Issue #261

Sellers Dorsey Digest

November 6, 2025

Coffee with a Colleague series 2025
NEW BLOG

New Coffee with a Colleague: Child and Family Well-Being and Value-Based Care

As child welfare systems evolve toward value-based and performance-based contracting, it’s essential to understand the roots of value-based care and how quality measurement has shaped healthcare over time. In our latest Coffee with a Colleague conversation, Katie Renner Olse, Managing Director of Child and Family Well-Being, sits down with Karla Richardson, Director of Quality, to unpack the history, evolution, and future of value-based care.

Federal News

MCO Associations Recommend Steps for CMS to Support OBBBA Implementation

On November 3, 2025, the Medicaid Health Plans of America (MHPA) and the Association for Community Affiliated Plans (ACAP) sent a joint letter to Centers for Medicare & Medicaid Services (CMS) Administrator Mehmet Oz outlining key considerations for implementing the One Big Beautiful Bill Act (OBBBA), particularly its community engagement (work) requirements. The groups thanked CMS for its collaboration and asked the agency to clarify that while Managed Care Organizations (MCOs) cannot serve as compliance entities, they should still be able to educate members and connect them with resources. They also urged CMS to maintain flexibility under the Telephone Consumer Protection Act (TCPA) so plans can continue using calls, texts, and emails for outreach. Other priorities include setting clear definitions for medically frail and substance use disorder populations, improving data sharing between Social Security Administration (SSA), CMS, and states, and allowing self-attestations to make compliance easier for seasonal workers. The letter also noted the need for technical assistance and federal matching funds to help states and counties manage new administrative demands, extensions for states making good-faith efforts toward compliance, and quarterly capitation rate reviews to address churn and rate pressures (MHPA, November 3).

Court Orders Emergency Funding to Keep SNAP Benefits Flowing

Two federal judges have ordered the Trump administration to use its $4.65B emergency fund to continue Supplemental Nutrition Assistance Program (SNAP) payments amid a prolonged government shutdown. The fund, however, covers only about half of the $9B needed for November benefits. Judges John McConnell and Indira Talwani ruled that the administration must exhaust available resources before cutting off aid, but USDA officials say they will not tap other accounts, such as the Section 32 Child Nutrition Program, calling it too risky. Patrick Penn, who oversees SNAP at USDA, warned that recalculating reduced benefits will cause significant delays, potentially leaving many households without food assistance for weeks or months. The lapse has become a major symbol of the shutdown, now entering its sixth week. Democratic-led states, cities, and advocacy groups have sued the administration to secure full benefits. Skye Perryman of the Democracy Forward Foundation said her organization is exploring further legal action to ensure families receive the aid Congress authorized. The administration maintains that emergency funds are reserved for natural disasters, not shutdown-related shortfalls (The Hill, November 3).

HRSA Announces Participants of New 340B Pilot Program

Earlier this year, the Trump administration announced the 340B Rebate Model Pilot Program, in which pharmaceutical companies can offer rebates on certain drugs to hospitals that participate in the program. On October 31, the Health Resources and Services Administration (HRSA) announced the eight approved drugmakers for the program: Bristol Myers Squibb, Immunex, Johnson & Johnson, Novo Nordisk, Merck, Pharmacyclics, Boehringer, Janssen Biotech, Janssen Pharmaceuticals, and Astra Zeneca. The drugmakers have their most prescribed drugs, such as Eliquis and Jardiance, available through the rebate pilot program. The manufacturers and the administration aim to address fraud and abuse concerns in the long-running 340B program, which aims to improve the affordability of drugs for low-income providers. Starting January 1, 2026, 340B providers will request rebates on the drugs after they are dispensed to eligible patients, deviating from the current practice in which 340B providers receive a discount at the point of sale for wholesale drugs. The 340B providers will also be subject to increased scrutiny to ensure a dispensed drug’s eligibility for the program. Hospitals are strongly opposed to the new 340 pilot program, arguing that the drugmakers have an incentive to decline otherwise valid rebates as well as placing a larger administrative burden on providers (Healthcare Dive, October 31; HRSA, October 31).

GOP Revives ACA Cost-Sharing Payment Proposal

House Republicans are again considering restoring federal payments to insurers for Affordable Care Act (ACA) cost-sharing reductions (CSRs), which would replace the “silver loading” system created after the Trump administration stopped payments in 2017. The policy could produce significant savings—about $30B over ten years according to the Congressional Research Service, or up to $50B per the Committee for a Responsible Federal Budget—but bipartisan agreement is unlikely. The plan, previously removed from a GOP reconciliation bill, would also block payments to plans covering elective abortions, violating Senate rules. Democrats favor keeping silver loading because it expands subsidies and coverage, while GOP leaders like Steve Scalise continue to push for direct CSR payments (Inside Health Policy, October 31).

PBM Reform Push Continues After Express Scripts Move

Lawmakers from both parties say Cigna’s Express Scripts decision to replace drug rebates with upfront discounts for commercial health plans does not remove the need for congressional action on pharmacy benefit managers (PBMs). Senator Chuck Grassley (R-IA) and Representative Buddy Carter (R-GA) welcomed the change, but said legislation is still needed to make the system more transparent and prevent PBMs from manipulating drug prices. President Trump and top health officials, including HHS Secretary Robert F. Kennedy Jr. and CMS Administrator Dr. Mehmet Oz, also supported Express Scripts’ move. Still, lawmakers pointed out that the company’s plan doesn’t cover Medicare or Medicaid and doesn’t address all the issues Congress is targeting. Bipartisan PBM bills would require more disclosure of drug pricing, limit “spread pricing,” and rein in rebates that reward high-cost drugs. Senators James Lankford (R-OK), Peter Welch (D-VT), and Ron Wyden (D-OR) said recent industry changes show PBMs are responding to pressure from Congress, but they remain skeptical (Modern Healthcare, October 30).

States Told to Review Medicaid Eligibility Under New Federal Immigration Directive

The Trump administration has instructed states to review the immigration status of some Medicaid enrollees, a move federal officials say is aimed at preventing benefits from going to people who are not legally eligible. CMS Administrator Dr. Mehmet Oz said billions in Medicaid funds may have been used for ineligible individuals, but several states disputed those claims, calling the data inaccurate or preliminary. The directive requires states to verify names provided by CMS, adding administrative pressure to Medicaid agencies already managing major policy changes. Advocates and researchers warned that the checks could cause eligible residents to lose coverage if they miss verification deadlines. States emphasized that they already confirm immigration or citizenship status through existing federal databases. The effort expands the administration’s broader immigration enforcement agenda and marks an unprecedented level of federal involvement in Medicaid eligibility reviews (KFF News, November 3).

CMS Confirms 2026 Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) finalized the 2026 Medicare Physician Fee Schedule, introducing payment changes that have drawn mixed reactions across the healthcare community. The rule includes a 2.5% efficiency adjustment for certain procedural services, which CMS says reflects improvements in technology that make some procedures less resource intensive. Time-based, telehealth, and new 2026 codes are excluded. Another provision cuts the indirect practice expense payment for physicians providing services in facilities in  half. CMS said the update better aligns payments with current practice patterns and reallocates funds toward office-based providers. The change is expected to reduce facility-based reimbursement by about 7% and raise office-based payments by roughly 4%. Physician and hospital groups have criticized the new policies, warning they could strain specialists and limit patient access, while organizations such as Medicare Payment Advisory Commission and the Paragon Health Institute support the rebalancing. CMS and HHS Secretary Robert F. Kennedy Jr. said the changes aim to modernize Medicare payments, improve efficiency, and maintain access to high-quality care (Inside Health Policy, October 31).

State News

Delaware Lawmakers to Address Revenue Loss from Federal Tax Changes

Delaware’s General Assembly will meet in a special session on November 13 to address potential revenue losses linked to recent federal corporate tax changes under H.R.1. State officials project a $400M decline in revenue over the next two years, with some provisions taking effect on January 1. Governor Matt Meyer and legislative leaders are considering decoupling the state’s corporate tax code from federal law to limit the impact on state finances. Updated forecasts from the Delaware Economic and Financial Advisory Council indicate reduced revenue for fiscal years 2026 and 2027, which could lower the state’s spending limit and increase reliance on reserve funds. Meyer said the immediate concern is offsetting the shortfall created by federal tax changes, while broader structural budget challenges will be addressed separately (Delaware Public Media, November 1).

Minnesota Taps Optum for $2.3M Medicaid Fraud Review

Minnesota has hired Optum, a subsidiary of UnitedHealth Group, on a $2.3M, one-year contract to help uncover potential Medicaid fraud. Using data analytics and artificial intelligence, Optum will review transactions across 14 service areas while the state temporarily pauses payments in sectors flagged as high risk. Governor Tim Walz said the move builds on his new executive order aimed at strengthening oversight and protecting taxpayer dollars. The review focuses on fee-for-service claims, as state law prohibits for-profit companies like UnitedHealth Group from managing Medicaid plans. State officials recently removed about 800 inactive providers to tighten controls, and advances in digital tracking tools are expected to make future fraud investigations faster and more precise (Health Payer Specialist, October 31).

SPAs and Waivers

There were no new SPA or waiver approvals or submissions this week.

Most Read - October

CMS Workforce Plan Released for Shutdown

HHS released its FY2026 shutdown plan on September 29, detailing that just over 3,300 CMS staff would continue to work if appropriations lapse on October 1. This includes about 50% of all staff who are funded by mandatory spending or other sources. Many activities will continue despite a government shutdown, including administering Medicare and Medicaid, federal marketplace activities like eligibility verification, and fraud, waste, and abuse efforts. The document states that there are enough federal funds to cover the cost of Medicaid through Q1 of FY2026, which ends on December 31, 2025. CMS also plans to retain enough staff to ensure that CHIP payments are sent to states. However, federal oversight of contractors and the regulatory process will cease in a shutdown. Any national or community outreach from CMS would be slowed down or stopped entirely. The White House Office of Budget and Management has indicated that agencies should consider additional reductions in force (RIF) notices for employees to further align the executive branch with President Trump’s priorities. This differs from previous government shutdowns that furloughed government employees without pay but reinstated them once appropriations were made (Inside Health Policy, September 29). Read full issue >

States Have Potential to Add Additional Exemption for Work Requirements

A recent KFF analysis highlighted a key exemption in H.R.1’s new work requirements mandate states may consider as they begin implementation: individuals living in counties with high unemployment rates. The law allows an exemption for Medicaid enrollees who live in counties where unemployment is at least 8.5%, or 1.5 times the national unemployment rate. However, states must choose to apply for this exemption, and the federal government can set a limit on how long a county can be exempted. KFF’s analysis predicts that this exemption could impact millions of Medicaid enrollees, roughly 7% of enrollees who are subject to work requirements. The Supplemental Nutrition Assistance Program offers a similar exemption to its own work requirements. However, 18 states did not offer this option in 2023 (Modern Healthcare, October 3; KFF Health News, September 29; KFF, September 29). Read full issue >

Medicare Telehealth, Hospital at Home Program Impacted by Government Shutdown

The federal government shutdown has triggered the automatic expiration of two temporary but widely adopted Medicare programs effective October 1, 2025. Coverage of telehealth and the Acute Hospital Care at Home program began during the COVID-19 pandemic and enabled remote consultations and hospital-level care at home. In the last year, about 4 million Medicare patients used telehealth services, while 31,000 beneficiaries took advantage of the hospital-at-home program. Because Congressional approval is needed to extend these programs, both are currently unavailable. As a result, hospitals such as Mayo Clinic and OSF Healthcare have had to discharge or transfer patients, sometimes due to overcrowded facilities. The shutdown has also caused confusion among private insurers, with some erroneously halting telehealth coverage for non-Medicare patients, despite no federal directive. In rural areas, where telemedicine often substitutes for in-person care, the impact is especially severe. Bipartisan legislative efforts to preserve these services stalled earlier in 2025. Currently, some Democratic lawmakers are calling for the Department of Health and Human Services to provide additional flexibility and guidance for these programs while the government is shutdown, allowing patients to continue receiving telehealth and hospital-at-home care. Mass General Brigham in Massachusetts is attempting to adapt, reorganizing its plan to utilize alternative home-care models without the Hospital Care at Home program. Other providers reiterated their hope that Congress will soon renew both telehealth visits and the hospital-at-home program (Stateline, October 10; Inside Health Policy, October 9). Read full issue >

Senate Committee to Hold Long-Anticipated Hearing on the 340B Program

On October 23, the Senate Committee on Health, Education, Labor and Pensions will hold a full committee hearing on the 340B program. Representative Bill Cassidy (R-LA) began his investigation into the 340B program in 2023 following several reports indicating that entities may not be appropriately disclosing their revenue. In April 2025, the committee released its investigation findings, including evidence that a few hospitals, FQHCs, contract pharmacies, and drug manufacturers had misused their positions as part of the program, such as failing to use revenue or resources to directly benefit the patients they serve. It is unclear if Representative Bill Cassidy will introduce 340B reform legislation at the meeting as he has previously signaled his interest in introducing a bill to address the misuse of 340B revenue (Inside Health Policy, October 17; Strategic Healthcare, N/A). Read full issue >

CMS Names Dan Brillman as New Medicaid and CHIP Director Amid Policy Shift

The Centers for Medicare & Medicaid Services (CMS) has appointed Dan Brillman, former CEO of the health technology company Unite Us, as Deputy Administrator and Director of the Center for Medicaid and CHIP Services. In this role, Brillman will oversee the implementation of major Medicaid provisions included in H.R.1, including work requirements and more frequent eligibility redeterminations. The selection follows major staffing reductions and restructuring within CMS, and HHS. Caprice Knapp, who had been serving as Acting Director, will become Principal Deputy Director (Fierce Healthcare, October 28). Read full issue >

Sellers Dorsey Updates

Reimagining Child Welfare: The Transformative Role of Technology

The child welfare system is in a state of flux. Caseloads, aging infrastructure, and overlapping data streams combine to strain providers, state and local agencies, and children and families. New and emerging technological solutions present one path forward to easing this burden by reducing redundant data, enhancing communication and coordination, and increasing access to services and care, among other impacts. In our latest blog, Associate Director for Child and Family Well-Being Sasha Rasco, explores current challenges in the field and ways technological solutions can be implemented to address them.

Latest Digests

Sellers Dorsey Digest
Digest Feature | Rural Health Transformation Program Summary

Issue #266

Read More

Sellers Dorsey Digest
New Hire | Stephanie Lee

Issue #265

Read More

Sellers Dorsey Digest
New Hire | Am'Asa Baldwin

Issue #264

Read More

Sellers Dorsey Digest
Digest Feature | Rural Health Transformation Program Summary

Issue #263

Read More