Issue #262

Sellers Dorsey Digest

November 13, 2025

The Risk Ready Hospital
NEW BLOG

The Risk Ready Hospital: Preparing to Take on Risk in an Evolving Healthcare Landscape

In a rapidly changing industry, hospitals are facing new challenges that drive organizational changes, financial shifts, and new approaches to securing long-term growth and vitality. In this new landscape, the prospect of providers taking on downside risk arrangements is becoming increasingly likely. In our latest blog, Sellers Dorsey Managing Director and former hospital CEO Joe Rafferty lays out the importance of understanding and planning for risk arrangements and the strategies that are necessary for success.

Federal News

New CMCS Director Releases CIB on Duplicate Medicaid and CHIP Enrollment

On November 6, 2025, CMS issued an Informational Bulletin reminding states of their obligation to detect and prevent Medicaid and CHIP beneficiaries from concurrently enrolling in multiple states. This marks the first public memo issued by new CMCS Director Dan Brillman. CMS asserts that, in 2024, an average of 1.2 million individuals were concurrently enrolled in more than one state. CMS reminds states of their obligation to take timely action upon notification of changes in beneficiary living circumstance, including their obligation to notify beneficiaries of potential adverse eligibility actions. CMS will provide states a file that lists individuals who were enrolled in Medicaid or CHIP in their state and at least one other state between June and August 2025. Once a state receives the file, it should:

  • Compare the data in the concurrent enrollment file from CMS to current information in the state’s eligibility and enrollment system.
  • Follow the required steps for acting on a change in circumstances for those individuals for whom the state does not have more recent data, including how the state should treat returned mail.
  • Follow federal notice and termination requirements.

CMS notes that continuous eligibility does not apply to individuals who are no longer a resident of the state and provides options for how states may respond if it is unable to locate an individual on the CMS file who is in a continuous eligibility period (CMS, November 6).

CMS Innovation Center Announces GENEROUS Model for Medicaid Prescription Drugs

On November 6, the CMS Innovation Center announced a new model that will begin in January 2026: GENErating cost Reductions for U.S. Medicaid (GENEROUS). Building on the Trump Administration’s efforts to pursue most-favored-nation drug pricing, the GENEROUS model will allow participating states to purchase drugs under the pilot program that are aligned with international prices. In the model, CMS will enter negotiated agreements with participating drug manufacturers to set prices, based on international data, and standardized coverage criteria for their drugs in state Medicaid programs. States and manufacturers will also enter into agreements where states send invoices for supplemental rebates to reach the international price for drugs purchased. CMS will share in the rebates by reducing the federal share of Medicaid provided to the state. The model is not anticipated to impact 340B rebates. The agency is releasing a Request for Applications for drug manufacturers and letters of intent from state Medicaid agencies to get more information on participating in the model (CMS Newsroom, November 6).

All 50 States Apply for $50B Rural Health Transformation Program

The Centers for Medicare & Medicaid Services (CMS) announced that all 50 states have applied for the $50B Rural Health Transformation Program funding, created by H.R.1 to improve healthcare in rural areas. Proposals address issues such as provider shortages, limited access to preventive care, and aging infrastructure. The initiative centers on five areas: prevention and population health, long-term access to care, workforce development, innovative delivery models, and technology expansion. Funding will be distributed in two stages, an equal baseline award for approved states and a second phase based on a merit review of each proposal’s approach and alignment with federal program goals. CMS and states are expected to negotiate over award terms before CMS announces awardees by December 31, 2025, with funds distributed over five years starting in January 2026. States will not have an opportunity to appeal award decisions (HHS, November 5).

HHS and CMS Outline Goals for AI in Healthcare

The Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) are accelerating efforts to integrate AI into healthcare, emphasizing speed and private-sector innovation. CMS launched the Health Technology Ecosystem Initiative in late July to improve interoperability and expand personalized tools and is pursuing efforts to create an app store of vetted digital health solutions and AI chatbots for beneficiaries by leveraging the 60 private companies that signed up for the initiative. The agency is also consolidating provider data into a national directory and adding modern identity security to Medicare.gov. Internally, HHS is deploying AI broadly, including using large language models and recruiting top tech talent from major firms and startups. Speaking at the Future of Health Summit last week, Deputy Secretary of HHS Jim O’Neill stressed that while safety matters, rapid AI adoption is critical to maximize benefits in diagnosis, care coordination, and drug discovery. Under the Trump Administration, CMS aims to make AI tools reimbursable and avoid overregulation that could stifle innovation. Looking ahead, officials envision AI assistants for patients and improved interoperability within four years, with early versions of AI companions expected within a year (Fierce Healthcare, November 7).

GOP Legislators Look to Replace ACA Tax Credits with HSA/FSA

As the expiration of enhanced premium tax credits draws closer, President Trump has begun urging GOP lawmakers to replace the prior system with federally pre-funded flexible spending accounts (FSAs). Some Republican lawmakers, including Senate health committee Chair Bill Cassidy (R-LA) have taken up this charge, arguing that the ACA is better for insurance companies than the consumers that rely on it, and that implementing an FSA approach would “trust Americans to manage their own care.” (Inside Health Policy, November 8).

Senate Reaches Agreement to Reopen Government and Restore Federal Workforce

The 43-day government shutdown ended late Wednesday, November 12, after President Trump signed the bipartisan continuing resolution (CR). The legislation was approved 60-40 in the Senate on November 9, with seven moderate Democrats and one independent aligning with Republicans. The House then passed the Senate’s bipartisan deal 222-209 on Wednesday with the President’s signature shortly following passage. The CR will fund the majority of federal operations through January 30, 2026. It also reverses October layoffs at the Centers for Disease Control and Prevention (CDC), the Substance Abuse and Mental Health Services Administration (SAMHSA), and other agencies. It also guarantees back pay for furloughed employees and blocks any additional layoffs through the end of the year. The package provides full-year funding for the Department of Agriculture, the Food and Drug Administration (FDA), the Department of Veterans Affairs, and congressional operations. It omits new restrictions on the administration’s ability to withhold appropriated funds, a point of concern for some Democrats. As part of the negotiations, Senate Democrats secured a commitment for a December vote on extending Affordable Care Act tax credits, though progressive members remain skeptical without a written guarantee from House leadership. The agreement, arranged by Senate Majority Leader John Thune and a bipartisan group of senators, comes after weeks of stalled talks and growing pressure to reopen closed agencies. The CR will rehire federal employees, restore key public health and safety functions, and bring an end, at least temporarily, to the longest government shutdown in U.S. history (Inside Health Policy, November 10; Politico, November 9; Politico, November 12).

State News

Prospect Looks to File for Bankruptcy Following Pending Sale

Prospect Medical Holdings (Prospect) has been attempting to sell two Rhode Island-based safety net hospitals for three years, and last week sought approval to close the two facilities. Prospect asserts it has been unable to sell the two facilities due to the conditions the state has placed on the sale, as well as the Centurion Foundation’s, a potential buyer’s, failure to raise the necessary funds. The state imposed 40 conditions on the sale, including requiring the seller to make repairs to the hospital facility. Centurion says they are committed to finalizing the deal soon, but Prospect is now looking to instead file for bankruptcy and close the hospitals’ doors by the end of the year. Rhode Island’s attorney general, Peter Neronha, has warned against closure as it would harm vulnerable low-income patients, and has instead proposed that Prospect sell the hospitals to another buyer, as the services these hospitals provide are irreplaceable (Healthcare Dive, November 5).

SPAs and Waivers

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

Sellers Dorsey Updates

Celebrating 60 Years of Medicaid: Providing Care for Individuals with Disabilities

For the last 60 years, the Medicaid program has provided care for at-risk populations across the country. One of the most vulnerable populations supported by Medicaid is individuals living with disabilities. In our final issue brief celebrating the 60th anniversary of Medicaid, Sellers Dorsey experts have broken down the history of Medicaid and disability care, from the program’s enactment to the introduction of home- and community-based services waivers to the Americans with Disabilities Act and the rise of managed care. As the Medicaid program faces funding challenges, aging populations, and workforce shortages, it is important to know where the program has come from so we can see where it is going. This brief provides an important look at how Medicaid continues to shape care for individuals with disabilities.

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.

New Weekly Newsletter: Child and Family Well-Being at a Glance

Stay informed with our new weekly newsletter designed for professionals working to improve child and family well-being. Get curated child welfare news clips plus engaging thought leadership from Sellers Dorsey experts, delivered straight to your inbox same time each week.

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