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红领巾瓜报 Insights: Your source for healthcare news, ideas and analysis.

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.

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Blog

Forty Years Supporting Medicaid at 红领巾瓜报

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This month鈥檚 Vital Viewpoints podcast features a special conversation with Jay Rosen, founder, president, and chairman of 红领巾瓜报 (红领巾瓜报), as he reflects on the evolution of Medicaid and the 40th anniversary of 红领巾瓜报鈥檚 founding. From his early days shaping Michigan鈥檚 Medicaid program in Michigan’s Office of Health and Medical Affairs, to building a national firm dedicated to public sector healthcare, Jay鈥檚 story is one of purpose, persistence, and visionary leadership. Over four decades, Jay has guided 红领巾瓜报鈥檚 strategic vision, growth, client service, and innovation in publicly funded healthcare.

Jay began his career at a time when Medicaid was still finding its footing. In the 1970s and early 1980s, states were grappling with how to operationalize a new federal promise鈥攈ealthcare for low-income and aging Americans. Jay saw firsthand the complexity and urgency of that challenge. But he also saw opportunity: to build something better, smarter, and more accountable. That vision led to a fateful meeting at a Big Boy diner in East Lansing, Michigan, where Jay, Paul Allen (Michigan鈥檚 then Medicaid director), Elliot Wicks, and Jay Endsley laid the groundwork for what would become 红领巾瓜报 on June 13, 1985, the date 红领巾瓜报 was founded.

The 1980s saw extreme economic distress in the U.S., with healthcare costs rising by 1,520% annually. Pressure on the federal government to reduce financial support for public sector health programs meant state governments had to lead the way. Managed care emerged as a novel idea, using risk-bearing intermediaries between the state as a payer and providers/consumers. Michigan was an early adopter of managed care.

Over the next four decades, managed care programs evolved to bring more accountability in Medicaid, transforming the state鈥檚 role from administrator to regulator. The state agency could focus on using its levers to improve performance of public programs. Reporting requirements, data-driven decision making, quality measurement and other innovative tools were introduced.

鈥淥ne-third of the country is on Medicaid, covering 90 million people, including the most expensive, vulnerable populations. Medicaid operates well despite financial challenges, addressing significant societal obligations,鈥 says Rosen.

Now, as we celebrate the 60th anniversary of Medicaid in July, the program faces new operational and financial pressures, but also new tools — like AI and digital health technologies to meet the moment. Innovation in Medicaid isn鈥檛 optional, it鈥檚 essential. 聽红领巾瓜报 experts work with states and other organizations to harness these tools and stay current with these new initiatives.

Hear more from Jay in this month鈥檚 podcast episode, 鈥Medicaid At (Another) Crossroads: The Future of Public Healthcare Coverage鈥.  And as you look ahead to the future of Medicaid, trust 红领巾瓜报 to be your partner for the next 40 years to come. #红领巾瓜报knowsMedicaid

Blog

红领巾瓜报IS Report Examines Medicaid Financial Accountability Policies and Emerging Strategies

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This week, 红领巾瓜报 Information Services (红领巾瓜报IS) released a new report that provides a detailed, state-by-state analysis of how Medicaid managed care programs are implementing and enforcing medical loss ratio (MLR) requirements. The comprehensive report, Medicaid Financial Accountability and Risk Sharing Arrangement Report, looks at 43 states and the District of Columbia, drawing from the most recent publicly available rate certifications and model contracts.

The report鈥攁vailable exclusively to 红领巾瓜报IS subscribers鈥 supports policy analysts, actuaries, and other interested Medicaid stakeholders with comparative analysis and identification of emerging trends, outliers, and best practices in managed care oversight.

Key Highlights in the 2025 Report

The 红领巾瓜报IS team examined rate certifications and model contracts, primarily covering rate periods ending in or extending through 2025. The report also reflects recent federal policy changes, including the  requiring the inclusion of state-directed payments in MLR calculations鈥攁n update that is already influencing how states structure their payment, reporting, and oversight processes.

Each state profile outlines key elements of the following:

  • MLR thresholds and remittance obligations
  • Risk corridors and reinsurance strategies
  • Other risk mitigation strategies, including high-cost drug pools and retroactive eligibility adjustments

Key findings include:

  • Standardization is at 85 percent: Most states with risk-based programs (22) enforce the federal minimum MLR of 85 percent.
  • Stricter Thresholds: 11 states have adopted thresholds above 85 percent, with some reaching as high as 91.3 percent (Mississippi).
  • Most states require managed care organizations to remit funds if they fall below the MLR threshold. Enforcement varies, however, with strict enforcement in states like Georgia, Indiana, and Iowa, which require 100 percent of the shortfall to be returned, and more flexible policies in other states.
  • The analysis finds states are modifying certain traditional policies and tools to strengthen financial accountability mechanisms and evolve policies to address the changing federal policy landscape. For example, in lieu of remittances, Oregon and Tennessee allow plans to reinvest funds in the community.

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As states continue to refine their approaches to financial accountability and program integrity and design innovative approaches to address enrollee healthcare needs, the 红领巾瓜报IS report offers a timely and actionable reference point.

This report is just one component of the broader 红领巾瓜报IS subscription platform, which offers exclusive access to:

  • Searchable files that enable comparative analysis of key state program information and data
  • Timely updates on Medicaid policy developments
  • Downloadable state-by-state and industry files

For health plans, state agencies, provider organizations, partners, and advocacy groups, subscribing to 红领巾瓜报IS means staying ahead of regulatory changes, identifying emerging trends, and making informed decisions about strategy, compliance, and program design. For more information about the new report, contact featured 红领巾瓜报IS team member below.

Blog

Disaggregating Managed Care Payments: New Insights into Medicaid Spending

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As states and stakeholders seek greater transparency and accountability in Medicaid, a new analysis from 红领巾瓜报 (红领巾瓜报), offers a fresh perspective on how dollars flow through the system. Drawing on publicly available data from the Transformed Medicaid Statistical Information System (T-MSIS), 红领巾瓜报 disaggregated funding dispersed to Medicaid managed care organizations to discern spending for specific categorically eligible populations. The findings significantly enhance policy discussions and can facilitate development of pragmatic and specific care management interventions that support quality patient care.

For policymakers, regulators, and other stakeholders, this level of disaggregation provides a clearer view of how public dollars are used鈥攁nd where there may be opportunities to improve performance or reinvest savings. It also supports more informed rate development and contract negotiations, particularly as states pursue value-based purchasing and other reforms. As Medicaid continues to evolve, especially in the context of budget pressures and changes in enrollment and risk profiles of enrollees, understanding the financial picture of managed care programs is essential to ensuring sustainability.

红领巾瓜报鈥檚 team of experts鈥攊ncluding actuaries, former Medicaid directors, and data analysts鈥攈as deep experience working with T-MSIS data and advising states, plans, and providers on Medicaid program analysis, evaluation, and strategy. For more information about working with T-MSIS data and the insights it can provide, contact聽our experts below.

Blog

Medicaid Expansion: Data-Driven Insights into Healthcare Needs

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As the US Senate debates H.R. 1鈥攁 sweeping legislative package that the House passed on May 22, 2025, which would impose nationwide Medicaid work and community engagement requirements by the end of 2026鈥 红领巾瓜报鈥 (红领巾瓜报鈥檚) latest analysis offers insights into the potential impact of these changes. Drawing on Transformed Medicaid Statistical Information System (T-MSIS) data, 红领巾瓜报 experts examine the health and demographic profiles of the approximately 16 million individuals who comprise the Medicaid expansion population.

This 10-slide presentation of findings underscores the high prevalence of chronic and behavioral health conditions among these individuals, raising important questions about how new eligibility requirements could affect access to care and health outcomes. Notably, the presentation contextualizes health needs with Medicaid spending patterns, comparing the Medicaid expansion group with other eligibility categories, such as dual eligibles and children. We explore how the proposals of the nine state 1115 demonstration applications could affect the work requirements policy and implementation landscape. It also breaks down pharmacy spending by therapeutic class, spotlighting common conditions like opioid use disorder.

These insights are especially valuable for Medicaid managed care organizations, providers, and other stakeholders that will play a key role in designing work requirement initiatives and operationalizing any new requirements. Our May 22, 2025, article鈥Building State Capacities for Medicaid Work and Community Engagement Requirements鈥攄elves into the issues that are central to such discussions.

With deep expertise in Medicaid policy, demonstration design, and advanced analytics, 红领巾瓜报 is uniquely positioned to help states, plans, and providers navigate the evolving federal landscape. For more information about 红领巾瓜报鈥檚 T-MSIS capabilities, contact featured experts聽below.

Blog

The Medicaid HRSN Pivot: What鈥檚 Next for States, Plans, and Providers?

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On March 4, 2025, the Centers for Medicare & Medicaid Services (CMS) rescinded the 2023 and 2024 guidance on Health-Related Social Needs (HRSN) Section 1115 demonstrations. This policy shift signals a significant pivot in federal Medicaid priorities under the current administration. While states with approved HRSN demonstrations may continue operating under existing terms, the path forward for pending proposals and future renewals is less certain. 

This article explores key considerations 红领巾瓜报 (红领巾瓜报), experts identified for states that need to realign HRSN activities with other activities to align with the Trump Administration鈥檚 federal policy objectives and priorities for Section 1115 Medicaid and CHIP demonstrations. 

Background on HRSN Initiatives in Section 1115 Demonstrations聽

In November 2023 and December 2024, CMS published guidance on a new Section 1115 demonstration that gave state Medicaid and CHIP agencies the opportunity to address the broad environmental conditions, or social determinants of health (SDOH), that affect people鈥檚 health. This initiative permitted states to address the individual-level adverse social conditions of enrollees that contribute to negative health outcomes. To assist states in their efforts, CMS approved Section 1115 demonstrations that piloted the provision of housing, food, non-medical transportation, and other environmental supports that meet enrollees鈥 HRSNs. 

What does CMS鈥檚 rescission of the HRSN demonstration policy initiative mean for states planning their next steps and priorities for Medicaid and CHIP?聽

First, CMS鈥檚 March 4 rescission has no impact on states with a current, active Section 1115 demonstration that includes HRSN. States with HRSN demonstrations can maintain their approved programs until the scheduled expiration date; however, requests to amend any aspect of the program before it expires could subject the state to renegotiation of HRSN components that align with the new federal direction. 

Second, states with pending HRSN Section 1115 demonstration proposals should proactively consider new coverage approaches to authorize services that address an individual鈥檚 SDOH. Pending proposals developed using the now rescinded guidance may require substantial changes to gain approval. States should also prepare for additional public comment periods if revisions significantly alter the original design. 

Looking ahead, CMS is not expected to renew demonstration components that no longer align with current federal objectives. This projection pertains to any demonstration component, not just the rescinded HRSN guidance. States should start planning now for how they will sustain successful HRSN-related outcomes through alternative coverage pathways. 

Strategic HRSN Pivot Considerations聽

While the HRSN guidance has been rescinded, CMS has not withdrawn the 2021 State Health Official Letter  (SHO# 21-001), published during the first Trump Administration. This leaves room for states to pivot HRSN initiatives into other federal authorities, such as: 

  • State Plan Amendments and Waivers. These approaches include state plan options, 1915 waiver options, CHIP Health Services Initiatives, as well as certain special program authorities like Program of All-Inclusive Care for the Elderly or Money Follows the Person. 
  • Behavioral Health Integration: States may expand SDOH supports for individuals with substance use disorder, serious mental illness, or serious emotional disturbance, leveraging still-active guidance from first Trump Administration, Letter to State Medicaid Directors (SMD # 17-003) and  (SMD # 18-011). By expanding activities focused on improving addiction or behavioral health treatment for Medicaid or CHIP beneficiaries, states could explore novel approaches to offering SDOH services. 
  • Childhood Chronic Disease Prevention: States could consider aligning SDOH activities with the Make America Healthy Again initiative of the current administration by focusing on environmental factors that adversely affect an enrollee鈥檚 health, such as poor nutrition, chronic stress, overexposure to synthetic chemicals, and mental health challenges. 
  • Justice-Involved Populations: States could explore  and SDOH supports for individuals transitioning from carceral settings to the community, including compliance with new Medicaid requirements for incarcerated youth under the Consolidated Appropriations Act of 2023. 
  • School-Based Health Services. States could explore SDOH activities as part of new approaches to address gaps in the provision of school-based health services to Medicaid and CHIP eligible children. CMS and the US Department of Education launched a joint effort to expand school-based health services by establishing the  to help states increase healthcare access to children enrolled in Medicaid and CHIP. States could explore SDOH initiatives that expand the capacity of school-based entities that provide assistance under Medicaid or CHIP. 

Looking Ahead聽

As states recalibrate their Medicaid and CHIP strategies, understanding how they can align with evolving federal priorities is critical for all stakeholders. Notably, Medicaid stakeholders, including managed care organizations, hospitals and health systems, and providers, also have several opportunities, including: 

  • Inform State Strategy: Plans and providers can share data and outcomes from HRSN interventions to help states assess the value of these services and whether they should continue under alternative authorities. 
  • Shape New Demonstration Designs: As states pivot to align with new federal priorities, plans and providers can offer practical insights into how SDOH interventions could be integrated into behavioral health, reentry, school-based services, and chronic disease prevention efforts. 
  • Strengthen Community Partnerships: Continued collaboration with community-based organizations will be essential to maintain service delivery and demonstrate impact in new policy contexts. 

Connect With Us聽

红领巾瓜报鈥檚 team鈥攊ncluding former CMS Section 1115 leaders and other colleagues steeped in Medicaid and CHIP policies and operations鈥攐ffers unique expertise in designing demonstrations that reflect current federal policy priorities and maximize state outcomes in alignment with program objectives that CMS will support. 

For questions about these developments and your organization鈥檚 plan to adapt to new federal Medicaid policy priorities, contact our featured experts below. Connect with our experts and other leaders experienced in new pathways for covering effective services at the , October 14-16, 2025, in New Orleans, LA. 

Brief & Report

Medicaid Expansion: Data-Driven Insights into Healthcare Needs and State 1115 Implementation Trends

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This 10-slide presentation, Medicaid Expansion: Data-Driven Insights into Healthcare Needs, offers a focused analysis of the Medicaid Expansion population鈥攏on-disabled adults ages 19鈥64 with incomes up to 138% of the Federal Poverty Level鈥攁cross more than 40 states. Using recent T-MSIS data, the deck highlights the high prevalence of chronic and behavioral health conditions within this group, while also detailing demographic trends among the approximately 16 million enrollees.

Developed by Matt Powers, Shreyas Ramani, Loren Anthes, and Lora Saunders, the presentation contextualizes health needs with Medicaid spending patterns, comparing the Expansion group to other eligibility categories, such as dual eligibles and children. It also breaks down pharmacy spending by therapeutic class, spotlighting common conditions like opioid use disorder. In light of recent federal legislative proposals such as H.R. 1, the deck explores how states are beginning to navigate policy changes through 1115 waiver activity鈥攑articularly around medically frail and good cause exemptions鈥攐ffering early insight into likely implementation strategies.

Webinar

Webinar Replay – Ask the Experts: Medicaid Town Hall

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This webinar was held June 30, 2025.

Watch our Medicaid Town Hall hosted by 红领巾瓜报. Our experts answered your questions live on a wide range of timely and critical topics, including:

  • Key policies and insights about the ongoing 2025 federal budget reconciliation negotiations, including changes to Medicaid eligibility policies, financing, and cost-sharing rules.
  • New executive branch priorities to address program integrity and agency regulations and guidance reshaping provider tax rules and state-directed payment arrangements.
  • The evolving landscape of Medicaid Section 1115 demonstrations, including updated federal monitoring approaches and new state initiatives.
  • Medicaid managed care trends, payment innovation, and emerging strategies to address whole-person care focused on maternal health and behavioral health needs.
Blog

Medicaid Redetermination Ripple Effects in the Individual Market

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As Congress intensifies negotiations over budget reconciliation, including potential changes to Medicaid financing and Affordable Care Act (ACA) subsidies, new data from Wakely Consulting Group, an 红领巾瓜报 (红领巾瓜报) company, sheds light on how the effects of the Medicaid redetermination process continued to unfold well into 2024. Appendix A of the May 2025 white paper , provides a full-year view of enrollment and morbidity trends, showing that the influx of former Medicaid enrollees had some negative effects on risk scores. In fact, relative risk increased across all market types鈥攕tate-based exchanges (SBEs), in federally facilitated exchange (FFE) Medicaid expansion states, and FFEs in non-expansion states鈥攄espite substantial enrollment growth.

Data presented in Wakely鈥檚  and their experts鈥 findings challenge the conventional assumption that higher enrollment dilutes risk and suggest that many new enrollees may have had unmet health needs or delayed care. The data also show that states with the highest enrollment growth did not necessarily experience the greatest morbidity shifts. This decoupling of enrollment and morbidity complicates forecasting for insurers and policymakers alike, especially as Congress debates Medicaid funding and ACA subsidy structures in the ongoing budget reconciliation process.

What to Watch

As federal lawmakers consider reforms that could alter Medicaid eligibility, subsidies, and risk adjustment mechanics, these findings underscore the importance of monitoring not just how many people enroll, but who they are and the type of care they need. The individual market鈥檚 evolving risk profile will have direct implications for premium setting, subsidy design, and the financial stability of plans that serve this population.

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Wakely is experienced in all facets of the healthcare industry鈥攆rom carriers to providers to government agencies. Wakely鈥檚 actuarial experts and policy analysts continually monitor and analyze potential changes to inform clients鈥 strategies and propel their success.

For more questions about the analysis contact our experts below.

Blog

Medicaid Managed Care Enrollment Update 鈥 Q1 2025

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In this week鈥檚 In Focus section, 红领巾瓜报 Information Services (红领巾瓜报IS) draws on its database of monthly enrollment in Medicaid managed care programs to provide the latest quarterly analysis of Medicaid managed care enrollment, offering a snapshot of developments across 28 states. [1] The data and insights are particularly timely as stakeholders, including states, Medicaid managed care organizations (MCOs), hospitals and health systems, and providers, continue to plan for multiple possible federal policy changes and the operational realities that will follow.

红领巾瓜报IS also compiles a more detailed quarterly Medicaid managed care enrollment report representing nearly 300 health plans in 41 states. The report provides by plan enrollment plus corporate ownership, program inclusion, and for-profit versus not-for-profit status, with breakout tabs for publicly traded plans. Table 1 shows a sampling of plans and their national market share of Medicaid managed care beneficiaries based on a total of 66 million enrollees. These data should be viewed as a broader representation of enrollment trends rather than as a comprehensive comparison.

Key Insights from Q1 2025 Data

The 28 states included in our review have released monthly Medicaid managed care enrollment data via a public website or in response to a public records request from 红领巾瓜报 (红领巾瓜报). This report reflects the most recent data posted or obtained.  红领巾瓜报 has made the following observations related to the enrollment data:

  • Year-over-year growth. As of March 2025, across the 28 states reviewed, Medicaid managed care enrollment declined by 2.5 million members year-over-year, a 3.9 percent drop as of March 2025 (see Figure 1). This marks a continuation of the downward trend reported in late 2024, though with notable variation across states.

Figure 1. Year-over-Year Growth in Medicaid Managed Care States, 2020鈭24, March 2025

  • Localized growth amid broader declines. While most states experienced enrollment reductions, Indiana and North Carolina bucked the trend with measurable gains, suggesting the influence of state-specific policy shifts or demographic factors. Oregon and Texas also saw modest growth.
  • Sharpest contractions. Illinois, Maryland, and South Carolina, reported double-digit percentage drops, underscoring the uneven impact of redeterminations and eligibility changes.
  • Difference among expansion and non-expansion states. Among the 21 states included in our analysis that expanded Medicaid, enrollment fell by 1.8 million (-3.6%) to 48.6 million. In contrast, the seven non-expansion states saw a steeper proportional decline (-5.4%), to a total of 12.2 million enrollees.

Table 1. Monthly MCO Enrollment by State, January 2025 through March 2025

Note: In Table 1 above and the state tables that follow, 鈥+/- m/m鈥 refers to the enrollment change from the previous month, and 鈥% y/y鈥 refers to the percentage change in enrollment from the same month in the previous year.

It is important to note the limitations of the data presented. First, states report the data at the varying times during the month. Some of these figures reflect beginning of the month totals, whereas others reflect an end of the month snapshot. Second, in some instances, the data are comprehensive in that they cover all state-sponsored health programs that offer managed care options; in other cases, the data reflect only a subset of the broader managed Medicaid population. This limitation complicates comparison of the data described above with figures reported by publicly traded Medicaid MCOs. Hence, the data in Table 1 should be viewed as a sampling of enrollment trends across these states rather than a comprehensive comparison, which cannot be established solely based on publicly available monthly enrollment data.

Market Share and Plan Dynamics

Using our data repository from 300 health plans across 41 states, 红领巾瓜报IS鈥檚 report addresses corporate ownership, program participation, and tax status. As of March 2025, Centene continues to lead with 17.7 percent of the national Medicaid managed care market, followed by Elevance (10.8%), United (8.8%), and Molina (6.3%), as Table 2 shows.

Table 2. National Medicaid Managed Care Market Share by Number of Beneficiaries for a Sample of Publicly Traded Plans, March 2025

What to Watch

The policy backdrop remains fluid. The US House of Representatives鈥 passage of the One Big Beautiful Bill Act introduces sweeping changes to Medicaid financing, including proposed cuts of up to $715 billion. Additional federal proposals, such as mandatory work requirements, could further reshape enrollment patterns.

Stakeholders should prepare for:

  • Implementation of work/community engagement mandates for certain adult populations
  • Potential redesign of Affordable Care Act expansion programs
  • Retraction of federal regulations focused on streamlining of eligibility and redetermination processes to improve accuracy and efficiency

Connect with Us

红领巾瓜报 is home to experts who know the Medicaid managed care landscape at the federal and state levels. As the Medicaid landscape continues to evolve, 红领巾瓜报IS equips stakeholders with timely, actionable intelligence. Our subscription service includes enrollment data, financials, waiver tracking, and a robust library of public documents.

For more information about the 红领巾瓜报IS subscription, contact our experts below.

[1] Arizona, California, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, Washington, West Virginia, Wisconsin.

Podcasts

Medicaid At (Another) Crossroads: The Future of Public Healthcare Coverage

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As Medicaid faces another set of policy shifts, this episode provides a look-back on the many twists and turns Medicaid has faced throughout the years. Jay Rosen, president and chairman of 红领巾瓜报, reflects on his work with states and health plans over the past four decades in their efforts to deliver services to vulnerable populations amidst shifting federal and state priorities, innovative delivery and payment models, and increased private sector involvement. With a sharp focus on policy, equity, and system transformation, Jay offers strategic insights for leaders across healthcare, government, and investment sectors.

Brief & Report

Disaggregating Managed Care Payments Provides Opportunities for New Insights into Medicaid Spending for Critical Populations

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红领巾瓜报 focused this paper on how states disperse Medicaid funds to certain subpopulations within the program鈥檚 categorical eligibility infrastructure. A previous companion paper centered on increasing our understanding of Medicaid managed care spending by provider, offering more detail on the relative order of magnitude of the amounts spent on inpatient and outpatient hospital care, professional services, long-term care, pharmacy, and other health services.

As the latest national Medicaid managed care enrollment data show 75% of Medicaid beneficiaries were enrolled in comprehensive managed care organizations (MCOs), these two foundational papers illustrate the importance of developing a sound methodology to reliably estimate costs associated with MCOS. These papers, which are the first to present findings related to the development of the MCO methodologies, help lay the foundation for further work that will enable us to answer relevant questions, including:

  • How much do we spend on Medicaid patients with chronic conditions like asthma, diabetes, and hypertension?
  • How much do we spend on Medicaid patients receiving long-term services and supports (LTSS) and what is the unmet need?
  • How is Medicaid funding spent on childbirth and a child鈥檚 first year of life?
  • What are the opportunities to be more efficient and effective with Medicaid resources?
Blog

CSR Funding, Budget Debates, and the Future of Marketplace Affordability

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In May 2025, the US House of Representatives passed a budget bill that includes funding for cost-sharing reduction (CSR) payments, marking a potential end to the 鈥渟ilver loading鈥 practice that has shaped pricing in the Affordable Care Act (ACA) Marketplace pricing since 2017. The US Senate is now considering this legislation as part of a broader budget reconciliation package that includes major Medicaid reforms, such as new work requirements and changes to eligibility and financing rules.

This evolving policy landscape has significant implications for states, payers, providers, and consumers. Wakely, an 红领巾瓜报 Company, recently published , which outlines how reinstating CSR payments could reshape ACA marketplace plan pricing, enrollment patterns, and federal subsidy flows. It also highlights the operational and financial risks stakeholders must prepare for in 2026.

Broad Loading and Silver Loading

Because CSR loading increases premium costs on silver plans that determine subsidies, they also increase federal payments for premium tax credit (PTC) subsidies. Guidance from the US Department of Health and Human Services on silver plan pricing has evolved over time. Three types of CSR loading are occurring in ACA markets, specifically:

  • Broad loading: Increasing premiums for all metal level qualified health plans (QHPs) in the individual market to collect enough revenue to offset the CSR costs of the silver plan variants enrollees
  • Two means of silver loading:
    • Increasing premiums for only silver QHPs in the individual market to collect enough revenue to offset the CSR costs of the silver plan variant enrollees
    • Raising premiums, functionally, for only on-exchange silver QHPs

As discussed in the Wakely paper, the impact of silver loading is that the federal government is likely paying out more in additional PTC subsidies than would be paid if CSR payments were fully funded. On Friday, May 2, 2025, the Centers for Medicare & Medicaid Services (CMS) released guidance related to silver loading and CSR payments for 2026 rate filings. This action was urgently needed, especially for states with May filing deadlines.

What鈥檚 at Stake

If Congress does appropriate funding for CSR payments, some issuers will be reimbursed for the difference in cost sharing between standard and CSR-enhanced silver plans. Issuers that cover nonemergency pregnancy termination services, would be ineligible for CSR payments; however, as the Wakely paper indicates, these payments would not cover the additional utilization driven by richer benefits. For example, it is anticipated that a member in a 94 percent actuarial value CSR plan will use more services (i.e., four primary care visits versus three in a standard plan), but reimbursement would only reflect the cost-sharing difference鈥攏ot the increased volume of care.

States like Georgia and New Mexico, which mandate silver loading, could see significant shifts in premium relativities and enrollment behavior. Wakely鈥檚 modeling suggests that changes in CSR policy鈥攅specially if paired with the expiration of enhanced premium subsidies at the end of 2025鈥攃ould lead to higher net premiums, reduced enrollment, and a deterioration in risk pool morbidity.

What to Watch

The Senate鈥檚 deliberations will determine whether CSR funding is restored and could have significant implications on whether enhanced premium subsidies are extended beyond 2025. These decisions will directly affect the following:

  • 2026 rate filings and benefit designs
  • Marketplace affordability and enrollment stability
  • State reinsurance funding and 1332 waiver dynamics
  • Consumer costs and plan switching behavior

Wakely鈥檚 analysis also cautions that if CSR funding is restored without accounting for induced utilization, issuers may still need to price for higher service use鈥攑otentially leading to premium volatility. In addition, if broad loading is mandated instead of silver loading, it could raise premiums across all metal tiers and reduce the value of premium tax credits for many enrollees.

Key Considerations for Stakeholders

  • States聽should assess how CSR policy changes affect reinsurance programs, waiver funding, and Medicaid redeterminations.
  • Payers聽must prepare for multiple pricing scenarios and evaluate how changes in subsidy structures influence enrollment and risk adjustment, 1332 reinsurance programs, and overall market risk.
  • Providers聽should anticipate shifts in patient mix and utilization (i.e., more uncompensated care with more uninsured patients).
  • Advocates聽need to monitor how policy changes affect access and affordability for low-income and underserved populations.

These developments also create more opportunities for movement between Medicaid, Marketplace, and uninsured populations, underscoring renewed opportunity for integrated eligibility systems and coordinated outreach.

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红领巾瓜报 (红领巾瓜报), experts are actively advising stakeholders on how to navigate these complex changes. Whether you鈥檙e a state policymaker, health plan executive, provider leader, or advocate, we can help you assess the impact and plan strategically.

These issues will also be explored in depth at the聽红领巾瓜报 Conference in October 2025. To discuss how these developments will affect your organization, contact our featured expert below.

Ready to talk?