This week's roundup:
- In Focus: CMS Shakes Up the Innovation Center Model Landscape: What Comes Next?
- Idaho Governor Signs Bill to Transition to Managed Care, Add Work Requirements
- Maine to Submit Section 1115 SUD Demonstration Renewal for Reentry Services, Tribal Health
- Massachusetts Seeks New Vendors as Commonwealth Care Alliance Plans to Cease Operations
- New York Extends CDPAP Enrollment Grace Period
- Senate Finance Committee Advances Dr. Oz Nomination for CMS Administrator
- President Trump Nominates March Bell for HHS Inspector General Position
- More News Here
In Focus
CMS Shakes Up the Innovation Center Model Landscape: What Comes Next?
This week, our In Focus section focuses on a March 12, 2025, announcement from the Centers for Medicare & Medicaid Services (CMS) regarding CMS Innovation Center programs under the new Administration. After reviewing the Innovation Center’s model portfolio, CMS has elected to discontinue four models ahead of their original end dates: Maryland Total Cost of Care (TCOC), Primary Care First (PCF), End-Stage Renal Disease (ESRD) Treatment Choices (ETC), and Making Care Primary (MCP). The agency also intends to downsize the Integrated Care for Kids Model (InCK) and forgo the launch of two drug pricing initiatives. According to the announcement, CMS appears to be moving forward with other Innovation Center models, but signaled upcoming modifications to models to align with Administration priorities as well as new model announcements.
The following is a discussion of CMS’s announcement and what it may signal about the agency’s commitment to value-based care, key takeaways regarding the four terminated models, and how stakeholders should be preparing to engage with the Innovation Center on current or future models while we await additional details.
CMS’s Strategic Decision
As part of CMS’s recent announcement about the model terminations, the agency reaffirmed its support for testing models that reduce program spending while maintaining or improving quality of care. Furthermore, the Innovation Center “plans to announce a new strategy based on guiding principles to make Americans healthier by preventing disease through evidence-based practices, empowering people with information to make better decisions, and driving choice and competition.” These statements should be seen as a commitment to using the Innovation Center to test new approaches to delivering care but with an expectation that the models will need to demonstrate significant cost and quality improvements as outlined in its statutory authority. According to CMS, the cancellation of these models is projected to save an estimated $750 million.
Because CMS said it may modify additional models in the future, it is reasonable to expect those changes will focus on achieving a higher level of savings or to see savings earlier in the demonstration, as well as aligning model design with the priorities of this Administration. The potential modifications could have an impact on the number of model participants, length of model testing, and financial arrangements, especially with regard to risk and quality improvement approaches.
Models Ending
CMS Innovation Center models are time-limited pilots meant to help the agency test which types of interventions lead to cost savings and improved quality and, if successful, can be scaled on a nationwide basis. These models are evaluated regularly, and CMS has the authority to modify or terminate models if they fall short of the statutory criteria.
The four models the agency plans to terminate are ending for various reasons (e.g., underwhelming performance, forthcoming replacement by successor model, etc.) and, as stated above, the decision should not be seen as a retreat from value-based care, but rather as a signal regarding Administration priorities for Innovation Center models. For example, despite terminating PCF and MCP prior to their original end dates, CMS reaffirmed its support for primary care as a “foundational component of the Center’s strategy” and that future primary care payment reforms will focus on approaches that produce savings. CMS also noted that ending these models early offers an opportunity to move beneficiaries into more permanent programs, such as the Medicare Shared Savings Program (MSSP)—CMS’ flagship accountable care initiative—even going so far as to direct readers to the MSSP’s calendar year 2026 application.
CMS plans to advise current model participants of other options for advanced primary care payment before the models conclude by December 31, 2025. Table 1 presents information on the models scheduled for early termination.
Table 1: Models Ending by December 31, 2025
In addition, the agency is considering options to reduce the size of the InCK model and will no longer pursue the Medicare Two Dollar Drug List and Accelerating Clinical Evidence models. The latter two initiatives were included in a Biden Executive Order on drug pricing and were not implemented. Notably, CMS did not end another drug pricing Innovation Center model, Cell and Gene Therapy Access (CGT) Model.
Innovation Center’s New Strategic Plan
CMS also announced that it will soon release its new vision for the Innovation Center, based on principles designed to improve Americans’ health through evidence-based practices, empower individuals with decision-making information, and drive competition.
This vision will set the direction for future value-based care initiatives and reflect the leadership changes within CMS, including the anticipated confirmation of Mehmet Oz, MD, as CMS Administrator and the appointment of Abe Sutton, as the new Director of the Innovation Center. Mr. Sutton’s experience with value-based care—especially during his time as an advisor to then Department of Health and Services Secretary Alex Azar under the first Trump Administration and his subsequent private sector leadership of value-based companies—positions him to play a key role in shaping CMS’s future efforts.
Stakeholder Considerations
Stakeholders have several critical operational decisions and strategic considerations to address, including:
- Transition Support. Participants in the models scheduled to end must assess their options for sustaining certain components of the payment models without Innovation Center support. This effort will require strategic, operational, and financial analyses to make informed decisions.
- Evaluation of Other Programs. While the Innovation Center has signaled its intentions of announcing new models, participants should not wait to evaluate options. The Administration plans to prioritize permanent payment programs and will continue to support the MSSP as CMS’s permanent model for accountable care organizations (ACOs). Stakeholders interested in participating in the MSSP in 2026 must act quickly to assess their organizational readiness, conduct financial modeling of their potential benchmark and performance, evaluate potential partners, and prepare for the application process. Both existing and new ACOs should be exploring their strategies and infrastructures to optimize performance.
- Adapting to Changes in Existing Models. While CMS discontinued select models, it is likely the agency will make additional changes to the Center’s continuing models. These revisions likely will reflect President Trump’s executive actions and policy priorities. With the increased focus on cost savings, CMS may choose to spend fewer resources on model implementation, including participant support and model engagement.
- Policy and Market Intelligence. Monitoring the dynamic federal policy landscape and seeking strategic advisory support can help stakeholders navigate and inform potential future federal and state alternative payment model opportunities. Stakeholders should expect that existing and potential new models may have stricter requirements and higher expectations for financial risk. Providers, states, insurers, and other interested stakeholders should monitor public and private sector developments to understand the landscape and evolving opportunities.
Connect with Us
Health Management Associates, Inc. (HMA), is home to alternative payment model experts that can assist stakeholders in responding to changes in Innovation Center models and the agency’s approaches and to help prepare for participation in future model opportunities. Additionally, HMA produces a weekly briefing focused on public and private sector VBP-related news. To learn more about how HMA can support your organization’s federal engagement and innovation strategy, contact Amy Bassano and Kate de Lisle.
HMA Roundup
Alabama
Alabama Senate Passes PBM Regulation Bill. The Associated Press reported on March 20, 2025, that the Alabama Senate voted 32-0 to advance a bill that would impose regulations on pharmacy benefit managers (PBMs). Senate Bill 252, sponsored by Senator Billy Beasly (D-Clayton), would require PBMs to reimburse independent pharmacies at the state Medicaid agency’s reimbursement rate and ban spread pricing. The bill now moves to the House for consideration.
Arkansas
Arkansas House Committee Advances Postpartum Medicaid Coverage Extension Bill. KATV reported on March 24, 2025, that the Arkansas House Public Health, Welfare, and Labor Committee advanced a bill sponsored by Representative Aaron Pilkington (R-AR) to extend postpartum Medicaid coverage from 60 days to one year. Nearly 40 percent of new mothers in Arkansas lose Medicaid coverage after the initial 60-day postpartum period, according to the Arkansas Department of Human Services.
Connecticut
Connecticut Committee Advances Bill to Cap LTC Rate Hikes, Increase Transparency. CT Mirror reported on March 19, 2025, that the Connecticut Government Oversight Committee advanced a bill which would require public hearings for long-term care insurance rate increases over 10 percent, mandate clearer disclosures about potential premium hikes, and cap certain rate increases based on the consumer price index. It also calls for a comprehensive review of long-term care insurance regulations, with a report due by February 2026, and requires biennial state audits of Connecticut’s long-term care insurance partnership plan.
Georgia
Georgia New Medicaid Foster Care Contract Raises Concern from Advocacy Group. The Georgia Recorder reported on March 24, 2025, that Georgia’s plan to shift Medicaid services for foster children to UnitedHealthcare has raised concerns from the Foster Care Institute advocacy group and parents about reduced access to mental health care. The award, announced in December, coincided with a ProPublica report accusing UnitedHealthcare of denying necessary autism treatments. The contract remains under protest and is not yet final.
Idaho
Idaho Governor Signs Bill to Transition to Managed Care, Add Work Requirements. The Idaho Press reported on March 19, 2025, that Idaho Governor Brad Little has signed a bill to implement Medicaid work requirements for the expansion population and move the state toward fully-capitated managed care. House Bill 345, sponsored by Representative Jordan Redman (R-Coeur d’Alene), directs the state Department of Health and Welfare (DHW) to submit a Section 1115 demonstration proposal to require able-bodied adults in the Medicaid expansion program to meet certain work requirements, and will also direct the DHW to seek federal approval to transition to managed care. The bill will also implement Medicaid cost sharing, end automatic eligibility renewal using information from other programs, and give DHW more authority to cut costs if the federal government reduces its federal medical assistance percentage for the expansion program.
Iowa
Iowa Senate Approves Medicaid Work Requirements Bill. The Iowa Capital Dispatch reported on March 25, 2025, that the Iowa Senate passed Senate File 615, which requires Medicaid expansion beneficiaries to work 80 hours per month, with exceptions for those with disabilities, in substance use treatment, or caring for young children. Approximately 142,000 of the 181,000 current expansion enrollees would be subject to the new requirements, with the state estimating up to 32,000 losing coverage. The bill includes a provision directing the state to terminate its expansion program if federal approval for work requirements is denied. Similar measures have advanced in the House and Senate committees.
Iowa Subcommittee Advances Bill to Impose Medicaid, SNAP Work Requirements. The Iowa Capital Dispatch reported on March 20, 2025, that Iowa’s Senate Appropriations Subcommittee approved Senate File 599, a bill that would impose work requirements on recipients of Medicaid under the Iowa Health and Wellness Plan (IHAWP) and Supplemental Nutrition Assistance Program (SNAP) benefits. If the required federal waiver is denied, the bill calls for suspending the state’s Medicaid expansion program. The legislation does not specify how many work hours are required and includes exemptions for people with disabilities and parents of young children.
Maine
Maine to Submit Section 1115 SUD Demonstration Renewal for Reentry Services, Tribal Health. Maine’s Department of Health and Human Services (DHHS) released on March 21, 2025, a draft five-year renewal application for its Section 1115 demonstration—currently the Maine Substance Use Disorder (SUD) Care Initiative—proposed to begin January 1, 2026, under a new name: Maine’s Whole Person Care Waiver. The draft proposal includes expanded behavioral health services, contingency management, pre-release Medicaid coverage for incarcerated individuals, recuperative care for people experiencing homelessness, and traditional healing services in partnership with tribal communities. DHHS is also requesting $15 million in capacity-building funds to support cross-system implementation. Public comments are open through April 22.
Lawmakers Introduce Bill for Medicaid IMD Exclusion Demonstration. News Center Maine reported on March 25, 2025, that Maine lawmakers introduced legislation sponsored by Senators Joe Baldacci (D-Bangor) and Rick Bennett (R-Oxford) directing the Department of Health and Human Services (DHHS) to seek a federal waiver removing the Institutions for Mental Diseases (IMD) exclusion, which currently prevents Medicaid reimbursement for inpatient psychiatric care in facilities exceeding 16 beds.
Massachusetts
Massachusetts Seeks New Vendors as Commonwealth Care Alliance Plans to Cease Operations. The Boston Globe reported on March 19, 2025, that Massachusetts officials are preparing for Commonwealth Care Alliance (CCA), an insurer serving 50,000 elderly, disabled, and low-income members, to cease operations due to ongoing multimillion dollar operating losses. The members will transition to the state’s fee-for-service program, MassHealth, which does not include the more robust services offered by CCA. The state is seeking vendors to take over care coordination services for members transitioning to MassHealth to ensure they receive the same level of services. The state may also step in to keep CCA’s primary care clinics open in Boston and Springfield. The state previously froze new enrollments in two CCA Medicaid programs after the insurer reported severe financial instability.
New York
New York Extends CDPAP Enrollment Grace Period. Crain’s New York Business reported on March 24, 2025, that the New York State Department of Health is extending the deadline for users to register with the single statewide fiscal intermediary taking over the Consumer Directed Personal Assistance Program (CDPAP). Public Partnerships LLC will take over CDPAP on April 1, 2025, but the state is allowing users to enroll through April 30. The extension does not impact the fiscal intermediaries currently running the program who must cease operations by April 1. Personal assistants who provide services during the month of April will receive retroactive payments.
North Carolina
North Carolina Receives Federal Approval for PHE Section 1115 Hurricane Helene Demonstration. The Centers for Medicare & Medicaid Services (CMS) announced on March 25, 2025, that it has approved North Carolina’s Section 1115 Hurricane Helene Public Health Emergency Demonstration, allowing the state to provide retainer payments to personal care service providers impacted by the public health emergency. The demonstration also extends Healthy Opportunities Pilots (HOP) services to eligible beneficiaries who were displaced from the affected region due to the hurricane. The waiver is retroactive to September 25, 2024—the start of the public health emergency—and will remain in effect through March 23, 2025.
National
Senate Finance Committee Advances Dr. Oz Nomination for CMS Administrator. NPR reported on March 25, 2025, that the Senate Finance Committee voted 14-13 in favor of advancing Dr. Mehmet Oz’s nomination as administrator for the Centers for Medicare & Medicaid Services (CMS). The nomination now moves to the full Senate for a final vote.
President Trump Nominates March Bell for HHS Inspector General Position. Modern Healthcare reported on March 25, 2025, that President Donald Trump has chosen Attorney March Bell to run the U.S. Department of Health and Human Services (HHS) Office of the Inspector General. Bell currently serves as general counsel for the House Administration Committee, and previously served as senior advisor and chief of staff at the HHS Office for Civil Rights during the first Trump administration.
CMS Increases Hospital Price Transparency Rule Enforcement. Modern Healthcare reported on March 25, 2025, that the Centers for Medicare & Medicaid Services (CMS) issued seven notices of monetary penalties against hospital systems for non-compliance with price transparency rules during the first two months of 2025, already more than the three penalties issued in all of 2024. The amount of the penalties is less, averaging $71,671 per penalty in 2025, compared to last year’s average penalty of $322,028. President Trump signed an executive order in late February 2025 strengthening the agency’s oversight of price transparency requirements.
Health Plans Invest in C-SNPs for 2025 Amid Medicare Advantage Shifts. Modern Healthcare reported on March 19, 2025, that health insurers like SCAN Health Plan, Alignment Health, and UnitedHealthcare are investing more in Chronic Condition Special Needs Plans (C-SNPs) in 2025 as the Medicare Advantage market shifts with higher competition in Dual Eligible Special Needs Plans (D-SNPs) and fewer people age into Medicare. C-SNPs are also adding supplemental benefits to address conditions like depression and are expanding where these policies are sold. In addition, C-SNP enrollment has increased 67.3 percent in the past year to 1.1 million as of February 2025, according to an analysis done by the publication using the Centers for Medicare & Medicaid Services data, the largest increase since C-SNPs began.
Proposed Medicaid Cuts Would Result in 29 Percent Increase of State Medicaid Spending Per Resident Per Year, KFF Finds. KFF released on March 24, 2025, an issue brief which found that Congress’ proposal to cut $880 billion in Medicaid spending over 10 years would result in a 29 percent average increase state spending per resident per year in order keep Medicaid spending and eligibility at current levels. States would have to increase taxes by an average of 6 percent in order to offset the cost, or make cuts to other large budget items such as education. The projected impact includes over 1 million job losses—primarily in healthcare and social services, according to a separate report by the Commonwealth Fund.
Industry News
Walgreens Settles Medicaid Fraud Pharmacy Lawsuit. Modern Healthcare reported on March 25, 2025, that Walgreens Boots Alliance has agreed to pay $5 million to Illinois to settle claims that it improperly billed Medicaid and Medicare. The lawsuit, which was originally filed in 2014, claimed the pharmacy violated the False Claims Act by influencing patients at an Illinois medical center to fill prescriptions at Walgreens’ specialty pharmacy. The funds will be distributed between the state of Illinois, the U.S. government, and lawsuit whistleblowers.
Aledade, Humana Expand Medicare Advantage Value-Based Care to Rural Clinics, FQHCs. Aledade announced on March 20, 2025, that it has expanded its collaboration agreement with Humana to provide value-based primary care for Humana’s Medicare Advantage members in Aledade’s in-network Federally Qualified Health Centers (FQHCs) and rural health clinics. Aledade has more than 300 health centers across 26 states.
RFP Calendar
Company Announcements
MCG Press Release
MCG’s Dr. William Rifkin to Speak at the ACMA 2025 National Conference on Observation Care and Utilization Trends: Dr. Rifkin will present the session, “Observation Care: Overview of Current Utilization and Anticipated Impact of Widespread Implementation of the Two-Midnight Rule,” on Friday, April 4, 2025, from 3:30 p.m. to 4:30 p.m. MDT. This session will focus on the utilization trends of observation vs. inpatient care in the wake of recent clarifications to the Two-Midnight Rule from the U.S. Centers for Medicare & Medicaid Services (CMS). Read More
HMA News & Events
HMA Podcast
What Strategies Help Local Governments Stay Resilient Amid Health Policy Changes? John Eller, managing principal at Health Management Associates, joins Vital Viewpoints on Healthcare to discuss the critical role of resilience in local health services. As communities navigate shifting federal policies, economic uncertainty, and natural disasters, John shares insights on how agencies can remain nimble, collaborative, and innovative. Drawing from his extensive experience in Medicaid transformation, behavioral health, and social services leadership, he highlights the power of community trust and cross-sector partnerships in maintaining stability during turbulent times. Listen Here
HMA Webinar
Survey Readiness: Prepare, Respond, Succeed, a 5-part Virtual Series. Every Wednesday in April 1:00 PM to 2:30 PM ET.
In today’s complex healthcare environment, navigating the scrutiny of regulatory and accreditation bodies like The Centers for Medicare & Medicaid Services (CMS), Department of Health (DOH), The Joint Commission, and Det Norske Veritas (DNV) Healthcare is critical for the success of every hospital and health system. Unexpected surveys, triggered by recertification, validations or even complaints, can occur at any time.
HMA has partnered with the Healthcare Association of New York State (HANYS) to develop the content for Survey Readiness: Prepare, Respond, Succeed, a 5-part virtual series on Wednesdays in April from 1- 2:30pm ET. HMA’s expert faculty will also co-teach the sessions. Attendees will dive deep into organizational strategies and tactics to prepare, manage and respond to surveyors effectively – and get the essential skills to excel in survey readiness.
While some examples in the program will address issues from the New York state perspective, attendees from organizations nationwide should attend. Hospital and long-term care executive team and leaders in quality and compliance, survey coordinators, and risk management will benefit from attending.
Survey Readiness: Prepare, Respond, Succeed
Virtual Series | April 2 – 30
- April 2: Survey readiness 101: Overview and getting started
- April 9: Preparation: How to mitigate risk and prepare for upcoming surveys
- April 16: They’re here: Establishing a survey response and management protocol
- April 23: Responding to survey findings: How to develop a strong correction plan and knowing your options
- April 30: What’s next: Leveraging survey findings and strengthening organizational quality and compliance
The cost to attend this series is $475.
State hospital associations and their members can enjoy $50 off when using this code when registering: SHADISCOUNT25
To learn more and to register, visit http://hanys.org/events/survey-readiness.
NEW THIS WEEK ON HMA INFORMATION SERVICES
(Exclusive Access for HMAIS Subscribers):
HMAIS Reports
- Medicaid Managed Care Enrollment for Nearly 300 Plans in 41 States, Plus Ownership, Updated 4Q24
- Updated Medicaid Managed Care RFP Calendar: 50 States and DC
- Updated Medicaid Managed Care Procurement Tracking Report
- Updated Section 1115 Medicaid Demonstration Inventory
- Updated Colorado State Overview
Medicaid Data
Medicaid Enrollment and Financial data from California, Colorado, Idaho, Minnesota, Nevada, North Dakota, Rhode Island, Texas, Virginia, and Wisconsin.
Public Documents:
Medicaid RFP documents from Florida, Massachusetts, New Mexico, and Washington.
Medicaid Quality Strategies, HEDIS/CAHPS Reports, External Quality Reviews, Medicaid Managed Care Advisory Committee Annual Reports, Regulatory Reports, Section 1115 Waivers, and other key documents from the following states: Colorado, Maine, New Hampshire, New Mexico, North Carolina, North Dakota, Tennessee, and Texas.
A subscription to HMA Information Services puts a world of Medicaid information at your fingertips, dramatically simplifying market research for strategic planning in healthcare services. An HMAIS subscription includes:
- State-by-state overviews and analysis of latest data for enrollment, market share, financial performance, utilization metrics and RFPs
- Downloadable ready-to-use charts and graphs
- Excel data packages
- RFP calendar
If you’re interested in becoming an HMAIS subscriber, contact Andrea Maresca at [email protected].