
October 1, 2025
The Rural Health Transformation Program: Options to Address the Maternity Care Crisis
红领巾瓜报 Insights 鈥 including our new podcast 鈥 puts the vast depth of 红领巾瓜报鈥檚 expertise at your fingertips, helping you stay informed about the latest healthcare trends and topics. Below, you can easily search based on your topic of interest to find useful information from our podcast, blogs, webinars, case studies, reports and more.

The Rural Health Transformation Program: Options to Address the Maternity Care Crisis

Persistent gaps in women’s health research, funding, clinical outcomes and access are increasingly well-studied, however less emphasis is placed on the role of coding, coverage, and reimbursement and whether male or female gaps exist in each of these key market access domains. The paper, Coding, Coverage and Reimbursement: Considerations for Women鈥檚 Health Access, examines challenges in these areas and offers recommendations to increase awareness, establish evaluative processes, and collaborative action to achieve incremental policy changes that can have a significant impact over time.

As of October 1, 2025, federal budget negotiations have led to a temporary government shutdown, prompting healthcare leaders to monitor potential impacts on programs administered by the Centers for Medicare & Medicaid Services (CMS). While federal agencies have contingency plans in place, to date CMS has not announced any potential impacts, including to the timelines for the application and award dates for the Rural Health Transformation (RHT) Program.
State governments and healthcare leaders should continue to develop and prepare to submit their applications for the RHT program, which provides a significant opportunity to revitalize rural healthcare infrastructure through strategic investments in access, workforce, innovation, and technology.
To maintain momentum and optimize their resources during this period of uncertainty in federal government funding and operations:
To support strategic planning and initiative tracking, 红领巾瓜报 (红领巾瓜报) is offering a free RHT Project Management Tool. This resource helps states:
Access the RHT Project Management Tool from 红领巾瓜报:
States and their partners can continue to refer to key CMS resources:
States can also submit questions to [email protected].
While the government shutdown presents challenges for many federal programs, it remains unclear whether there will be any direct impact on CMS鈥檚 engagement with states regarding the Rural Health Transformation Program. Regardless of federal circumstances, this moment highlights the value of state-level leadership and innovation. By leveraging tools like 红领巾瓜报鈥檚 project management platform and aligning with CMS鈥檚 strategic goals, states can continue advancing rural health transformation and position themselves for success, even in uncertain times.

Health insurance coverage is likely to be disrupted by changes in ACA marketplace financing, particularly due to the projected reductions in ACA subsidies, as well as the impacts of eligibility and enrollment changes in Medicaid. At a recent 红领巾瓜报 webinar, our ACA marketplace experts detailed a number of challenges that health plans participating in the ACA will face in the coming months and years due to these new policies, and some of the thinking behind ways that plans can take action now while Congress debates whether to extend any of the subsidies.
The webinar touched on areas including:
The ACA marketplace is bracing for impacts for the 2026 plan year, depending upon potential Congressional actions in the remaining months of 2025. In May 2025, CMS put out a rate filing bulletin for plan year 2026 that gave technical directions for submissions and urging states and issuers to be prepared to react to Congressional action. This was a signal that the administration anticipated potential policy changes between May when they put this out and the rate filing window in the fall.
This is reminiscent of the ACA changes that happened in 2017, when there was litigation around cost-sharing reduction (CSR) subsidies that needed to be appropriated. (This was during the 鈥渞epeal and replace鈥 debate in Congress, in that same July-August timeframe.) When repeal efforts failed in Congress, the Administration decided not to pay CSRs, necessitating a bipartisan agreement to address this new financing issue. Changes to CSRs were dropped from this year鈥檚 law but could be addressed before the end of the year in upcoming appropriations bills in Congress.
鈥淎CA plan strategies need to change to ensure that they are considering different outcomes in the market composition and competitor changes to pricing strategies. Expect more policy changes and potential for market churn, making pricing difficult in 2027 given the limited information on what happens in 2026.鈥 – Michelle Anderson
A recent Wakely report analyzing the early draft of HR 1 before passage () details estimated reductions in the individual market enrollment with potential reduction anywhere from 47 to 57% or 11.2 to 13.6 million enrollment enrollees by 2028. The attrition estimates include the loss of both federally subsidized individuals, as well as the unsubsidized due to premium increases. This paper was quoted in a recent NY Times piece,
鈥淐hanges are coming for Healthcare.gov and state marketplace consumers in 2026. The (likely) expiring enhanced premium tax credits, as well as provisions within HR 1 and the Marketplace Integrity and Affordability rule will all be rolled out to marketplace consumers this coming Open Enrollment. In addition to the marketplaces, state departments of insurance, issuers, enrollment assistance professionals, and other stakeholders will play a critical role in helping consumers navigate the coming eligibility and affordability changes.鈥 – Zach Sherman
Impacted marketplace consumers need to be made aware of these coming changes. States and issuers should undertake a broad, aggressive, and coordinated communication effort around the overall rate changes. Ensuring consumers understand how their net premium is changing due to expiring enhanced premium tax credits as well as the other operational changes will be crucial to their ability to stay covered. We expect to see considerable consumer plan switching this coming open enrollment as a result. Some consumers may need to buy-down to silver or bronze plans to be able to afford to maintain their coverage. Marketplaces will need to ramp up customer service and navigation support. States with reinsurance programs or premium subsidies should consider ramping up funding to mitigate the affordability gaps that are likely to occur.
鈥淚t’s really important for folks in the ACA marketplace community to be active when it comes to policymaking and advocacy.鈥&苍产蝉辫; 鈥 Liz Wroe
These issues are part of the government funding debates underway right now as a government shutdown looms. Depending upon the outcome with the September funding deadline, or the possibility of a supplemental funding bill this year, these ACA marketplace issues could be addressed in several sets of negotiations. Now is the time to talk to your state officials, insurance commissioners, associations and contacts in the Federal government to ensure they have a good understanding of how these ACA marketplace changes will impact coverage in your state.
To hear the full discussion, you can find the replay and materials for the ACA webinar here, and download the full Wakely paper at .

New 红领巾瓜报 report discusses the unmet needs of older adults in low-income housing, highlighting the challenges of siloed programs and the difficulty in blending services
Research consistently shows that more than 70 percent of Americans want to age in place, remaining in their own homes. Yet the country鈥檚 shifting demographics, rising costs for long-term services and supports, and changing financing landscape make achieving this goal more challenging than ever, especially for low-income older adults. In fact, more than one-quarter million older Californians live in senior affordable housing developments that range in size from a few dozen apartments to over a thousand units in large high rises. Most striking was the finding that while many of these residents are not only low-income and disproportionately burdened with chronic disease and also dually eligible for Medicaid and Medicare鈥攁 group shown in countless studies to represent a considerable proportion of Medicare and Medicaid costs, but that few residents appear to participate in aligned Medicare and Medicaid special needs plans (D-SNPs) or to access Medi-Cal waiver services.
The report gathers direct input from older adults, including Asian populations, in eight languages, addresses critical funding gaps, and identifies policy priorities that if implemented offer innovative recommendations for California to reduce duplication and better serve older adults using current resources.

红领巾瓜报 (红领巾瓜报) prepared this compendium in September 2025 on behalf of the Chicago Department of Public Health. It was developed at a pivotal moment, as Illinois was poised to take action on multiple program initiatives of critical importance to community providers: reprocure its Medicaid Managed Care system, initiate provider training for 1115 Medicaid Waiver services that address social determinants of health (SDOH), prepare a new Community Health Worker (CHW) benefit, continue implementation of Doula services as a Medicaidcovered benefit, and establish a Third Party Administrator (TPA) support system to promote statewide access to new services, potentially via regional hubs.
A team of subject matter experts with deep experience in Illinois鈥檚 social health and healthcare sectors, as well as national social health integration efforts, created this resource to help organizations evaluate how these program initiatives will affect the services they provide, understand their opportunities to successfully participate in the Medicaid delivery system, and support their ability to effectively serve the needs of their communities. The team brings extensive knowledge of how community-based organizations (CBOs) deliver Medicaid-financed CHW and SDOH services, as well as the alternative payment methodologies managed care organizations (MCOs) use as they engage CBOs to promote population health.
In this context, this compendium is intended to address the following targeted needs identified by stakeholders across the Illinois community-based social health service ecosystem:

As the end of 2025 approaches, the future of enhanced premium subsidies for Affordable Care Act (ACA) Marketplace coverage remains uncertain. These subsidies, extended by the Inflation Reduction Act (IRA), are set to expire December 31, 2025. Without congressional action, millions of Americans will face a sudden and significant increase in out-of-pocket premium costs, reintroducing the 鈥渟ubsidy cliff鈥 and raising the percentage of income that they will need to direct toward health insurance premiums. More than 16 million consumers who now receive subsidies will be affected, making this a critical issue for policymakers, payers, and consumers.
A new from Wakely, an 红领巾瓜报 Company, offers a timely and detailed analysis of the potential impacts and strategic considerations for stakeholders navigating this uncertain terrain.
How ACA Subsidies Are Calculated: The Mechanics Behind Premiums
The white paper explains that advance premium tax credits (APTCs) are designed to cap a household鈥檚 health insurance premium contribution at a specific percentage of income. The calculation is based on household income, size, the cost of the benchmark Second Lowest Cost Silver Plan (SLCSP), and age. The expiration of enhanced subsidies will revert contribution percentages to higher levels, increasing costs for all income brackets.
Premium Shock: Quantifying the Impact of Subsidy Expiration
Wakely鈥檚 analysis shows that the expiration of enhanced subsidies will result in a substantial increase in monthly premium contributions. For example, a hypothetical single 40-year-old at 150 percent of the federal poverty level (FPL) will see monthly premiums jump from $0 to $81.97 in order to keep the same plan.
Mitigation Strategy: Buying Down to the Lowest Cost Silver Plan
Consumers may offset part of the premium increase by switching from the SLCSP to the Lowest Cost Silver Plan (LCSP). The difference in premiums between these two plans translates directly into monthly savings, independent of income. In Raleigh, NC, a hypothetical 40-year-old could save $53.03 per month by buying down, mitigating about two-thirds of the premium shock. For older consumers, the savings are even greater; however, in highly competitive markets like Charlotte, NC, the premium gap鈥攁nd the savings鈥攚ill be much smaller, offsetting only a modest portion of the increase.
Consumer Savings
After applying the buy-down strategy, the net premium increase for a hypothetical single 40-year-old at 150 percent of the FPL in Raleigh will be $28.94 per month rather than $81.97 without mitigation. Depending on age and location, consumers can offset 37鈥100 percent of the premium increase in less competitive markets, but only 7鈥28 percent in highly competitive ones.
Market Dynamics: Why Local Competition Matters
The effectiveness of mitigation strategies depends on local market dynamics and competition. In markets with fewer carriers and larger premium gaps, consumers have greater opportunities to offset premium increases. In competitive markets, options are more limited. The paper notes that the 2026 landscape may shift due to carrier exits and price changes, underscoring the need for ongoing monitoring and adaptive strategies.
Recommendations for Payers, Regulators, and Brokers
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Wakely is experienced in all facets of the healthcare industry鈥攆rom carriers to providers to government agencies. Wakely actuarial and policy experts continually monitor and analyze potential changes to inform healthcare organization strategies and advance effective solutions to propel their success.
For questions about this analysis or to discuss strategies for navigating the post-subsidy cliff, contact聽our expert below.

Navigating the Post-Subsidy Cliff鈥擬itigating Premium Increases After Enhanced ACA Subsidies Expire

Michelle Anderson, director and senior consulting actuary at Wakely, an 红领巾瓜报 Company, joins Vital Viewpoints on Healthcare to unpack the state of the Affordable Care Act (ACA) marketplace. From the market鈥檚 volatile beginnings to today鈥檚 uncertainty around subsidies, Michelle shares how insurers, states, and consumers have adapted and what challenges lie ahead. We explore the forces shaping affordability, coverage options, and consumer behavior, as well as the critical policy decisions that could redefine the individual market in 2026 and beyond.

The September 2025 release of the “” marks a pivotal moment in the Trump Administration鈥檚 effort to address childhood chronic disease. Building on the work of the Make America Healthy Again (MAHA) Commission鈥攅stablished by in February 2025 and led by US Health and Human Services (HHS) Secretary Robert F. Kennedy, Jr.鈥攖he Strategy Report provides a proposed road map for federal, state, and local action.
The MAHA child-focused Strategy Report is already driving the Trump Administration鈥檚 healthcare agenda. Though the report sets ambitious goals, public health entities, state governments, and other experts have raised concerns that several recommendations run counter to established scientific research or lack sufficient evidence.
In this article, 红领巾瓜报 (红领巾瓜报) experts highlight the areas of focus in the Make Our Children Healthy Again Strategy Report and offer specific recommendations, initiatives, and considerations for stakeholders. Earlier editions of In Focus have addressed the commission鈥檚 formation, initial assessment, and the administration鈥檚 growing focus on childhood health (Spotlight on Development of President Trump鈥檚 Children鈥檚 Health Strategy).
Key Components of the MAHA Strategy
Advancing Critical Research to Drive Innovation
The strategy identifies broad areas of research to inform healthy outcomes and positions HHS to direct initiatives in collaboration with the US Food and Drug Administration (FDA), the Centers for Disease Control and Prevention (CDC), and other agencies. Examples include:
Realigning Incentives and Systems to Drive Health Outcomes
The report recommends improvements to transparency and efficiency in regulatory processes to address nutrition, fitness, pharmaceuticals and vaccines, and care delivery and payment to address chronic disease. Specific initiatives include:
Increasing Public Awareness and Knowledge
Major campaigns will involve:
Fostering Private Sector Collaboration
The strategy emphasizes the administration鈥檚 work to advance private sector partnerships aligned with MAHA priorities, including partnerships to achieve the following:
Key Considerations for Partners and Stakeholders
Early engagement is critical as federal agencies begin implementing over 120 recommended actions.
States, providers, health plans, and community organizations should identify how their current approaches to children鈥檚 health could align with the MAHA initiative and strategy report, as well as where these new ideas might conflict with present policies. This assessment will identify opportunities to maximize new federal funding opportunities and additional resources.
Progress toward the Strategy Report鈥檚 specific goals will require coordinated efforts across agencies, sectors, and communities. Stakeholders should consider how and when to engage in research, policy development, and public awareness campaigns outlined in the report.
Connections to Trump Administration Priorities and Broader Opportunities
The report鈥檚 recommendations are already influencing federal agency actions and are driving congressional hearings and new legislation at the federal and state levels.
The US Department of Agriculture鈥檚 (USDA), for example, is working with states to approve SNAP waivers to restrict the purchase of junk food with federal benefits. 红领巾瓜报 experts are tracking the SNAP waiver actions, and as of September 2025, a total of 12 states have received USDA approval for waivers that restrict the purchase of soda, candy, and other unhealthy foods with SNAP benefits. Other states are considering similar waivers, and the USDA is providing technical assistance to support these efforts.
The FDA has enhanced oversight of direct-to-consumer pharmaceutical advertising, including new enforcement activities and rulemaking on drug safety disclosures in ads. This approach aligns with MAHA recommendations and Trump Administration priorities for transparency and consumer protection.
HHS is also pursuing a new vaccine framework; however, states retain significant authority over school-based immunization requirements, and several are considering alternative approaches or maintaining broader vaccine recommendations than those outlined in the MAHA report. Recent legislative actions in some states seek to shift authority for determining school-based immunization requirements solely to the legislature, reflecting ongoing debate and federal-state dynamics.
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As implementation of the Make Our Children Healthy Again Strategy Report advances, all stakeholders must be ready to engage, partner, innovate, and drive change that will shape the future of child health.
红领巾瓜报 guides state and local government, providers, plans and other partners through the multi-pronged strategies and recommendations in the report as well as the complexities of federal funding opportunities, such as the new Rural Health Transformation Program. We are helping state and local policymakers plan for MAHA and Trump Administration priorities, which includes guidance on how to leverage innovative approaches like SNAP waivers to promote healthy food access for children and families.
With deep expertise in policymaking and operational management, 红领巾瓜报 consultants are enabling states and their partners to accelerate their work, build sustainable models for child health improvement, and position themselves to take advantage of new federal, state, and local policy opportunities driven by the MAHA report. To discuss questions about the impact of the report contact our experts below.

The Centers for Medicare & Medicaid Services (CMS) has officially opened the window for the (RHTP)鈥攁 $50 billion federal initiative designed to stabilize and transform rural health systems across the country. This one-time opportunity allows states to submit a comprehensive plan that could redefine how rural communities access care, manage chronic conditions, and sustain their healthcare infrastructure.
As outlined in our earlier In Focus article, , RHTP represents one of the most significant federal investments in rural health in decades.
Applications must be signed by governors and submitted by November 5, 2025, and awards are expected by December 31, 2025, providing states with a very narrow window to act.
The remainder of this article explains key aspects of the RHTP application, including the evaluation and scoring aspects. Notably, the structure of the scoring system will reward states that are already aligned with these , as well as those willing to implement new initiatives or make state policy changes to achieve alignment.
Program Overview and Funding Structure
Created under HR.1, the 2025 Budget Reconciliation Act, the RHTP allocates $10 billion annually from federal fiscal year (FY) 2026 to FY 2030, totaling $50 billion over five years. Funding is split into two tranches:
States must submit a single, one-time that covers the full five-year period. Stand-alone provider applications will be declined. Hence, states must coordinate across agencies, providers, and stakeholders to develop a unified transformation strategy.
Importantly, this award is not a grant; rather, it is a cooperative funding agreement, which means CMS will play an active role in oversight and collaboration. States must be prepared to meet higher standards of accountability, transparency, and performance monitoring. According to the RHTP application, continued funding requires states to demonstrate satisfactory progress toward implementing their plan.
Application Requirements and Strategic Priorities
To be eligible for funding, states must submit a Rural Transformation Plan that addresses eight core priorities as follows:

Within these core priorities, state plans must propose activities that address several specific issues.
Technical Factor Weighting for Workload Funding Reflects Federal Policy Priorities
CMS outlines the eligibility criteria for baseline funding and the scoring components for workload funding. Baseline funds will be distributed equally among states, while workload funding will be based on each state’s rural facility and population score as well as their technical score. Evaluators will score technical factors based on state policy actions and initiative-based plans for each state.
The technical factors, and the weighting of these factors, in the RHTP application are not just neutral scoring mechanisms; rather, they are closely linked to the Trump Administration鈥檚 health policy priorities.
Preparing for What Happens Next: Implications for States, Providers, and Health Plans
The RHTP offers a rare opportunity to reshape rural healthcare. But success will require strategic coordination and a commitment to long-term change. States in the short and long term should consider include:
Providers and other stakeholders should also prepare to align with state strategies. Examples include:
The scoring structure also incentivizes states that may not yet be fully aligned to implement new initiatives or make policy changes that would improve their technical scores and secure greater funding. States and their partners will need to be united on the goals and initiatives, disciplined about implementing and evaluating the plans based on data informed reports, nimble and willing to make strategic pivots based on feedback and experiences.
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States that are already aligned with Trump Administration priorities鈥攕uch as those with established value-based payment models, short-term limited duration plan options, preferred technology infrastructure, or strong rural hospital support policies鈥攁re positioned to be rewarded in the scoring and funding process.
红领巾瓜报 (红领巾瓜报), is actively supporting states in developing compliant and compelling RHTP applications. Our advisory services include:
We help clients navigate the complexities of federal funding, align transformation goals with community needs, and build sustainable models for rural care delivery. For details about the RHTP, including the 红领巾瓜报IS State Action Tracker, contact 红领巾瓜报 experts below.