extend reach.
  • Update Community Health Worker (CHW) Benefit Structure to Maximize Impact: States, in collaboration with their partners, should revisit CHW benefit design to allow for greater flexibility. Reducing reliance on clinical supervision and referral-only pathways can help CHWs operate more effectively in terms of outreach, education, and engagement.
  • Strengthen Workforce Retention through Flexible Financing: Healthcare stakeholders should explore braided funding, shared hub models, and alternative payment models that go beyond base rates. These approaches can sustain staff and morale amid shifting demands and constrained budgets.

Connect with Us

The strategies in HMA’s recent report for IllinoisMedicaid Financing for Social Health: A Resource Compendium for Illinois Community-Based Organizations & Networks, can be adapted to other states and communities. By sharing lessons and adopting best practices from transformation programs nationwide, we can reinforce pathways to integrated care and ensure that populations continue to receive the support they need—even in the face of unprecedented challenges.

HMA experts are helping states, healthcare plans, and community partners adapt and thrive as federal and state policy landscapes continue evolving. HMA teams are applying their cross-sector expertise in SDOH, workforce development, and state-specific knowledge to help organizations better plan, implement, and develop programs to solve healthcare challenges in their community. For questions about the report or opportunities for your organization, reach out to our experts below.

Solutions

HMA’s Experts Support States in Rural Health Initiatives

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HMA Solutions

HMA’s Experts Support States in Rural Health Initiatives

RHTP Requirements and Opportunities: Now What?

As of November 5th, each state should have applied for the Rural Health Transformation Program (RHTP) designed to support communities across the United States who face unique and persistent healthcare challenges. Residents in rural areas often have limited access to care, a shortage of service providers—primary care, behavioral health, emergency services, and clinical specialists—and significant barriers in transportation, connectivity and care coordination among providers.

The Centers for Medicare & Medicaid Services (CMS) will announce funding by the end of the year, with states receiving notice of their allocations and potentially feedback on their application content. States are now tasked with developing comprehensive plans to enhance rural healthcare infrastructure, improve access, integrate care, and demonstrate measurable outcomes within tight timelines. The RHTP requires:  

A strong management structure at the state level, including dashboards and oversight of programs funded through this award

Defined goals and sustainable initiatives in chronic disease management, primary care, behavioral health, maternal health, digital innovation, workforce initiatives, and other topics

Demonstrated outcomes that evidence improvements in rural access and health outcomes, as well as the care experience of rural residents

The short turnaround and wide range of components and requirements in the RHTP application process will mean there is a lot of detail left to be decided. States should be prepared to engage in a planning process that capitalizes on near-term opportunities and lays the groundwork for implementing sustainable transformation initiatives. HMA is ready to provide support with practical, field tested solutions for immediate effect and support the development of last reforms. 

HMA’s Rural Track Record

HMA is a national leader in healthcare consulting, with a multidisciplinary team of over 700 experts experienced in policy, finance, clinical services, analytics, and community engagement. HMA has supported a diverse array of clients serving rural and frontier communities, including state and local governments, health systems, federally qualified health centers, tribal organizations, providers of every specialty, and community-based groups.

Examples of some of HMA’s past work in rural health include:  

Primary Care improvement: HMA partnered with New Mexico Human Services Department to reform primary care payment models, addressing sustainability and fiscal soundness for rural providers. This work involved designing, testing, and evaluating new models, engaging stakeholders, and supporting implementation through provider training and analysis.

Tribal Behavioral Health Systems: In Montana, HMA assessed gaps and provided the state recommendations to improve behavioral health systems for tribal communities, focusing on culturally competent, integrated care models.

Strengthening the financial health of rural providers: In Colorado and Georgia, HMA supported the development of value-based payment strategies for rural providers by analyzing fiscal operations and performance and creating operational pathways to enhance sustainability and care quality.

Supporting rural residents through community interventions: HMA developed a toolkit for tackling access challenges for dually eligible individuals in rural areas, offering actionable solutions for policymakers and providers to improve care and outcomes. 

Workforce Development: HMA has led numerous initiatives to address workforce shortages in rural settings, providing solutions for recruitment, retention, and care coordination, particularly in behavioral health. As a founding member of the Workforce Solutions Partnership, we have captured near- and longer-term solutions to behavioral health workforce shortages. 

How HMA Can Assist States in Executing RHTP

HMA offers a comprehensive suite of services to help states and their partners successfully implement RHTP initiatives, all under one roof. From actuarial and financial skills to clinical and operational expertise, policy, and analytics, HMA can support successful implementation of your State’s Rural Health Transformation program.

Here are some of the ways we can support your efforts:  

Program integrity and effectiveness

Design robust oversight tools to monitor state programs, ensuring transparency in funding flows, program goals, and outcomes.

Provide data-driven insights, program monitoring, and evaluation to demonstrate impact and guide continuous improvement.

Conduct financial assessments and provide recommendations to improve the solvency of rural healthcare systems.

Initiative design and implementation

Support and coach providers and health systems in operational change, clinical organization, e-health adoption, and integrated care models tailored for rural settings.

Leverage proven strategies to address workforce shortages, integrate behavioral health with primary care, and implement scalable solutions.

Design and help execute chronic disease management programs tailored to rural populations and systems.

Help implement the maternal “hub-and-spoke” model and other efforts to improve birth outcomes and access to care

Offer field-tested tools for community engagement and assessment like the HEARD Toolkit for rural residents and other resources to address disparities, improve access, and ensure the needs of vulnerable rural populations are met.

Design, test, and scale innovative models and pilots that align with state and community RHTP goals.

Sustainability

Develop and facilitate effective partnerships and information exchange among government entities, providers, payers, and community organizations to align efforts and maximize the impact of RHTP investments.

Provide a range of financial, revenue, and operational tools for states and rural providers. These tools can help make grant-funded activities sustainable, lasting change.

Conduct a range of workforce development initiatives to enhance access and optimize virtual and in-person care experiences.

A unique HMA differentiator is our team of clinicians – primary care and specialty care physicians, nurse practitioners and physician assistants, registered nurses, behavioral health providers among others – who bring years of direct care delivery experience and the ability to engage other clinicians to effect change and innovation across the delivery system. All of our clinicians have worked in rural and economically disadvantaged communities, and most have worked on rural health initiatives in Alaska, Idaho, South Dakota and other states. This team has been instrumental in developing solutions that encompass a deep understanding of the interplay between medical, behavioral health and social determinants of health as they all contribute to the individuals’ and communities’ wellbeing. Moreover, this team has helped design innovative solutions that incorporate telehealth, remote monitoring, patient apps, and other technologies that engage patients in their care, facilitate care team collaboration, and ultimately close care gaps and reduce instances of avoidable, costly care.

With extensive hands-on experience and a deep understanding of the rural health landscape, HMA is uniquely positioned to help states navigate the complexities of the RHTP, drive sustainable change, and improve health outcomes for rural communities nationwide.

Contact our experts:

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R.J. Briscione

Principal

R.J. is an expert in operations and patient/member engagement across government-sponsored plans, with a focus on Social Determinants of Health … Read more
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John Eller

Regional Director

John Eller is a seasoned executive with more than 23 years of service in public administration and health and human … Read more
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Farah Hanley

Regional Director

Farah Hanley is a healthcare executive with more than 30 years of experience with state Medicaid programs, policies, and budget … Read more
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Alicia M. Johnson

Regional Director

Alicia M. Johnson is a visionary leader with nearly three decades of experience driving transformative change in the public and … Read more
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Beth Kidder

Regional Director

Beth Kidder is a transformative and innovative health care leader with more than 20 years of experience working within the … Read more
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Andrea Maresca

Managing Director, Information Services

With nearly two decades of experience in healthcare, Andrea Maresca is a skilled legislative and regulatory analyst and strategy developer. … Read more
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Juan Montanez

Managing Director

Effectively applying information technology (IT) solutions and optimizing information management processes, Juan Montanez has driven operational and service delivery improvements … Read more
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Tonya Moore

Associate Principal

Tonya Moore is a lawyer and public healthcare professional with more than 28 years of government experience at the Centers … Read more
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Kathleen Nolan

Senior Advisor

Kathleen Nolan has been actively engaged in the national dialogue during one of the most transformative periods in the history … Read more
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Robin A. Preston

Senior Regional Vice President

Robin Preston is dedicated to improving access to healthcare for low-income populations. She has been working in the policy and … Read more
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Lina Rashid

Principal

Lina Rashid is a nationally recognized expert in public policy, communications, and outreach, with over 15 years of federal leadership … Read more
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Jay Reiser

Principal

Jay Reiser is a healthcare executive with extensive experience driving growth and operational excellence across Medicare, Medicaid, and ACA programs. … Read more
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Matt Roan

Vice President, Client Partnerships & Business Sector Growth

Matt Roan brings a valuable perspective having worked for the past 15 years on issues impacting healthcare stakeholders in the … Read more
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Bill Snyder

Principal

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Margaret Tatar

Vice President, Client Solutions

Margaret Tatar has more than 25 years of public and private sector experience in managed care program and policy development, … Read more
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Patrick Tigue

Senior Vice President, Practice Groups

Patrick Tigue is an accomplished executive with experience leading and managing critical efforts to achieve strategic health policy goals on … Read more
Blog

The Future of Integrated Care Programs for Dually Eligible Individuals in Massachusetts: Key Takeaways from the Fall 2025 MAHP/HMA Policy Forum

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Health Management Associates (HMA) recently co-hosted a policy forum with the Massachusetts Association of Health Plans (MAHP), entitled Advancing Better Outcomes: How the One Care and SCO Programs Improve Health for Older Adults and People with Disabilities on Medicare and Medicaid. More than 100 key decision makers from MassHealth (Medicaid), health plans, providers, community-based organizations, and advocacy organizations attended the conference, elevating the value of the MassHealth One Care and Senior Care Options (SCO) programs to dually eligible individuals. The policy forum also provided an important opportunity for state legislators and their staff to learn about these complex programs.

MassHealth One Care and SCO Programs

Massachusetts’ One Care and the SCO programs currently serve more than 125,000 individuals covered under MassHealth and Medicare, also known as dually eligible individuals. One Care is a population-specific program for dually eligible adults 21-64 years of age. SCO is a population-specific program for dually eligible older adults 65 and older, tailored to the needs of older adults. The One Care and SCO programs serve individuals with complex chronic conditions and disabilities, including mental health and substance use disorder needs, and high home-and-community-based service (HCBS) needs. The One Care and SCO programs advance independent living, recovery, and community living goals. Approximately 99 percent of One Care enrollees, and 95 percent of SCO enrollees, live in the community.

The One Care program is currently authorized as a Financial Alignment Initiative (FAI) demonstration program. The FAI demonstration ends December 31, 2025. MassHealth will continue the One Care program as a Fully Integrated Dual Eligible Special Needs Plan (FIDE SNP) model. This transition from the FAI to a FIDE SNP model introduces changes to the program. A FIDE SNP model is a type of Medicare Advantage (MA) Dual Eligible Special Needs Plan (D-SNP).

HMA’s Role: Bringing National and State Expertise

In addition to creating the forum in partnership with MAHP, HMA shared its national and state policy expertise and local market insights with attendees during a series of presentations. HMA outlined ways in which the One Care and SCO programs offer more value to dually eligible individuals than the state’s fee-for-service (FFS) system.

The event focused on three key topics:

  • The national landscape for Medicare-Medicaid integrated care programs.
  • The value of the One Care and SCO programs and the role that health plans play in improving outcomes for adults who are eligible for both Medicare and Medicaid (“dually eligible”), and
  • The upcoming changes to the One Care and SCO programs, as reflected in the 2026 state Medicaid agency contracts (SMACs) with MassHealth.

Key Takeaways from the MAHP-HMA Conference

Key Takeaway #1. Nationwide trends suggest that Medicare-Medicaid integrated care programs will face competition and financial pressures.

Forum attendees were very interested in the national trends. At the national level, D-SNPs have bipartisan support. At the same time, D-SNPs should expect competition from Chronic Condition Special Needs Plans (C-SNPs) and innovation models developed by the Centers for Medicare and Medicaid Innovation (CMMI). CMMI models such as the Guiding an Improved Dementia Experience (GUIDE) Model and Accountable Care Organizations (ACO) Realizing Equity, Access, and Community Health (REACH) Model will compete with D-SNP models in some markets. Finally, presenters and panelists alike raised concerns about the financial risks that D-SNPs will face due to rising pharmacy costs and changes in Medicare payment methodologies.

Key Takeaway #2. The Massachusetts One Care and SCO programs provide significant value to dually eligible individuals in Massachusetts.

The One Care and SCO programs provide significant value to enrollees. As compared to FFS, Medicaid-Medicaid integrated care programs like One Care and SCO provide care coordination, a personal care plan, bundling prescriptions through a single provider, and other services.

Many forum attendees pointed out that the One Care program is one of the most advanced integrated care programs in the nation. One Care’s success is tied in part to the active and critical role that the One Care Implementation Council plays in shaping program policy. For more than a decade, the One Care Implementation Council and MassHealth have worked in partnership to improve the program. As shared by the Massachusetts Medicaid Policy Institute (MMPI): “The Commonwealth intends to preserve the Implementation Council’s role in the next phase of One Care, and to continue engaging the council as an essential partner in policy and program change, monitoring, and oversight.”

Key Takeaway #3. Over the last two decades, SCO and One Care plans have established many innovations.

The forum highlighted many innovations in these programs, from primary and urgent home care to place-based supports. It also provided an opportunity to talk about the important role and commitment that the plans have in emergency situations to ensure that members are safe in the face of a community crisis.

Panelists see many opportunities for plans to continue to evolve and improve outcomes and equity. For example, the One Care program has significant opportunities to address the behavioral health needs of dually eligible adults. Dually eligible adults with mental health and/or substance use disorder diagnoses are at higher risk of an emergency department visit and inpatient stay than other enrollees. Health plan per member per month (PMPM) spending on inpatient services for those with a behavioral health condition is much higher as a share of the total PMPM than other populations. The HMA data pointed to a need for further innovation in the mental health arena to advance better outcomes of quality of life and costs.

Key Takeaway #4. Conference attendees focused on the importance of addressing enrollees’ social determinants of health needs.

Throughout the day, the importance of community and addressing the social determinants of health (SDOH) was a common theme. Aging and disability leaders spoke about the importance of community organizations such as Aging Services Access Points (ASAPs), independent living centers (ILCs), recovery learning communities (RLCs) including peer support since most  One Care and SCO individuals live in the community.

Many One Care and SCO eligible individuals are often just one unmet health related social need away from the risk of hospitalization or institutionalization. Other attendees underscored the risk that enrollee living situations and recovery can become instantly unstable due to the death of an important family member. One aging leader described her role as “triaging risk.” Other leaders from the disability community urged plans to use z codes to improve plan and provider attention to identify and address the SDOH needs.

Looking Ahead

As Massachusetts prepares for the 2026 One Care and SCO contract year, the forum underscored the progress made over the past decade and the opportunities ahead to improve care coordination, collect z codes, and invest in outcomes-driven partnerships. Massachusetts is well-positioned to continue leading the nation in designing integrated care programs that improve health and support community living for older adults and people with disabilities.

HMA looks forward to supporting all organizations including state Medicaid programs and health plan and provider associations as they convene stakeholders to improve their integrated care programs. Our expertise includes program planning, strategy and implementation, technical support and evaluation, and state-specific knowledge to make projects successful. Please contact Ellen Breslin, Rob Buchanan, and Julie Faulhaber for more information on how HMA can help your organization.

Summary Facts About the One Care and SCO Programs
The One Care and SCO programs are population-specific programs, serving more than 125,000 individuals with MassHealth plus Medicare coverage.   MassHealth designed the One Care and SCO programs around the specific needs, preferences and goals of adults and older adults.The One Care program enrolls dually eligible adults with disabilities, ages 21-64 at the time of enrollment, covered under MassHealth Standard or CommonHealth and Medicare (Parts A and B, and eligible for Part D). Enrollees in One Care have multiple chronic conditions and disabilities including significant mental health and substance use disorder needs. The SCO program enrolls dually eligible adults ages 65 and older, covered under MassHealth Standard and Medicare (Parts A and B, and eligible for Part D). SCO enrollees have significant chronic conditions, many of which are associated with aging.
MassHealth launched the SCO program in 2004 and One Care in 2013.   The One Care program currently operates as a Financial Alignment Initiative (FAI) demonstration. The One Care and the SCO programs combine MassHealth & Medicare benefits into a single plan with one card and one care team. One Care covers medical, mental health, and prescription medications, plus support for daily tasks and independent living and recovery. Care coordinators help members stay healthy and get the services they need.
The One Care and SCO Programs Continue to Evolve. The FAI demonstration authority ends in 2025. Massachusetts will shift from the demonstration to a Fully Integrated Dual Eligible Special Needs Plan (FIDE-SNP) structure. The SCO program currently operates as a FIDE SNP model. The state reprocured the One Care and SCO plan network. The state selected five One Care plans and six SCO plans. New contracts for One Care and SCO plans start January 1, 2026.The new contracts create several changes including changes in eligibility for the program and enrollment processes, benefits, and financial payment provisions.
Blog

Rewriting the Playbook: State Budgeting in the Era of OBBBA

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As of October 22, 2025, all but two states—North Carolina and Pennsylvania—had enacted budgets covering fiscal year (FY) 2026, even as the federal landscape has shifted dramatically throughout the year. In particular, passage of the 2025 Budget Reconciliation Act (OBBBA) and the ongoing federal budget impasse are creating significant downstream pressures on state budgets and the programs they support.

A new report from Health Management Associates Information Services (HMAIS) examines enacted state budgets. Of the 48 enacted budgets, 16 cover the 2025‒27 biennium, and three states—Kentucky, Virginia, and Wyoming—approved budgets in 2024 for the FY 2024‒26 biennium.

The HMAIS report highlights state Medicaid funding priorities, initiatives states are pursuing to adapt to new federal Medicaid and other healthcare policy changes, and reforms to strengthen and ensure the sustainability of programs, particularly in states that expect a reduction in the federal share of their Medicaid program.

OBBBA’s Impact on State Budgets

Congress has yet to reach agreement on the federal fiscal year 2026 spending bills, and there are emerging signals of the challenges this impasse will create for states and federally funded public services. For example, this week the US Department of Agriculture’s Food and Nutrition Service notified every state that Supplemental Nutrition Assistance Program (SNAP) benefits will be withheld because of the funding lapse. This unprecedented situation puts immediate pressure on states and community organizations, which may need to intervene to fill gaps in essential services and benefits.

In addition to the funding impasse, OBBBA introduces major changes, particularly for the Medicaid program, including:

  • Medicaid Community Engagement/Work Requirements: All states must implement these requirements for certain Medicaid members by December 31, 2026, requiring rapid infrastructure and system changes.
  • Eligibility and Redetermination: States must conduct Medicaid eligibility redeterminations every six months for expansion populations, with new verification requirements and narrowed definitions for “qualified” immigrants. States will need to pressure test their systems for increased volume and may need additional capacity to prevent and minimize backlogs.
  • Cost Sharing: By 2028, states must apply a cost sharing requirement for Medicaid expansion adults with incomes above 100 percent of the federal poverty level, with some service exemptions. In 2026, states will need to begin efforts to ensure their systems can track this requirement.
  • Provider Taxes and Payments: Freezes on provider tax programs, phased reductions in allowable tax rates, and caps on state-directed payments will reduce flexibility and funding.

In addition, the Rural Health Transformation Program and new federal drug pricing initiatives present both opportunities, such as new funding streams, and risks, including administrative complexity and compliance expectations.

Given the scope of federal changes, states face urgent decisions. They must quickly assess and act on these opportunities, often without dedicated budget allocations.

These federal changes, combined with the budget impasse, are forcing many states to revisit approved budgets, adapt policies, and plan for new initiatives and revise programs that were already in effect—often within short timelines and with limited resources.

State-Level Challenges and Adjustments

Notably, most states enacted their budgets before the passage of OBBBA. As a result, these budgets do not fully account for the new federal requirements, funding changes, and administrative expectations that OBBBA introduces. While many OBBBA provisions will not take effect for at least a year, states must now accelerate planning and make rapid adjustments to comply with new mandates. For example, states are expected to expediently and efficiently implement systems and policies to ensure compliance with OBBBA’s statutory requirements, particularly for the Medicaid program.

HMAIS has examined state budgets that will guide states through the next fiscal year, while also watching closely how they respond to new demands during the first full state legislative cycle under OBBBA.

The HMAIS report describes a mix of budget conditions and actions. Many states continue to invest in ongoing healthcare priorities as well as new initiatives, including targeted rate increases for behavioral health, dental, and maternal health services. In addition, states are addressing inefficiencies in program administration broadly. In healthcare specifically, they are revisiting approaches to financing healthcare service delivery to drive more value from organizations, such as implementing alternative payment models in Medicaid programs, as well as considering tools to improve patient outcomes and consumer experiences.

States are using a variety of tools in their Medicaid budgets to manage these pressures, as well as implementing more general cost-reduction and efficiency measures, including:

  • Special Legislative Sessions. Some state legislatures, including Colorado’s and New Mexico’s, have reconvened to address emerging gaps.
  • Hiring Freezes. Several states, including Alaska, Colorado, Maryland, Massachusetts, New Hampshire, and Washington, have announced hiring freezes, which could complicate OBBBA preparation efforts.
  • Pausing or Ending Planned Programs and Benefit Coverage. Oregon announced that it will end its juvenile justice Medicaid reentry program to conserve funding. North Carolina will not cover new weight-loss drugs because of its budget shortfall. The HMAIS report indicates that officials in other states also have signaled that they are planning for similar updates to their programs if required to address budget shortfalls.
  • Medicaid Provider Rate Updates. Colorado rolled back a planned Medicaid provider rate increase, while Idaho is decreasing all Medicaid provider rates by 4 percent.
  • Coalitions and Advisory Groups. Other states, including Rhode Island, are convening groups charged with analyzing how the federal cuts may affect their state programs and advising the legislature on feasible responses to the changed landscape.

What to Watch

Healthcare organizations are essential partners as states navigate the current federal budget uncertainty and implement OBBBA requirements. Given the challenges cited above, healthcare organizations should be prepared to collaborate and position to anticipate future needs as the exact components of the various policies are in development.

Recommendations for states and healthcare organizations include:

  • Do not delay planning. While federal policymakers are developing guidance and regulations, the OBBBA language provides significant information on what states need to do and initial expectations for reporting. States and their partners should be developing options and contingency plans to make expeditious decisions once details are available.
  • Monitor and anticipate state actions and develop responses that are ready to go if needed. For example, states may need to make rate reductions, limit enrollment for optional programs, and communicate with beneficiaries about new requirements. Partners should plan to adapt to these changes and assist providers and beneficiaries as needed.
  • Prepare for changes in workload. States will need to design, develop, implement, and report on new Medicaid eligibility and enrollment requirements. They will need a workforce that is trained and can read into the policies, systems, and related needs. States will expect their partners to collaborate on efficient approaches to meet workload demands.
  • Engage with state officials. States need thoughtful partners to manage and implement the forthcoming changes that will affect Medicaid partners and beneficiaries. Healthcare organizations should bring experience and data-informed ideas and input to facilitate state approaches and decision-making.

Connect with Us
With federal funding reductions and ongoing uncertainty at the national level, states need to pay heightened attention to the frontline of essential healthcare and human services, implementation of OBBBA, and means of addressing gaps left by federal delays. As we approach the 2026 election year—with many governors up for reelection—state budgets will serve as a blueprint for leadership and policy priorities in the next cycle.

HMA is on the frontlines, working with states and healthcare partners to navigate these complexities. HMA has expertise, tools, and insights—from budget contingency planning supports to analysis of public coverage program enrollment and market insights.

The full report is available to HMAIS subscribers. For questions contact our experts below.

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