Weekly Roundup -
May 27, 2026
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Unmatched Healthcare Insights from 红领巾瓜报,
Leavitt Partners & Wakely.
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Achieving financial resilience in a time of turbulence
READ SPOTLIGHTSupporting Medicaid Dental Benefit Administrators: Oral health and dental care are vital for the health of communities听
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Trending: In Focus
Connecting the Dots: Key Trends, Plan Shifts, and 2027 NBPP Changes Affecting ACA Marketplace Enrollment
Explore听how 2026 ACA Marketplace enrollment shifts, plan selection trends, and the 2027 NBPP changes are听impacting听affordability, market stability, and state strategies.听
Recent听红领巾瓜报 (红领巾瓜报)听webinars听and听reports discussed that Affordable Care Act (ACA) Marketplace enrollment trends are evolving听rapidly and the takeaways go beyond total enrollment numbers. In addition in May, the Centers for Medicare and Medicaid Services (CMS) finalized the 2027 Notice of Benefit and Payment Parameters (NBPP), introducing new flexibility for plans and states alongside stronger program integrity requirements.听
To understand how these changes are reshaping the ACA Marketplace,听听Andrea Maresca鈥痵poke with鈥�Zach Sherman, Managing Director for Coverage Policy and Program Design听at 红领巾瓜报 as well as听, PhD, Principal鈥痑t Wakely,听and听, Principal at Leavitt Partners, both 红领巾瓜报 companies.
Q: The recent Wakely听analysis has been central to understanding听飞丑补迟鈥檚听happening with ACA enrollment. What should people be paying听closest听attention to?听
Michael Cohen:听The key takeaway is that ACA Marketplace trends are about much more than the enrollment numbers. The plans consumers choose, how long they maintain coverage over the course of 2026, and the evolving picture of the morbidity and demographics of the enrolled population are all critical factors for understanding the ACA Marketplace.
Our听recent听听found that听only about 86 percent of enrollees paid their first premium听in听2026.听That鈥檚听a strong indicator that affordability pressures are already affecting coverage听stability.听听
Q:听Where听are these enrollment changes听showing up most clearly?听听
Michael Cohen:听One data point that stood out is听the number of new consumers in 2026,听which听was down 13听percent听compared听with听prior years.听听
The听impact听also听shows up in coverage losses and听consumer plan selection.听Some consumers are听dropping coverage听altogether, while others are making tradeoffs to stay covered.听These听consumers are moving to lower-premium products鈥攑articularly听from silver听to听bronze plans鈥攚hich offer less robust coverage and higher out-of-pocket costs.听Both trends matter, especially when thinking about access and financial risk.听
Q:听How are听enrollment shifts听affecting听broader听ACA Marketplace听stability?听
Zach Sherman:听It听varies听by state, but听there are听notable trends. States that听are听using the听Federally Facilitated听Exchange听(FFE)听and expanded Medicaid saw听the听largest听enrollment declines.听听
Notably,听non-expansion听states听on听the听FFE听significantly outperformed听expansion听states.听This was surprising because, with enhanced听subsidies ending, the biggest听net premium hit听consumers would feel is听at the lowest income levels, yet听that鈥檚听where we听saw most enrollment growth.听
Across the individual states, the听enrollment shifts听have real implications for stability. When healthier individuals leave the market鈥攐r shift to less comprehensive coverage鈥攊t can put pressure on premiums and risk pools.听Issuers听are taking this information to听begin to make estimates for their 2027 pricing and听what this means for their听2026 performance.听听
At the same time,听CMS is听introducing new flexibilities听in the final 2027 Notice of Benefit and Payment Parameters.听
Q:听What are the most听important changes听in the 2027 final rule?听
Zach Sherman:听Broadly, the听rule听makes听a clear push toward increased flexibility听for听consumers,听plans,听and state regulators.听
One of the categories of changes is around expanded availability of lower premium plans with higher out-of-pocket costs. For example, catastrophic plans can now be offered for up to 10 years.听
CMS also听removed听certain听requirements for standardized plans and听relaxed听limits on non-standard plan offerings.听That gives issuers more room听for plan design innovation,听but it also means a more complex landscape听and听plan selection听experience听for consumers.听
One of the most notable changes is the introduction of non-network plans as qualified health plans. These plans听don鈥檛听rely on traditional provider networks, which could lower costs听while introducing听new considerations for access and consumer experience.听听
We鈥檙e听seeing a shift toward听allowing听more听tailored听options听and potentially less standardized听marketplace听programs.听It will require a different approach from regulators, and it creates a different type of experience for consumers.听听
Q:听CMS is听intensely focused on addressing fraud,听waste听and abuse.听How听is that听playing out听in the Marketplace program?听
Zach Sherman:听Program integrity is a central theme in the 2027 final听rule,听too. It听includes stronger eligibility verification, increased oversight of brokers and marketing practices, and new safeguards to reduce improper enrollments.听So听while听there鈥檚听more flexibility in plan design,听CMS is pairing听it听with听more scrutiny on how the system听operates.听
Q:听Where do听states听fit in all of this?听
Zach听Sherman:听The听final rule听gives states more authority in key areas, including听oversight of plan听network adequacy听and essential community provider compliance.听We鈥檙e听deep into discussions with states and health plan issuers about the changes听they鈥檙e听interested in听exploring听for听their state.听States will have to decide how to use that flexibility to balance affordability, access, and stability.听
Although听many of the provisions take effect听in听the 2027 plan year,听regulators and plans are receiving this information fairly late in the听cycle听which will make it difficult to听incorporate some of the flexibilities.听We鈥檙e听anticipating听robust discussions to continue听next year and expect to see more variation starting in plan year听2028.听
Differences and Alignment in Federal听础颁础听惭补谤办别迟辫濒补肠别 Policy Discussions听听
Q: Stepping back from the听2027听NBPP,听what should interest-holders know about the evolution of the听broader policy landscape?听
Liz听Wroe:听Members of Congress will need to听see听the 2027听rates听being听filed before听they听consider听taking action.听Even then,听there鈥檚听no听consensus听on several key issues听that prevented听a听bipartisan deal听to bring听back enhanced subsidies听in 2025.听
Instead听everyone has听transitioned to a larger听affordability conversation, and听we鈥檒l听spend this year working听on the听policies with a goal of moving forward听in 2027.听听
There are different approaches to affordability and coverage听that are driven by fundamentally different philosophies on how to structure the market. Some proposals focus on expanding subsidies, reducing cost sharing, and strengthening ACA protections.听Others emphasize consumer-directed models听like defined contributions,听health savings accounts, and expanded use of ICHRAs听[Individual Coverage Health Reimbursement Accounts]听as well as broader access to lower听premium plans.听
There are听also听several areas of bipartisan alignment.听Prior authorization reform is a big one. There鈥檚 broad agreement that the current system creates administrative burden and delays in care.听
We鈥檙e听also seeing听common听interest in听policy approaches to strengthen medical loss ratio听[MLR]听requirements, expand price transparency, and address provider consolidation.听
Even if there is divided government after the November elections,听these are areas where policy action may be more likely.听States, health plans, providers, and other interest holders听will want听to听monitor听these issues now for signals of what may move forward later this year or in the next Congress.听
Stakeholder听Opportunities to Inform Marketplace Programs听
Q: What听should stakeholders be focused on right now?听
Michael Cohen:听For issuers,听it鈥檚听about understanding how these changes affect pricing, enrollment, and risk.听There鈥檚听more uncertainty听in how plans听should听be听priced.听
Zach Sherman:听For states, the focus should be on听strategy. The choices they make now听on plan oversight, market structure, and consumer protections听will shape outcomes for听several years.听Additionally, there were several听proposed听Marketplace听policies听that CMS听did not听finalize听in the 2027 rule鈥擲tate-Based Exchange听Enhanced听Direct听Enrollment Model鈥攖hat听CMS is likely to revisit in future rules, including the 2028 NBPP.听听听
Liz Wroe:听Broadly, stakeholders should recognize that听we鈥檙e听in a transition period. The market is evolving, and policy is still catching up.听
Connecting the Dots: Enrollment, Rules,听Regulators,听and the ACA Marketplace听
For stakeholders across the healthcare landscape, navigating this environment requires both technical听expertise听and strategic insight.听
红领巾瓜报 works across policy, actuarial, and operational domains to help states, health plans, and other stakeholders translate these developments into actionable strategies鈥攚hether that means evaluating market risk, designing programs, or preparing for future policy scenarios.听
To explore these issues in more detail, access听红领巾瓜报鈥檚听webinar听discussions听and briefs, including:听
Federal Policy News
Fueled By Weekly Health Intelligence
New CMS Medicaid Rule Signals Tighter Payment Controls and Expanded Oversight
On May 20, CMS听听the 鈥�. The proposed rule is intended to implement Section 71116 of the FY 2025 budget reconciliation law (Public Law 119-21), which directed CMS to revise the payment limit for certain听state directed听payments (SDPs) to providers within their Medicaid programs. The regulation also proposes new limitations on payments for services not addressed by the reconciliation law, in addition to听establishing听various new reporting requirements related to CMS鈥檚 program integrity focus.听听
The proposed rule would reduce the payment rate limit for certain SDPs for inpatient hospital services, outpatient hospital services, nursing facility services, and qualified practitioner services at an academic medical center to 100 percent of the total published Medicare payment rate for expansion states, or 110 percent of the total published Medicare payment rate for non-expansion states beginning for rating periods on or after July 4, 2025.听
鈥疻hile the scope of the statutorily required changes impact four service areas, CMS has proposed to 鈥渆xtend the payment rate limit under the law to all SDPs for all services in all states, the District of Columbia, and territories for rating periods beginning on or after January 1, 2029,鈥� with limited exceptions for certain services. CMS had signaled its potential intent to expand the scope of services captured by the law in听听released February of this year.听
鈥疭ection 71116 allowed for certain SDPs to be grandfathered such that they would be reduced by 10 percent annually, until the allowable Medicare-related payment limit is reached, beginning January 1, 2028. The February guidance details the criteria for certain SDPs to be considered grandfathered.听
鈥疶he rule is open for public comment until July 21, 2026.听
鈥疶he release of the rule comes as CMS also prepares for the implementation of another major provision of the FY 2025 budget reconciliation law, community engagement requirements in the Medicaid program. June 1, 2026, marks the statutory deadline by which CMS must release an听, which is currently under review at OMB. This rule will significantly听impact听how much flexibility states have in implementing the requirements, including providing key definitions that will听impact听exemptions from the requirements and guidance听regarding听procedures for states to conduct enrollment determinations. As an interim final rule, the rule will be 鈥渇inal鈥� or legally binding but will allow for public comment at the time the rule is听promulgated.听
FDA Moves Forward With Advisory Review of Moderna鈥檚 mRNA-Based Flu Shot
On May 21, FDA听听the Vaccines and Related Biological Products Advisory Committee (VRBPAC) will meet on June 18 to 鈥渄iscuss and make recommendations on the safety and effectiveness鈥� of Moderna鈥檚 mRNA influenza vaccine.听听
鈥疎arlier this year, FDA鈥檚 Vinay Prasad, CBER director at the time,听听to accept Moderna鈥檚 application for review, issuing a refuse-to-file letter.听However, a week later, FDA reversed its decision and accepted the Moderna application for review.听Prasad left the agency in late April.听
鈥疉听 for the VRBPAC meeting is open for public comment until June 17, and all comments received on or before June 12 will be provided to the Committee for review. Additionally, an hour has been allotted for public oral presentations at the VRBPAC meeting on June 18, from 1鈥�2 PM ET. Those interested in conducting presentations are encouraged to submit a brief statement and contact information listed in the VRBPAC meeting听听by 12 pm ET on June 8, 2026.听
HHS Releases National Guidance on Screen Time and Child Wellbeing
On May 20, the HHS Office of the Surgeon General听听a warning titled, 鈥�.鈥� Though there is not currently a Senate-confirmed Surgeon General, the report was issued under the leadership of听, Principal Deputy Assistant Secretary for Health and the Director of National Health Communication for the Office of the Surgeon General, who has been named 鈥渋nterim Surgeon General.鈥� Through Dr. Haridopolos鈥� appointment as interim surgeon general, the Administration can leverage the messaging tool of the Surgeon General鈥檚 office, despite not having a confirmed Surgeon General. A nomination hearing for Dr. Nicole Saphier, the current nominee for Surgeon General, has not been scheduled.听听
鈥疶he听 on screen use details emerging science related to the impacts of screen time on the health and wellbeing of children and adolescents, while the toolkit provides action items for children, their families, schools, and healthcare providers to support prevent potential harms and 鈥渟hift cultural norms鈥� around screentime. The听听also includes policy considerations for school districts to support the development of a school policy related to screen usage, while noting widespread variation across 41 states that have enacted laws related to cell phone use in schools.听
HHS Restructures Civil Rights Office Under New Enforcement and Policy Framework
On May 19, the HHS announced a听听for the Office for Civil Rights (OCR) that created three subject-matter divisions: the Conscious and Religious Freedom Division (CFRD), the Civil Rights Division, and the Health Information Privacy, Data, and Cybersecurity Division. The CFRD was originally created in 2018 under the first Trump Administration to 鈥減rotect the fundamental and unalienable rights of conscious and religious freedom.鈥� In March 2023, then-President Biden combined the CFRD with the Civil Rights Division under a singular 鈥淧olicy Division,鈥� leaving OCR with general听jurisdiction听over the subject. HHS听states听the new organization will work to 鈥渁dvance the protection of conscience rights, address race-based discrimination in a color-blind manner, eradicate antisemitism and anti-Christian bias, and restore biological truth.鈥� Breaches of unsecured PHI will remain under the Enforcement Division鈥檚听jurisdiction. HHS noted that the reorganization will not听result in a reduction of OCR鈥檚听workforce. Further information听regarding听this reorganization will be published next month in a Federal Register notice.
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State Policy News
California Submits Section 1115 CalAIM Renewal Request Seeking Employment Services, HCBS for Medicare Adults
The Centers for Medicare & Medicaid Services鈥�鈥痮n May 27, 2026, that California听submitted听a request to extend its California Advancing and Innovating Medi-Cal (CalAIM) Section 1115 demonstration for five years. Within the amendment, the state is seeking new authority to provide pre-employment and employment sustaining services for certain beneficiaries, as well as authority for the Bridge Care Pilot, which would provide home and community-based services to older adults on Medicare that have significant needs but incomes above Medicaid eligibility limits. It also听seeks听to continue multiple services, including reentry services, substance use disorder services, traditional healthcare practices, and more. The current demonstration is effective through December 31, 2026. Public comments are due June 26, 2026.听
Maine Plans County-Based Approach for Medicaid Re-Entry Waiver
Healthcare Innovation鈥�鈥痮n May 24, 2026, that Maine鈥檚 Medicaid program听MaineCare听is currently negotiating with the Centers for Medicare & Medicaid Services (CMS) on its 1115 Medicaid re-entry waiver and is developing a county-by-county implementation approach听rather a听statewide model. If approved, the waiver would allow Maine to cover certain services for people up to听90 days听before release from jails and prisons, including case management, medications for substance use disorder, and at least听30 days听of medication at release. Maine also plans to include physical and behavioral health consultations for youth and services tied to needs such as HIV and hepatitis C. Maine鈥檚 approach is being informed by visits to all 21 jails and prisons, listening sessions with residents, and input from sheriffs, providers, corrections officials, and community partners. Implementation is expected in late 2027 or early 2028.听
Minnesota Seeks Input on Medical Frailty Definition for Medicaid Work Requirements
The Minnesota Department of Human Services鈥�鈥痮n May 21, 2026, a Request for Information seeking stakeholder feedback on how the state should define 鈥渕edically frail鈥� individuals for purposes of Medicaid work and community engagement requirement exemptions under Public Law 119-21. The proposed approach would use available claims data from the state鈥檚 Medicaid Management Information System, including specified International Classification of Diseases, Tenth Revision diagnosis codes, to听identify听Medicaid expansion adults who may qualify as medically frail without requiring听additional听enrollee documentation where possible. The department is requesting input on clinical criteria, data sources, equity and access considerations, operational consistency, and outreach ahead of the January 1, 2027, effective date. Responses are due June 1, 2026.听
Missouri Releases RHTP Rural Health Hub Anchors RFA
The Missouri Department of Social Services鈥�鈥痮n May 15, 2026, a Request for Applications (RFA) for rural healthcare organizations to serve as Transformation of Rural Community Health Care Hub Anchors under the state鈥檚 Rural Health Transformation Program. Selected Hub Anchors will coordinate regional healthcare ecosystems across听roughly three听to five counties, bringing together hospitals, clinics, pharmacies, emergency medical services, community-based organizations, and other partners to improve care coordination, referral systems, and community-specific health needs. Applications are due June 18, 2026.听
Rhode Island Issues Medicaid EVV Module RFP
The Rhode Island Executive Office of Health and Human Services (EOHHS)鈥�鈥痮n May 25, 2026, a request for proposals (RFP) seeking a qualified vendor to administer the RI Medicaid OASIS electronic visit verification (EVV) Module. The state plans to implement a single statewide EVV solution as it transitions from its legacy Medicaid Management Information System to a modular Medicaid Enterprise System (MES). The EVV vendor will help Rhode Island improve accountability, accuracy, care coordination, and transparency in home and community-based services. The contractor will be a point-of-care verification and must听interface with听other modules via the System Integrator and Operational Data Store. Proposals are due July 14, 2026.听
Private Market News
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ACA Deductibles Reach Record High as Membership Losses Slated to Continue
A fuller picture is听emerging听of how the听expiration听of enhanced subsidies is affecting听听and the millions of Americans who rely on them for coverage.听The average deductible for an Affordable Care Act plan has reached record highs after jumping more than $1,000 between 2025 and 2026. This has resulted in estimates that the marketplace enrollment could fall by听5 million people, or 21.5%, as Americans听fail to听pay their premiums.听
Our Insights
Fueled By Experts Across Our 红领巾瓜报 Companies
红领巾瓜报
Webinar Replay 鈥� ACA Enrollment Declines: Implications and Options for State and Federal Policymakers
Recent and future policy changes are reshaping the ACA market. A recent Wakely report finds that only 86% of ACA enrollees nationwide paid their first premium at the start of the year. Additionally, the 2027 Notice of Benefits and Payment Parameters (NBPP)听was听finalized,听which will have听additional听implications for consumers, issuers, and other stakeholders.听During this听webinar, 红领巾瓜报鈥檚 ACA team had a policy-focused conversation on what these projected changes mean for marketplace dynamics, including impacts to risk pools, premiums, and issuer participation. The session explored emerging federal and state policy responses and offered insight into how today鈥檚 decisions may shape 2027 rates, plan offerings, and long-term market sustainability.
Registration Open: 红领巾瓜报 2026 Conference
Registration is open for 红领巾瓜报鈥檚 annual conference,鈥�US Healthcare 2026: Signals, Signs & Flashing Lights鈥擮ct 5鈥�7鈥痠n鈥疦ew Orleans. Join leaders from payers, providers, and the public sector to cut through the noise and focus on听飞丑补迟鈥檚听working to address financial pressures, performance expectations, and AI and听new technologies.听
SAVE THE DATE: Fall State of Reform Health Policy Conference Dates Announced
State of Reform pulls together practitioners, thought leaders, and policymakers 鈥� each working to improve the healthcare system in their own way 鈥� into a unified conversation in a single place. These conferences are sure to be some of the most diverse statewide gatherings of senior healthcare leaders, and some of the most important events in state healthcare.
Join us for one of our fall events:
- September 3, 2026 – Southern California
- September 16, 2026 – Pennsylvania
- September 30, 2026 – Minnesota
- November 10, 2026 – North Carolina
- November 17, 2026 – Illinois
Wakely
From Premiums to Performance: Managing Risk in Self-Funded Health Plans
This brief is the second in a听Wakely听series outlining the fundamentals of听self funding. It highlights key steps to successfully听establish听and manage a听self funded听health plan, with a focus on funding strategy, risk management, and cost control, and explores alternative funding approaches such as level funding, HRAs, captives, and trusts.
RFP Calendar
RFP Calendar
| Date | State/Program | Event | Beneficiaries |
|---|---|---|---|
| Date: February 2026 - DELAYED | State/Program: Illinois | Event: Awards | Beneficiaries: 2,400,000 |
| Date: June 24, 2026 | State/Program: Wisconsin LTC GSR 3 | Event: Awards | Beneficiaries: 56,000 (all GSR) |
| Date: Summer 2026 | State/Program: Illinois Foster Care | Event: RFP Release | Beneficiaries: 33,000 |
| Date: July 1, 2026 | State/Program: Hawaii Community Care Services | Event: Implementation | Beneficiaries: 5,500 |
| Date: July 28, 2026 | State/Program: Nevada Children's Specialty | Event: Awards | Beneficiaries: NA |
| Date: August 2026 | State/Program: Indiana | Event: RFP Release | Beneficiaries: 1,400,000 |
| Date: January 1, 2027 | State/Program: Illinois | Event: Implementation | Beneficiaries: 2,400,000 |
| Date: January 1, 2027 | State/Program: Nevada CO D-SNP | Event: Implementation | Beneficiaries: 88,000 |
| Date: January 1, 2027 | State/Program: Wisconsin LTC GSR 3 | Event: Implementation | Beneficiaries: 56,000 (all GSR) |
| Date: January 1, 2027 | State/Program: Illinois Tailored Care Management Program | Event: Implementation | Beneficiaries: 22,400 |
| Date: July 1, 2027 | State/Program: Nevada Children's Specialty | Event: Implementation | Beneficiaries: NA |
| Date: January 1, 2028 | State/Program: Wisconsin LTC GSR 4,6 | Event: Implementation | Beneficiaries: 56,000 (all GSR) |
| Date: Fall 2027 | State/Program: Oregon | Event: RFP Release | Beneficiaries: 1,200,000 |
| Date: 2028 | State/Program: North Carolina | Event: RFP Release | Beneficiaries: 2,200,000 |
| Date: 2029 | State/Program: California | Event: RFP Release | Beneficiaries: NA |