This report synthesizes insights from multiple efforts to support the financial sustainability of HealthySteps sites in California, including federally qualified health centers (FQHCs), community clinics (non-FQHCs), private practices, and other settings. Led by the HealthySteps National Office and ϱ (ϱ), the technical assistance (TA) elevated challenges, strategies and best practices to achieve sustainability informed by learning collaboratives, individualized TA sessions, and financial modeling exercises. This report complements additional resources that the HS National Office and ϱ developed which are available via the HealthySteps (HS) Sustainability website.
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Congress Advances FY 2026 HHS Appropriations Bill with Health Extenders and PBM Reforms
On February 3, 2026, Congress finalized federal funding for fiscal year (FY) 2026, with the House passing the Consolidated Appropriations Act (CAA), 2026, with a vote of 217-214, following Senate approval last week. The president signed the CAA () shortly thereafter. The law provides full-year appropriations for the Departments of Health and Human Services (HHS), Housing and Urban Development, Labor, and several other departments.
This year’s HHS funding bill is notable not only for what it includes, but also for what it omits. It restores or maintains funding for key public health and research agencies previously proposed for elimination in the president’s FY 2026 , extends several healthcare programs, and contains a significant package of pharmacy benefit manager (PBM) reforms. All of this activity comes as the Administration new grant programs and policy efforts related to its signature priorities.
In this article, we review the major funding and policies approved in the HHS spending bill. We also address key considerations for healthcare organizations as they anticipate downstream funding and policy developments and develop advocacy initiatives for federal FY 2027 bills.
HHS Funding Levels and Direction
The bill provides $116.8 billion for HHS, an increase of $210 million over FY 2025, and rejects large-scale structural reorganizations proposed in the president’s FY 2026 budget. This provision preserves funding for the Agency for Healthcare Research and Quality (AHRQ), Centers for Disease Control and Prevention (CDC), Health Resources & Services Administration (HRSA), and the Substance Abuse and Mental Health Services Administration (SAMHSA)
Table 1. HHS Agency Funding Highlights, FY 2026
| Agency | FY 2026 Funding | (+/-) Compared with FY 2025 |
| Administration for Strategic Preparedness and Response (ASPR) | $3.7 billion | +$58 million |
| CDC | $9.2 billion | level funding |
| Centers for Medicare & Medicaid Services (CMS), administrative expenses only | $3.7 billion | level funding |
| HRSA | $8.9 billion | +$415 million |
| National Institutes of Health (NIH) | $48.7 billion | +$929 million |
| SAMHSA | $7.4 billion | +$65 million |
The bill also extends mandatory funding for community health centers, special diabetes programs, the National Health Service Corps, and Teaching Health Center Graduate Medical Education.
PBM Reforms in the Package
In one closely watched area of federal policymaking, the FY 2026 package includes a substantial set of PBM-related reforms that largely mirror the bipartisan package negotiated but not enacted in December 2024. These reforms have implications across Medicare Part D, commercial insurance, and employer-sponsored plans.
The legislation contains the following PBM reforms:
- Prohibits PBMs from derivingremunerationlinked to drug prices forMedicare-covered Part D drugs
- Restricts spread pricing in Medicaid,eliminatinga major driver of PBM revenue
- Requires contractual transparency, mandating that PBMs clearly define pricing terms in agreements with Part D plan sponsors
- Adds new PBM reporting obligations, including drug price reporting and rebate disclosures
- Requires 100percentpassthrough of rebates in ERISA-regulated plans for new, renewed, or extended contracts beginning30 monthsafter enactment
- Expands audit rights for plan sponsors
- Codifies the “any willing pharmacy” requirement for Medicare plan sponsors
These provisions position 2026 as a consequential year for PBM regulation, increasing transparency, strengthening plan leverage, and heightening HHS oversight.
Healthcare Extenders and Program Reauthorizations
The bill includes a broad set of Medicaid, Medicare, and public health program extenders, affecting providers, patients, states, and managed care plans.
Medicaid
- Postpones reductionsin theDisproportionate Share Hospital (DSH)allotmentsuntil FY 2028
- ChangestheDSH cap calculationtobroaden which patient costs count toward Medicaid shortfall
- Requires states todevelop and implement a process toallow certain out-of-state pediatric providers to deliver services withoutadditionalscreening for three years
- Removes age limits on Medicaid’s Ticket to Work program, allowing adults older than age65 toparticipateand requires state compliance by January 1, 2028
- Establishes new maternity care reporting requirementsfor rural hospitals, with dedicated federal fundingfor hospitalsand states tocomply withthe reporting
Medicare
Congress extends several key programs and payment provisions, including:
- Telehealth flexibilities through December 31, 2027
- Incentive payments for participation in eligible alternative payment models through payment year 2028 (for performance year 2026) and applies an adjustment amount of 3.1 percent for 2028
- Acute Hospital Care at Home waivers through 2030
- Low-volume and Medicare-dependent hospital payment adjustments
- The1.0 work geographic practice cost index floor used in the calculation of payments under the Medicare physician fee schedule through December 31, 2026
- Add-on payments for ambulance services
- Continuation of Part D coverage for certain antivirals and modifications to hospice payment caps
Behavioral Health Policy
The appropriations billwasfinalizedas theadministrationnew funding and policy initiativestosupport behavioral health, crisis services, workforce expansion, and youth mental health—efforts mirrored in SAMHSA’s increased appropriations.
SAMHSA’s $7.4 billion budget includes:
- $1.6 billionfor State Opioid Response grants
- $1.01 billionfor the Mental Health Block Grant
- $535 million for the 988 Suicide and Crisis Lifeline
Considerations for Stakeholders
Federal funding and policy developments affect state budget dynamics as many states are now releasing 2026–2027 budget proposals as well as the operational and growth plans of healthcare organizations and partners.
A few key takeaways from the FY 2026 funding bill include:
- Federal appropriations signalcongressional andadministration priorities and havedownstreamimpact on upcoming rounds of grant cycles, includingSAMSHA and HRSAawards.
- The approved funding and certain policy extensions provide operational stability and reduce near-term fiscal pressure, such as the further delay of Medicaid DSH cuts. The extra time will allow healthcare entities to prepare for future reductions and plan for financial sustainability.
- Agency and program funding emphasize oversight, program integrity, andcompliance. In addition,fraud and program integritypriorities arewoven intocertainnewpoliciesand programextensions,includingPBM reforms, flexibility for pediatric care across state borders,and rural maternity cost reporting requirements,among others.
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If you would like deeper analysis or state and stakeholder-specific effects, ϱ’s policy experts are available to assist.

ϱ’s Take on 2026 ACA Marketplace Open Enrollment Snapshot
On January 28, 2026, the Centers for Medicaid & Medicare Services (CMS) released its second of 2026 Affordable Care Act (ACA) Marketplace Open Enrollment (OE) activity. While this update is not a final accounting of enrollment activity, it is likely to be the last OE federal data release for some time and offers an early look at how enrollment trends are shifting in the wake of expired enhanced premium tax credits and new eligibility standards under the 2025 budget reconciliation act (P.L. 119-21, OBBBA).
In this article, ϱ (ϱ) and Wakely, an ϱ company, highlight findings from their analysis of the 2026 OE activity and compare this activity with 2025 data. This analysis builds on the findings in their January 2026 analysis () and will provide important context for the 2027 plan year.
Overall Enrollment Trends
CMS reports that 2026 plan selections decreased by 5 percent from 2025, with enrollment declining across both new and returning consumers. New sign-ups dropped by 14 percent and renewals fell by 3 percent (Table 1). State-based Marketplace (SBM) enrollment dipped modestly, though many SBMs were still enrolling consumers in late January.
Table 1. Comparison of 2026 and 2025 Open Enrollment
| 2026 | 2025 | Net Change | |
| Total | 22,973,219 | 24,166,491 | (1,193,272) |
| New Consumers | 3,382,189 | 3,938,907 | (556,718) |
| Returning Consumers | 19,591,030 | 20,227,584 | (636,554) |
Variation Across State-Based and Federally Facilitated Marketplaces
Enrollment patterns varied substantially across states.
SBMs:
- New Mexicosaw thelargestyear-over-yearincrease(14%), attributed tostate-funded subsidiesdesigned tooffset the loss ofenhanced premium tax credits (ePTCs).
- Georgiaexperienced a14percent decline,thesteepest drop amongSBMs.
Federally Facilitated Marketplace (FFM) States:
- Overall, FFM enrollment fell5percent.
- Texas ledFFM stateswith a5percent increase inplan selections.
- Ohio and North Carolina experiencedsubstantial enrollment declines,20percentand22percentrespectively.
What This Tells Us—and What It Doesn’t Tell Us Yet
FFM data are as of January 15, 2026, and measure plan selections after the OE period ended. Within the FFM, state-by-state enrollment activity varied significantly. Some of this variation is surprising and not readily explainable from the available data and will be a focus of future ϱ and Wakely analyses.
The data include neither effectuated enrollment nor paid enrollment—data which will be key to fully understanding 2026 enrollment trends and the impact of changing federal policies, including the ePTC expiration and changing eligibility standards introduced in 2026 as the result of OBBBA.
suggest significantly higher cancellation and disenrollment rates than in previous years.
SBMs are sharing that they expect substantial affordability-driven voluntary and nonpayment terminations over the first half of 2026.
Monitoring paid enrollments, attrition, and grace period dynamics, including retro-terminations, will be key to understanding market dynamics and 2027 pricing.
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ϱ and Wakley experts have considerable experience working with states, insurers, and federal policymakers with jurisdiction over the Marketplace. We work with these entities to inform, analyze, and shape federal policies and conduct impact analyses on pricing, enrollment, administration, and operations. ϱ also provides strategic and project management support for the implementation of finalized policies.
Please contact Michael Cohen, Taylor Gehrke, or Zachary Sherman with questions, follow-up, or if you would like expert assistance exploring any of the issues discussed in this post.

2026 Marketplace Open Enrollment: Where the Numbers Currently Stand
On January 28, 2026, the Centers for Medicaid & Medicare Services (CMS) posted a detailing 2026 Open Enrollment (OE) results. Although this report is neither a complete nor final picture of 2026 Marketplace enrollment activity, it is likely to be the last OE data CMS publishes for some time. A comparison of 2026 and 2025 Open Enrollment results can be found in Table 1.
Table 1. Comparison of 2026 and 2025 Open Enrollment
| 2026 | 2025 | Net Change | |
| Total | 22,973,219 | 24,166,491 | (1,193,272) |
| New Consumers | 3,382,189 | 3,938,907 | (556,718) |
| Returning Consumers | 19,591,030 | 20,227,584 | (636,554) |
A summary of our analysis on these 2026 OE results and how they compare with 2025 data can be found below. This analysis builds on the findings in Wakely’s from January 2026.
- Overall, topline plan selections are down from last year. Total enrollment decreased by 5%, with new enrollment down 14% and renewals down 3%.
- State-based marketplace (SBM) enrollment declined modestly, but the data are as of January 10, and many SBMs are continuing to enroll people through the end of January.
- New Mexico plan selections increased by 14% over last year, the largest increase of any state, driven by state-funded subsidies mirroring the expired enhanced premium tax credits (ePTCs).
- Georgia plan selections decreased by 14%, the largest SBM year-over-year decline.
- The federally facilitated marketplace (FFM) experienced an overall decrease of 5%. FFM data are as of January 15 and therefore measures plan selections after the OE period has ended. Within the FFM, state-by-state results varied significantly.
- Texas led all FFM states with a 5% increase, whereas Ohio and North Carolina experienced 20% and 22% decreases in enrollment, respectively.
- Some of this variation is surprising and not readily explainable from the available data and will be a focus of future ϱ and Wakely analyses.
- The data include neither effectuated enrollment nor paid enrollment—data which will be key to fully understanding 2026 enrollment trends and the impact of changing federal policies, including the ePTC expiration and changing eligibility standards introduced in 2026 as the result of P.L. 119-21 (OBBBA).
- from SBMs suggest significantly higher rates of cancellations and disenrollments than in previous years.
- SBMs are also sharing that they expect high rates of affordability-driven voluntary and non-payment terminations throughout the first half of 2026.
- Monitoring paid enrollments, attrition, and grace period dynamics, including retro-terminations, will be key to understanding market dynamics and 2027 pricing.
ϱ and Wakley experts have considerable experience working with states, insurers, and federal policymakers with jurisdiction over the Marketplace. We work with these entities to inform, analyze, and influence federal policies and conduct impact analyses on pricing, enrollment, administration, and operations. ϱ also provides strategic and project management support for the implementation of finalized policies.
Please contact Taylor Gehrke at [email protected], Michael Cohen at [email protected], or Zachary Sherman at [email protected] with questions, follow-up, or if you would like expert assistance exploring any of the issues discussed in this post.
Related Resources:
- Upcoming Webinar February 4, 2026 at 12pm ET: 2027 ACA Considerations: Proposed NBPP and Other Key Changes and Trends

Medicaid Changes in the OBBBA and Implications for the Marketplace and Individual Market in 2027
In recent years, the individual market has undergone significant disruption. The expiration of enhanced premium tax credits (ePTC) at the end of 2025 and sweeping eligibility changes under the 2025 Budget Reconciliation Act (OBBBA) have reshaped—and will continue to reshape—the individual market.
The number of changes facing states and issuers in coming years are significant. As a result, it is unsurprising that discussion and analysis on the individual market impacts of the new Medicaid requirements is limited and expected to result in large numbers of Medicaid beneficiaries being disenrolled. Between community engagement requirements (i.e., work requirements), increases in eligibility checks, and loss of eligibility for certain immigrant population, the expectation is that millions of people will leave Medicaid in 2027.
This brief explores how these coming changes will reshape coverage pathways and costs, and examines implications for consumer affordability and churn, issuer pricing and risk pools, and state administrative burdens—alongside strategies for states, issuers, and policymakers to mitigate adverse effects.

CMS ACCESS Model: A New On-Ramp to Outcomes-Based, Tech-Enabled Care in Traditional Medicare
The Centers for Medicare & Medicaid Services (CMS) Innovation Center recently published applications for its new (Advancing Chronic Care with Effective, Scalable Solutions), a 10-year voluntary initiative beginning July 2026. The model is designed to advance outcomes-based, technology-enabled care delivery in Original Medicare and aligns with the Innovation Center’s priorities of strengthening prevention, empowering beneficiaries, and promoting performance-based competition. ACCESS is particularly suited to organizations with mature clinical operations and data infrastructure, offering a new pathway for tech-supported services.
This article summarizes the model’s design, highlights key considerations for prospective applicants, and addresses common questions our Medicare and technology experts fielded during a recent Health Management Associates (ϱ)/Leavitt Partners webinar.
What the ACCESS Model Is Testing
ACCESS evaluates whether Outcome-Aligned Payments (OAPs)—recurring payments contingent on measurable clinical improvement—can reduce spending while maintaining or improving quality for beneficiaries with chronic conditions. The model tests whether incentivizing technology supported care can produce reliable clinical outcomes while complementing traditional care delivery.
Who may participate? Organizations must be Medicare Part B–enrolled providers or suppliers (excluding DMEPOS [Durable Medical Equipment, Prosthetics, Orthotics, and Supplies] and labs). Participants may enroll beneficiaries directly, operate across multiple clinical tracks, and manage all qualifying conditions within each selected track. Beneficiary participation is voluntary, and individuals may switch ACCESS participants every 90 days.
Clinical tracks. At launch, the four clinical tracks reflect high-prevalence chronic conditions with established care pathways and strong evidence for technology-supported interventions:
- Early Cardio-Kidney-Metabolic (eCKM)
- Cardio-Kidney-Metabolic (CKM)
- Musculoskeletal (MSK)
- Behavioral Health (BH)
Payment. OAPs vary by track and performance period. CMS pays a portion prospectively each quarter and withholds 50 percent pending reconciliation based on:
- Clinical outcomes attainment: The percentage of aligned beneficiaries who complete the 12‑month performance period and achieve track‑specific clinical targets relative to their baseline.
- Substitute‑spend test: Ensures beneficiaries do not receive duplicativefee-for-service (FFS)services for conditions managed under ACCESS.
Technology and data exchange. ACCESS takes a tech-forward approach. Key expectations include use of Fast Healthcare Interoperability Resources (FHIR®) based Application Programming Interfaces (APIs) for eligibility, consent, claims sharing, and care coordination—part of the broader federal push to modernize the health data ecosystem. CMS also plans to publish a public directory that lists participants, tracks, cost-sharing policies, and risk-adjusted outcomes to enable consumer and clinician choice.
Regulatory coordination. To complement ACCESS and expand the pipeline of technology-supported interventions, the US Food and Drug Administration’s (FDA) (Technology-Enabled Meaningful Patient Outcomes) allows selected US-based digital health device manufacturers to participate while generating real-world evidence. Up to 40 device manufacturers may participate across clinical areas.
This coordinated CMSFDA effort is intended to reduce barriers to innovation and accelerate access to safe, effective digital tools that can support chronic disease management.
Key Considerations for Applicants
Program integrity and fraud/abuse. CMS has emphasized program integrity across Medicare and Medicaid, and ACCESS reflects that emphasis. Applicants and their parent organizations should expect rigorous screening. Participants must also operationalize controls to pass the substitute spend test and maintain auditable evidence of outcomes and beneficiary consent.
Overlap with Accountable Care Organizations (ACOs) and other models. Patients may participate in ACCESS and be aligned with an ACO simultaneously; however, “participant overlap” raises important operational and financial issues. ACCESS includes an FFS exclusion policy that prohibits participants or affiliated entities from billing Medicare FFS for any services delivered to the same beneficiaries for the duration of their ACCESS episode. As a result, traditional providers, ACO-aligned clinicians, and integrated delivery systems must assess whether they can segment patient populations or if partnering is more feasible.
Eligibility and clinical scope. ACCESS is focused on relatively stable, chronically ill beneficiaries and excludes those with more acute/severe conditions. Participants must accept responsibility for all qualifying conditions a beneficiary has within a track.
ܳٳdzڴǰԳ.TheACCESS Model places substantialemphasis on clinicalperformanceand care coordination. Participantsare paid in full only if enough patients hit outcomes targets.Early cohorts willlikely skewtoward organizations with mature clinical protocols, robust engagement models, and demonstrated outcomes.Applicants shouldbefinanciallypreparedtotolerate withholds, beneficiary switching, andfollow-onperiod payment reductions after year one.
Digital infrastructure and interoperability. ACCESS presumes API-driven data exchange, including consent capture, eligibility checks, claims/clinical data integration, and bidirectional information sharing with the patient’s broader care team. Applicants should ensure they have a FHIR API server and meet the requirements described in the CMS .
Go-to-market and referral strategy. Beneficiary alignment is voluntary and will be facilitated by CMS’s planned public directory with risk-adjusted outcomes. Access participants will benefit from strong referral relationships—especially with ACOs and primary care providers—both to enroll eligible beneficiaries and to minimize substitute services. A field strategy grounded in evidence, patient engagement, and interoperability with local providers is critical to success.
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for the first ACCESS Model performance period are due April 1, 2026, with model launch in July 2026; applications submitted later would start January 1, 2027. Because ACCESS is a rolling, decade-long model, some organizations may choose to stage entry.
ACCESS is the most explicit Innovation Center opportunity to date on outcomes-based, tech-enabled chronic care in Traditional Medicare. It offers digital health and advanced care organizations a direct line to FFS beneficiaries with payment tied to results, not activities. Success will favor teams that combine clinical excellence, consumer-grade engagement, and API-level interoperability, as well as manage program integrity, ACO overlap, and beneficiary churn.
For questions or support assessing readiness, developing an application, or operationalizing the model, contact Amy Bassano, , or Kate de Lisle.

CMS Releases 2027 Advance Notice with Medicare Advantage and Part D Rates
The Centers for Medicare & Medicaid Services (CMS) released the on January 26, 2026. The Advance Notice begins CMS’s annual rate-setting cycle and describes proposed updates to Medicare Advantage (MA) growth rates, benchmark rebasing, risk adjustment, Star Ratings, and Part D payment parameters. CMS previously released a in November 2025 that included policy changes to the Star Ratings system and enrollment policies for MA and Part D starting in contract year 2027. (Read the ϱ (ϱ) summary here.)
Comments onthe Advance Notice are due February 25, 2026, andCMS will publish the final CY 2027 rate announcement no later than April 6, 2026.
This article provides an early look at the proposed methodological updates and draft capitation rates. Wakely, an ϱ Company, will publish a detailed analysis of the Advance Notice in early February.
Payment Impact on Medicare Advantage Organizations
CMS estimates a national per capita MA growth rate of 5.10 percent from 2026 to 2027, with fee-for-service (FFS) non-end-stage renal disease (non-ESRD) growth of 5.10 percent and FFS dialysis end-stage renal disease (ESRD) growth of 6.17 percent.
The5.10percent growth rate reflects projected increases in percapitaFFSMedicare spending for beneficiaries who areaged/havedisabilitiesand serves as the primary driver of 2027 benchmark updates, interacting with rebasing and risk adjustment changes todeterminefinal capitation payments.The growth ratereflectsupdatestohow CMS pays for skin substitutesin the 2026 Medicare PhysicianFeeSchedule. These updates resulted in significantly lower projected costsand materially reducedthe growthrate.
These preliminary estimates inform the development of MA benchmarks and may change in the final rate announcement.
Table 1. Estimated Impact of Proposed Payment Changes on Medicare Advantage Plan Payments, CY 2027
| Year-to-Year Percentage Change | |
| Impact | CY 2027 Advance Notice |
| Effective Growth Rate | 4.97% |
| Rebasing/Re-pricing | TBD |
| Change in Star Ratings | -0.03% |
| MA Coding Pattern Adjustment | 0% |
| Risk Model Revision and Normalization | -3.32% |
| Sources of Diagnoses | -1.53% |
| Expected Average Change | 0.09% |
| Source: Centers for Medicare & Medicaid Services. 2027 Medicare Advantage and Part D Advance Notice. January 26, 2026. Available at: https://www.cms.gov/newsroom/fact-sheets/2027-medicare-advantage-part-d-advance-notice. | |
Medicare Advantage Benchmarks, Rebasing, and Risk Adjustment
The Advance Notice describes CMS’s approach and changes that will affect payment to plans, including:
- Excluding from the risk adjustment process diagnoses submitted from chart reviews with unlinked claim records. In the Fact Sheet, CMS estimates this change will reduce Part C payments by 1.53 percent.
- RebasingcountyFFSrates for 2027 using 2020–2024 claims data, continuingCMS’spractice of updating benchmarks annually to reflect the most current FFS experience. The Advance Notice also reiterates the statutory framework for calculating benchmarks, including applicable and specified amounts, benchmark caps, and quality bonus payments.
- Updatingthe CMS Hierarchical Condition Category (CMS-HCC) and Prescription Drug Hierarchical Condition Category (RxHCC) risk adjustment models and associated normalization factors for CY 2027 andcontinuingto apply the statutory MA coding pattern difference adjustment to account for systematic differences in diagnosis coding between MA and FFS.
Quality Bonus Payments, Star Ratings, and Part D Updates
CMS states that contracts with 4 or more Stars receive a 5 percentage-point quality bonus, while new and low-enrollment contracts receive a 3.5percentage-point bonus. The Advance Notice also includes updates related to Part C and Part D Star Ratings measures and methodological refinements.
For Part D, CMS outlines proposed updates to the defined standard benefit parameters for CY 2027, as well as changes to Part D risk adjustment, normalization, premium stabilization, reinsurance, and risk-sharing, with additional policy context provided in the Contract Year 2027 Medicare Advantage and Part D proposed rule.
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The CY 2027 Advance Notice provides early signals on benchmark growth, rebasing, and payment methodology changes that will shape MA and Part D paymentsin2027. Stakeholders should begin evaluating the potential implications for bid development, benefit design, and financial performance as CMS moves towardfinalizingrates in April.
ϱ supports Medicare Advantage and Part D stakeholders with payment impact modeling, scenario analysis, and strategic advisory services related to benchmark rebasing, risk adjustment, Star Ratings, and Part D payment policy to help organizations prepare for the CY 2027 rate announcement.
For details about the finalized payment and policy rules,contact our featured experts, and.

January 28, 2026
CMS Releases 2027 Advance Notice with Medicare Advantage and Part D Rates

Preparing for Change: A Look at Proposed State Fiscal 2027 Budgets
As of January 1, 2026, nine governors had released proposed budgets for state fiscal year (SFY) 2027. With the phase down of federal funding and substantial policy changes approved in the 2025 budget reconciliation act (P.L. 119-21, OBBBA), these proposals offer insights into how governors plan to manage mounting fiscal pressures, navigate new federal mandates, and position their programs for long-term sustainability.
Today, ϱ Information Services (ϱIS) published its first preliminary review of proposed SFY 2027 budget proposals. The initial installment includes budgets from Alaska, Colorado, Florida, Mississippi, New Mexico, South Dakota, Utah, Virginia, and Wyoming, with the latter two proposals covering the fiscal 2026–28 biennium.
ϱIS will release periodic updates as additional governors publish their budget proposals—the same rolling approach we used in 2025 (here and here). Because 15 states enacted 2025–27 biennial budgets last year, ϱIS also might review substantial mid-biennium health-related adjustments or supplemental funding.
The remainder of this article provides a snapshot of several notable themes and emerging trends detailed in the full report.
Implementation of New Federal Requirements
State leaders are preparing budgets for SFY 2027 at a time of heightened fiscal stress and structural uncertainty. Entering 2026, governors are facing reductions in federal funding, particularly in Medicaid and Supplemental Nutrition Assistance Program (SNAP) funding. In addition, they are preparing for new federal requirements that will begin to take effect later this year, including narrower flexibilities for financing and Medicaid community engagement policies and more frequent eligibility redeterminations.
Against this backdrop, governors are using FY 2027 budget proposals to comply with OBBBA’s mandates and to stabilize their safety net programs and realign state operations around stricter fiscal realities.
Medicaid Work Requirements. Virginia’s proposed budget includes funding to implement federal Medicaid community engagement requirements, including a recommendation to add nine new authorized positions in SFY 2027 and 12 more in fiscal year 2028 to meet workload demands. In addition, South Dakota’s governor proposed amending the state’s 2026 budget to secure funding to implement these requirements.
Eligibility and Redetermination. Several governors are proposing investments to support heightened eligibility checks across Medicaid, SNAP, and Temporary Assistance for Needy Families (TANF). For example, Colorado Gov. Jared Polis’s budget proposes $19.1 million to improve the state’s eligibility system for programs such as Medicaid, SNAP, and TANF. Utah’s proposed budget includes a recommended allocation of nearly $16.5 million to the Department of Workforce Services for “H.R. 1 Medicaid Eligibility Administration,” and nearly $10 million for the “H.R. 1 SNAP Administrative Services.”
SNAP Changes. States are backfilling lost federal funding and investing in error reduction and system modernization. New Mexico Gov. Michelle Lujan Grisham’s proposed budget, for example, includes $37 million to replace the decrease in federal funding for SNAP administration ($4 million of which will support 150 new full-time positions), as well as $8.9 million for systems improvements to reduce payment errors in SNAP. South Dakota Gov. Larry Rhoden’s proposed budget includes $5.5 million to offset a reduction in SNAP federal funding.
Strategic Cost Containment
Considering OBBBA implementation and the effects that it will have on their budgets, our first review of governors’ budget proposals signals that states are taking an aggressive posture toward limiting expenditure growth in 2026 and 2027. Initial proposals include targeted reductions, tighter utilization management, and restrictions on benefits.
Since the 2025 legislative session, Colorado has taken multiple steps to prepare for declining federal revenue. For example, Governor Polis’s proposed budget accounts for multiple actions approved through an amended executive order that would reduce spending to brace for OBBBA’s impacts. Examples include:
- Reducing provider rates to 85 percent of the Medicare reimbursement rate
- Establishing limits on Community First Choice services
- Adjustingthehome health nursing and therapy services paymentmethodology
- Introducing cost controls for Medicaid benefit categories that have shown disproportionate growth
- Implementinga$3,000 annual cap on adult Medicaid dental benefitsand a$750 annual cap on dental benefits for individuals in the Cover All Coloradans program
- ChangingtheCover All Coloradans behavioral health program from managed care to fee for service
- Reviewing provider feesin anticipation ofpossible StateDirected Payment approval from the Centers for Medicare & Medicaid Services (CMS)
Former Virginia Gov. Glenn Youngkin’s budget—now inherited by Abilgail Spanberger following her inauguration January 17, 2026—includes multiple cost-containment proposals, such as:
- Anticipated adjustments to capitation rates after a review of Medicaid managed care organizations
- A $2,000 annual limit on adult dental services Medicaid coverage
- Elimination ofbothautomatic rate increases for psychiatric residential treatment facilities and qualifyingaddictionand recovery treatment services providersandautomatic biennial inflation increases formedicalassistanceproviders
- Restrictions onemergencymaternity services to Medicaidenrolleeswhoare ineligiblefor Medicaidbecauseof their citizenship status
- Standardizedhourly limits across home and community-basedserviceswaivers
- Actionsrelated to“ensuring appropriate utilization” of services,such asappliedbehavioralanalysis and crisis services
States are expected to include additional cost-containment tools throughout 2026 and beyond as OBBBA’s fiscal effects become clearer over the coming months and years.
What to Watch
The budget proposals indicate the resources that executive agencies need and preview governors’ policy agendas for the year ahead. Stakeholders should track program reductions and rate changes, eligibility system investments, and shifts in care models.
In addition, some of the announced budget proposals consider federal awards to states under the Rural Health Transformation Program (RHTP). For example, the Alaska Department of Health budget request addresses the state’s RHTP implementation plans, and Wyoming’s budget proposal outlines RHTP priorities. Many states are preparing RFP processes to operationalize their RHTP strategies and make progress on the goals of their initiatives.
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As federal funding uncertainties continue, states and other stakeholders will need to adapt their delivery systems, administrative structures, and financing models throughout OBBBA’s multiyear rollout. ϱ offers expertise, analytics, and strategic advisory services needed to navigate this evolving landscape. For details contact Andrea Maresca and Kathleen Nolan.
The full state of the states and governor budget report is available to ϱIS subscribers. In addition, ϱIS maintains a that incorporates details of each initiative and the first year award.

Outlook 2026: ACA Marketplace Trends–A Conversation with Michael Cohen and Zach Sherman
As the 2026 Affordable Care Act (ACA) Marketplace open enrollment period nears its close—and with enhanced subsidies expiring, rates shifting, and consumer behavior evolving—questions about enrollment stability, affordability, and operational readiness have rapidly moved to the forefront. Andrea Maresca, Senior Principal, at ϱ, caught up with Zach Sherman, Managing Director for Coverage Policy and Program Design at ϱ, and , PhD, who leads much of the federal policy analysis advanced by Wakely, an ϱ company, to unpack what they’re seeing so far.
Q: This year’s open enrollment period has been unusually complex. At the federal level, what stands out most so far?
Michael: The headline is that new enrollment is down sharply, while returning consumers have held steadier than expected. That reflects the reality that the enhanced subsidies are gone, premiums have risen, and consumers are facing higher net costs across nearly every market.
But nuance matters: The real question now is how many of these plan selections will effectuate—meaning consumers pay their first month premium, and how many will stay enrolled the entire year? Average effectuated enrollment throughout the year is what truly determines 2026 risk mix and market stability.
Q: Enrollment appears to vary considerably from state to state. What are you hearing from state partners?
Zach: It’s a tale of two markets. StateBased Exchanges (SBEs) are generally seeing less attrition and, in some cases, even modest increases in plan selections. The reason is simple: Many states are doing a lot of heavy lifting to offset the loss of federal support.
For example, SBEs perform earlier and have more customized outreach. We’ve also seen some states step in and offer state-funded subsidies, which are cushioning the affordability loss in places like New Mexico, Maryland, and California.
While still early, the data suggest that states with heavy investment in awareness and enrollment assistance, operational support, and affordability are weathering the transition better because they have more tools to stabilize the consumer experience.
Q: There’s been a lot of speculation about how consumers are responding to the end of enhanced subsidies. What are the early signs?
Michael: Consumers appear to be buying leaner benefits or different metal tiers to manage premium increases.
Another underrecognized but incredibly important dynamic is that autoreenrolled consumers may not effectuate coverage once they see the final outofpocket premium. That dynamic won’t be fully understood until March, April, and even May.
Q: Idaho is a particularly interesting early case study. What are you learning from the first state to complete enrollment?
Zach: Your Health Idaho’s open enrollment finished on December 15, and while they saw a slight increase in plan selections, state officials are not celebrating as they expect a large wave of cancellations—up to 20,000—due to the expiring subsidies.
That’s the clearest early indication that affordability is the defining issue of 2026. States are preparing for higher-than-usual enrollment attrition in quarters one and two (Q1 and Q2), and they’re thinking hard about customer service capacity as consumers navigate changing net premiums, increased deductibles and out-of-pocket costs, and nonpayment grace periods.
Q: Are there policy levers states can still pull to mitigate affordability challenges going forward?
Zach: We’re seeing states explore options for mitigating affordability gaps and enrollment losses, including through state subsidy programs and increased investment in existing reinsurance programs. SBEs are also leaning on their core competencies—tailored and specific education campaigns and enrollment and plan comparison tools—to help their customers cut through the noise and navigate to the best option within their budget.
These aren’t perfect or quick fixes and most states don’t have the resources necessary to backstop the expiring subsidies, but state leaders increasingly view doing something as necessary to stabilize their markets.
Q: What should health plans, exchanges, and policymakers watch most closely over the next three months?
Michael: Effectuation, effectuation, effectuation. The composition of the effectuated population will define 2026 risk.
Zach: Agree. In addition, future regulatory action on affordability, eligibility and enrollment processes, and program integrity. The federal government is expected to issue its annual payment notice, the proposed 2027 Notice of Benefits and Payment Parameters, in the near future.
You can find more insights on the initial enrollment patterns to date in this ϱ-Wakely paper, and register for the 2027 ACA Considerations: Proposed NBPP and Other Key Changes and Trends.

January 21, 2026
Outlook 2026: ACA Marketplace Trends–A Conversation with Michael Cohen and Zach Sherman