Abby Burns (00:02):
From Advisory Board, we are bringing you a Radio Advisory, your weekly download on how to untangle healthcare's most pressing challenges. I'm Abby Burns. We can call a spade a spade. Healthcare policy ended up being a much bigger part of everyone's year last year than we all anticipated. The first quarter of this year perhaps hasn't felt quite as chaotic as the majority of 2025, but that's not to say there's nothing happening in the world of health policy. Some things have real teeth. Some things are more bark than bite. So today we're going to catch up with three advisory board experts to talk about three different areas of policy that are actively in play. I'll talk about what's happening with value-based care, with Clare Worth, site neutral payments with Nick Hula, and 340B with Chloe Bakst. We'll start off with my conversation with advisory board value-based care expert, Clare Wirth.

(00:51):
Hey, Clare. Welcome to Ready Advisory.

Clare Wirth (00:53):
Hey there, Abby. Happy to be back.

Abby Burns (01:01):
Clare, we talked a lot about the intersection of policy and provider financials last year, but perhaps counterintuitively, that conversation actually didn't really include all that much about value-based care or value-based payment policy specifically.

(01:14):
If I remember correctly, the Trump administration announced they were going to sunset a couple of CMMI programs. Then I've seen a number of new programs get announced in the last few months. Give us a pulse. What's going on with federal payment transformation and what does that tell us about the second Trump administration's posture toward value-based payment programs?

Clare Wirth (01:35):
Abby, you're right. There has been a lot of activity from CMMI in the last couple of months. Let me go back before we go into Q4 of 2025. So before that point, CMMI, CMS's innovation arm where all the value-based care models have come from, they said, "Here's our strategy for this Trump administration, and it is to protect the federal taxpayer." And that means zeroing in on cost savings fast, immediate fiscal impact, more accountability, and that is what led to that decision making you said around ending models early, like making care primary and primary care first.

Abby Burns (02:11):
Yeah, those are not models that we typically think of as having a a fast ROI in terms of financial savings.

Clare Wirth (02:16):
Yeah. They want value-based care on fee-for-service timelines.

Abby Burns (02:20):
Okay. So that maybe brings us to the fourth quarter of last year. What happened then?

Clare Wirth (02:26):
Flurry of announcements, ACCESS, LEAD, BALANCE, GUARD, GLOBE, ELEVATE, and GENEROUS.

Abby Burns (02:31):
Those are all CMMI models. New CMMI models.

Clare Wirth (02:35):
And all acronyms, so it's a bit of alphabet soup right now. This does feel a little unusual for CMMI for a couple of reasons. First, releasing a flurry of models at that volume and speed is a bit unusual for CMMI. That could be a lesson learned from the last Trump administration. Also, we didn't get the final specs and the final details in those announcements. So a lot of the underlying rules and details are still under development. And then the other thing to note is that the application cycle is compressed. So some of these models go live in July or September, and normally we have a longer runway between final details and launch.

Abby Burns (03:13):
That feels particularly difficult if the plans that were announced are also light on details.

(03:18):
Okay, so this is kind of a lot to take in because you rattled off a number of programs. I imagine a lot of healthcare leaders right now are just trying to keep up, keep their heads above water. What do listeners need to know about the models that you just named?

Clare Wirth (03:30):
So there's two large categories of models. The first is a set of drug pricing models, there were four of them having to do with negotiating GLP-1s and getting costs of certain drugs more similar to comparable countries, that's BALANCE, GENEROUS, GUARD, and GLOBE. The other set of new models are LEAD, ELEVATE, and ACCESS, and those are the three that VBC leaders are most interested in for good reason.

Abby Burns (03:56):
Interesting. I don't typically think about drug payment as being the focus for programs coming out of CMMI, I typically think about non-drug care delivery.

Clare Wirth (04:06):
I think the focus here is on giving CMS authority to negotiate in places that they want, which is right in line with reducing costs on a very rapid timeline.

Abby Burns (04:16):
In other words, when we look at where CMS spend breaks down, what are some of the highest cost areas and drugs fits squarely in there. The second three models that you named, LEAD, ELEVATE, and ACCESS, you said those are the three that VBC leaders are most interested in, and you said for good reason. What makes you say that?

Clare Wirth (04:34):
I'll start with LEAD, which stands for Long-term Enhanced ACO Design. And it is the only new accountable care model that they introduced, and it takes a lot of previous lessons learned from former ACO models that we've seen. So for example, models have changed midway through, or they've not been long enough to demonstrate cost savings for our population. LEAD is 10 years.

Abby Burns (04:57):
Wow.

Clare Wirth (04:57):
It is the longest ACO model CMS has ever tested, and they are done by upfront monthly payments. And while the exact methodology has not yet been fully fleshed out, the idea is that they're going to have a longer, improved, predictable benchmarking methodology. So longer runway than before and consistent rules of the road.

Abby Burns (05:19):
We don't know exactly what those rules are going to be?

Clare Wirth (05:21):
Correct. We've also consistently seen in the research that a driver ... In fact, the number one driver of an ACO success is taking on meaningful downside risk and not spending so much time on that glide path dabbling in upside risk, LEAD is two-sided risk from day one. There's no upside risk to track at all.

Abby Burns (05:41):
That feels like a really high bar to clear for organizations to sign up and say, "Yes, I want to do this. I want to commit my organization for 10 years and take on downside risk from the jump." I'm assuming this is not a mandatory program, but an opt-in. Any sort of crystal ball that you can give us on provider interest in participating here?

Clare Wirth (06:01):
LEAD is optional. And at first I had the same thought who's going to want to do this. We have seen orgs that are committed to long-term and downside risk are the most likely to succeed. And there's also some interesting elements of this model that open up possibilities of what we haven't done before. So for example, we've left specialists out, LEAD has optional specialty bundles built in, nested bundles, and they also have explicitly written out some benefits that an ACO can use if patients are engaged. So for example, offering healthy foods to patients who are engaged in chronic disease management, they're able to provide those services.

Abby Burns (06:39):
This is really interesting because it's almost like experimentation from CMMI, but within an infrastructure and architecture that we already are familiar with.

Clare Wirth (06:48):
Exactly right. And at the same time, they are still doing some active experimentation, and that's where ELEVATE comes together.

Abby Burns (06:56):
Okay, what is that one?

Clare Wirth (06:57):
The full name is MAHA ELEVATE, so Making America Healthy Again, Enhancing Lifestyle and Evaluating Value-based Approaches Through Evidence model. So really catchy.

Abby Burns (07:07):
Rolls right off the tongue.

Clare Wirth (07:09):
Easy to remember. This program is designed by having a set of money designated for about 30 pilot projects, each one designed to test different preventive care approaches that will eventually inform future Medicare payment design.

Abby Burns (07:27):
Okay. And I'm guessing this is one of the ones where we're a little bit lighter on details as to what those pilots might actually look like.

Clare Wirth (07:33):
Yes, but they have designated a couple for dementia care specifically.

Abby Burns (07:37):
There's one other that you mentioned. We talked about LEAD, we talked about ELEVATE, and then you also mentioned ACCESS.

Clare Wirth (07:45):
ACCESS is an interesting one because it's CMMI inviting tech vendors in for chronic disease management, not dissimilar to what they've already done with WISER last year. There's a lot of tech-based chronic disease management care that Medicare has not previously reimbursed for. And so this opens up a world of tech-enabled care beyond what we've primarily done, which is a lot of telephonic chronic disease management, and they're biting off a huge piece of opportunity here. So another 10-year model, there's a set of target conditions that accounts for two-thirds of Medicare patients, so we're talking really common conditions, diabetes, MSK, behavioral health, hypertension, really the big ones.

Abby Burns (08:30):
It feels like one of the themes across these programs is widening the umbrella, bringing more organizations and more patients potentially into value-based payment arrangements.

Clare Wirth (08:43):
And more perspectives. This CMMI seems to be more open to new ideas from new stakeholders who haven't previously been in the mix and not really wedded to one ideology or any previous structure. So for folks out there who want to bring something useful to CMMI, I think that they're more open than previous administrations.

Abby Burns (09:03):
As long as you can show financial ROI.

Clare Wirth (09:05):
Exactly.

Abby Burns (09:07):
All right, Clare, bearing in mind the conversation that we've had so far, I want to end by asking what decisions healthcare leaders need to be making today to prepare for changes to VBC that we're going to see across the rest of 2026 and the rest of the second Trump administration.

Clare Wirth (09:25):
These models are quite new. As we said, folks are just starting to learn them and there's still details to be sorted out. So the first is people don't necessarily know about these programs and it's time to educate yourself. The second is that time is of the essence. There are literal deadlines, so check CMMI's website to make sure that you're in a position to apply should you want to. And of course, Advisory Board has been researching this topic of value-based care for a long time, and we have playbooks of what works. And two specific Radio Advisory episodes I'd call out for folks is Ochsner Health, who we interviewed in the fall and Advocate Health last spring. They're phenomenal examples of what VBC's success looks like.

Abby Burns (10:04):
Well, Clare, thank you for coming back on Radio Advisory.

Clare Wirth (10:08):
Thank you.

Abby Burns (10:11):
I also caught up with Advisory Board expert, Nick Hula to talk about site neutral appointments.

(10:18):
Hey, Nick. Welcome to Radio Advisory.

Nick Hula (10:21):
Thanks, Abby. Always great to be here.

Abby Burns (10:23):
Nick, we're here to talk about site neutral payments today. I have to say, and you've come on the podcast before to talk about site neutral payments, and every time I feel like I start with the caveat, these were first enacted in 2015, but they've essentially been delayed, pushed off, shifted for the last decade plus. This is a great example of a policy where providers and plans are on the same page in terms of the degree of passion that they have for site neutral payments, just on opposite sides of the equation. There's a lot riding on the policymaking here. Catch me up. Where are we?

Nick Hula (10:58):
First, just a reminder on what site neutral payment is, as you mentioned, it's been talked about and then dismissed and talked about dismissed for a while now. Site neutral payment is for outpatient services. It would align what Medicare reimburses to hospital outpatient departments with what they reimburse to an office setting.

(11:19):
Where we are today is in 2025, site neutral payment gained actually a lot of bipartisan support as a way to reduce federal health spend. If they can bring down the monthly reimburse to the office setting amount, that would be savings for CMS. Talk here was a little bit bigger than action though. In the end, CMS only finalized a rule to expand site neutral payment to drug administration at some previously exempted hospital outpatient departments.

Abby Burns (11:48):
Okay.

Nick Hula (11:49):
Moving into 2026, we're watching to see how does CMS and how does Congress really expand upon that momentum? This could include expanding site neutral payment to all off-campus HOPDs that may have been previously exempted from this rule. It also could be expanding the type of services a site neutral payment applies to. Think things like imaging, think things like potentially even some procedures.

Abby Burns (12:16):
Would that include things like office visits as well?

Nick Hula (12:19):
Yeah. So office included, others are already included in it right now, added drug administration, but could include in the future things like imaging, things like those procedures too.

Abby Burns (12:28):
Okay. I believe, Nick, though, and correct me if I'm wrong, site neutral payments are actually not the only policy lever being pulled right now to try and push procedures to lower cost sites of care. What are some of the other things that are happening?

Nick Hula (12:42):
Oh, absolutely. There's a lot going on right now when it comes to site of care shifts. One big one is the inpatient only list or the removal of the inpatient only list, and that one is, as it sounds, it's a list of codes CMS will only reimburse in the inpatient setting. This is also one just like site neutral payment where there's been a ton of back and forth. Every year or so, CMS will remove a couple of codes from that list, but back in 2021, the final rule from the Trump administration and Trump 1.0, they actually said, "We're getting rid of this thing altogether. No more inpatient only list." The following year, Biden administration's first rule, they said, "No, wait, we're going to have the inpatient only list, [inaudible 00:13:23] going back on that." And then so this year, once again, Trump administration said they're getting rid of the inpatient only list on a three-year phase out.

Abby Burns (13:34):
That was going to be my question. Is this something that happens immediately once this is passed or is this something that happens over time?

Nick Hula (13:38):
Yeah, so it'll be over time. There are a bunch of codes that were removed mainly in the musculoskeletal space this year as of January one, 2026. But like you said, there's going to be more things that come off this list in 2027 and the rest of 2028.

Abby Burns (13:54):
I want to get a sense for how big a deal that is, but before I do, we've got site neutral payments, we've got removal of inpatient only list. Are there any other policy leverage we need to look at?

Nick Hula (14:03):
Yeah, so there's actually one state level policy I want to talk about. There are two upon at the federal level. And the state level one is what's called Certificate of Need laws. Sorry, I'm continuing along the alphabet soup that Clare started with here. Certificate of Need laws, or CON laws, are laws that individual states will have that limit what providers can build or invest in unless they can prove their market needs it. So they can't just go out and build this new ambulatory surgery center or freestanding imaging center or infusion center unless they can prove that their market needs it.

Abby Burns (14:37):
You mentioned this as a state lever, and I imagine this could look pretty different across different states. Any that you have your eye on in particular?

Nick Hula (14:44):
Yeah, so right now we're watching North Carolina, Alabama and New York are going to be the three we watch in 2026. The trend over the past few years has been states either removing these laws altogether or at least loosening them to apply to less types of sites. But those three states are ones in which we could see some state legislatures drop the barrier to ambulatory expansion by allowing organizations to build more without needing to get this certificate of need.

Abby Burns (15:11):
So when we look across these three policies, site neutral payments, inpatient only, certificate of need, how should we think about the relative importance or relative impact of each of these policies?

Nick Hula (15:23):
Each one of them is not going to cause a site of care shift on their own. These don't occur in a vacuum. What I'll say is these will more likely accelerate a shift that's already taking place than cause one in the first place. For example, for a certificate of need, we saw that accelerate shifts down in Florida when they loosened their laws in terms of orthopedic ASCs or cardiovascular ASCs. It was already starting to shift in Florida, but that's the thing that really accelerated it. The same thing with site neutral payment. It's essentially just dropping a barrier that's been in place to sight of care shifts. The inpatient only list is going to be an interesting one as that might cause some experimentation.

Abby Burns (15:58):
Yeah, that one feels like a little bit more heavy-handed.

Nick Hula (16:01):
Exactly. If something can now be reimbursed in the outpatient setting, [inaudible 00:16:05] might experiment with like, "Hey, can we be doing this in the hospital outpatient space first, and then eventually move into the non-hospital space later on?" So that might be one where it actually causes new shifts to occur over the next 5, 10 years.

Abby Burns (16:17):
I could also see commercial payers saying, "Hey, this was removed from the inpatient only list, therefore I am only going to reimburse it at an outpatient rate regardless of where a provider provides the service."

Nick Hula (16:28):
Correct. Down the line, that's absolutely something that we could see.

Abby Burns (16:30):
So I want to come back to the reality that you've named for us, which is this is an area where we've had a lot of false starts over the last decade. What degree of confidence should leaders have that these policy changes, one, are going to happen and going to stick this time, and two, that they're actually going to make a difference?

Nick Hula (16:47):
Yeah, I would say a high degree of confidence. Something new is going to happen here because a lot of the stops and starts that we've seen over time were because it happened at say the end of the Trump administration, for example, like the inpatient only list that happened the very last year of the Trump administration, and then the Biden administration reversed course there. This is happening at the very beginning of the Trump administration and it's a three-year phase out, three years left in his term, aligns nicely there. It's also an area where there is some bipartisan support from Congress.

(17:17):
And the final thing I'll say there is there's a lot more than policy that was impacting these side of care shifts. So think about consumer preferences, payer, employer, steerage physician preferences. Leaders can kind of ignore what's going on in DC or their state capital at their own risk, but there's a lot else that's really having the same effect for better or worse on where care takes place.

Abby Burns (17:40):
Nick, I'll end with the same question that I asked Clare, which is, bearing our conversation in mind, what do leaders need to do next when it comes to site of care shift?

Nick Hula (17:50):
Everyone needs to have an ambulatory strategy. And that doesn't mean dismissing the importance of the hospital. The hospital is still critically important to every market, but it's about having a smart ambulatory strategy. This is where we have done a ton of research over the past couple years, and it's on things like focusing on what are the key capabilities that my market needs from my organization in the ambulatory space. It's about not just copying and pasting what worked in the hospital into the ambulatory setting and just assuming it's going to work. It needs to have unique operations, unique workflows.

(18:22):
The change management aspect of it all too, just because something comes off an inpatient only list, that doesn't mean that doctors are going to do that thing in the outpatient setting or they'll be comfortable doing it. So the big workforce piece to this as well.

Abby Burns (18:34):
For non-providers, are there any pieces of guidance that you would name?

Nick Hula (18:38):
Honestly, I would probably give really similar advice. And just like I said, providers can't just copy and paste what worked in the hospital into the ambulatory setting in terms of operations and workflows and assume it's going to work. Suppliers, be that med tech, device, pharma, service providers, whatever you are, you can't just copy and paste your value narrative or your value proposition that works in the hospital into the ambulatory space and assume it's going to work. These sites have unique needs. They're getting less reimbursement for the same services, making them really cost sensitive. They are probably going to have a lot less supply chain resources than hospitals do, so they might need logistics support perhaps. They're just smaller sometimes, so space requirements might be very different, needing to not just tweak your value narrative, but to almost come up with a whole new value narrative for ambulatory altogether.

Abby Burns (19:27):
Nick, thanks for coming back on Radio Advisory.

Nick Hula (19:30):
I appreciate you guys having me.

Abby Burns (20:57):
For our final conversation today, advisory board pharmacy expert Chloe Bakst is back on the pod to talk about 340B. Hey, Chloe. Thank you for coming back on Radio Advisory for the second week in a row.

Chloe Bakst (21:08):
Happy to be here.

Abby Burns (21:09):
And once again, to talk about drugs or at least drug policy. And specifically, we're here to talk about 340B. This is a policy area that generates a lot of anxiety, especially for providers because of how important it is to provider finances, but it feels like it's also an area where a lot has been happening. And to be honest, it's hard to kind of keep track of where things stand at any given moment. How would you describe this moment in 340B policy, Chloe?

Chloe Bakst (21:37):
I think the word that comes to mind for me is chaotic in the sense that things are just changing so quickly. Let me give you an example. So on January 1st, 2026, we were supposed to have the launch of a 340B rebate pilot program. This would've changed the way that 340B discounts were applied for a select set of 10 drugs, where instead of having the discount at point of sale, the health system's 340B eligible institutions would have to send data to manufacturers, manufacturers would receive that data, say, "Yes, this is a 340B prescription," and apply the discount as a rebate after the point of sale.

Abby Burns (22:14):
Which to be clear, most providers were not then and are not now set up to operate that way.

Chloe Bakst (22:20):
Yes, it would've been a dramatic change from the way that the program is currently run. Perhaps because of the level of dramatic change that would become of that, it was ultimately stalled in the courts on December, I believe, 27th or maybe even 29th, very close to the end of the year and was not going to move forward into 2026. We were kind of in this stalemate of watching the litigation move forward. To be clear, the reason why it was halted was the fact that there were some rules processes that were potentially skipped or are not followed to the letter in enacting the pilot. So in response to that, HRSA in early February said, "Okay, we're actually going to just pull the plug on this pilot model. We're not going to move forward with this iteration of a rebate program for 340B." And we kind of sat in this moment of relief for providers who no longer had to worry about that happening in 2026.

Abby Burns (23:20):
But that is not where the rebate model story ends.

Chloe Bakst (23:24):
No, this is where we come back to that idea of chaos. As of February 6th, HRSA issued an Office of Management Budget, OMB, notice to approve data collection needed to run the pilot. So this is them trying to dot the I's cross the T's of the rules making process so that they can enact the pilot in the future without having it get stalled up by the courts.

Abby Burns (23:46):
This is probably a good moment to timestamp our conversation, so we're talking on the afternoon of February 12th, in case more happens between now and when folks might be listening to this episode.

Chloe Bakst (23:56):
Great call. I will say that for this new rebate model pilot program, there is an open public comment period. So there's also probably a level of urgency for listeners if this is something that they care about a lot, now is the time to get with your leadership and figure out if you want to make a comment.

Abby Burns (24:13):
So for this very moment, a rebate model is not moving forward. Does that mean we're not going to see significant change to the 340B program at all in the near term?

Chloe Bakst (24:23):
No. I think the rebate chaos to me signals that there's still a lot of interest and momentum in regulating 340B. The rebate model itself was going to be a very small scoped pilot, it's more so what it represented to the program of, we are going to change the way that this discount is applied, feels like a more existential change. There are other changes on the table, things that are actively happening that feel a little less existential, but still we see 340B reform in the spotlight in a way that it hasn't been in years prior.

Abby Burns (24:59):
What are a couple of the other options on the table?

Chloe Bakst (25:02):
I talked about this a bit when we had our infusion conversation, Abby, but in Trump 1.0, we saw that the administration changed the way that they reimbursed for drug administration for 340B hospitals and Medicare. To not go too into the weeds, they essentially cut reimbursement for drug administration for 340B hospitals. Those cuts were overturned by the Supreme Court for, again, a rules making violation or are not following the procedures to the letter. And that actually led to CMS having to repay hospitals about $9 billion in remedy payments.

(25:37):
What's happening today is that CMS is putting out a survey to collect data on drug acquisition costs for 340B and non-340B hospitals in Medicare, and that's the first step toward making those cuts happen in a way that they would not get overturned in the courts.

Abby Burns (25:56):
Right. Rectifying the legal mistake by first getting the data solicitation so then you can move forward with the cuts.

Chloe Bakst (26:01):
Yeah, we're seeing very similar to what Nick described, the lessons learned from Trump 1.0 applied and adapted in Trump 2.0.

Abby Burns (26:10):
That's really interesting because it's not so much flip-flopping, it's learning from past experiments or attempts.

Chloe Bakst (26:16):
Exactly.

Abby Burns (26:17):
Do we know how big cuts would be in this second attempt?

Chloe Bakst (26:20):
We don't know exactly. I will say we have some estimates of mild, moderate, severe scenarios for providers and our policy scenario calculator tool that we have at advisory.com. So if that's something that folks are trying to size as they're doing scenario planning, highly recommend checking out that tool.

Abby Burns (26:39):
As we're thinking about projections and scenario planning, Chloe, I also want to understand the relationship between 340B and the One Big Beautiful Bill Act. Is the One Big Beautiful Bill Act likely to impact 340B or 340B eligibility?

Chloe Bakst (26:56):
Yeah, there are definitely some ripple effects that we're going to keep our eye on. The Medicaid changes that we're going to go into effect as a result of the One Big Beautiful Bill Act could impact DISH status. DSH status is what determines your eligibility for the 340B program.

Abby Burns (27:10):
Right. DSH being Disproportionate Share Hospital Status.

Chloe Bakst (27:13):
Yes, thank you. And we're going to see community hospitals and rural hospitals really get hit hardest from those changes. The bottom line there is that the Medicaid cuts may make hospitals, especially those who are our most vulnerable safety net hospitals, either ineligible for 340B or have to change from a DSH status to a different 340B eligibility status, which can have impacts on their profitability and then level of savings that they generate from the program.

Abby Burns (27:40):
For a long time, it felt like nobody wanted to touch the 340B program because there are such strong parties and strong lobbying arms on both sides of the equation, hospitals on one side pharma on the other. It sounds like 340B may no longer be untouchable. Is that a fair read?

Chloe Bakst (27:58):
I think that's a very fair read. We're starting to see this happen at the state level more and more. Already 10 states have passed 340B reporting requirements, and that has put one, a lot of tension between hospitals providing care in those states and their state legislatures, and it creates an operational burden where we're now having to report things like your 340B savings broken down by payer type, how you're using those savings on the drugs themselves.

Abby Burns (28:25):
Which is data that a lot of organizations are not currently collecting.

Chloe Bakst (28:29):
Yes. Either they're not currently collecting or it's not in an organized fashion that they're ready to necessarily share it. And I think the other thing that catches my eye when I see states enacting policies here is that it's often the precursor to federal regulation, especially in the drug space. We saw that with PBMs. We're going to see it with 340B. It's really where we see federalism happen. States are going to do this level of experimenting on enacting transparency rules for the 340B hospitals in their states and the federal government's going to watch, see what works, and it's giving us the roadmap to what we're going to see happen in a few years down the line.

Abby Burns (29:09):
Chloe, thanks for coming on Ready Advisory.

Chloe Bakst (29:12):
Thanks for having me, Abby.

Abby Burns (29:17):
We covered a lot of ground today in terms of what's happening in the world of value-based care, site neutral payments, and the broader policy landscape around site of care shifts, and of course, 340B. Hopefully, you feel like you have a better sense of what the rest of the year holds when it comes to these areas of health policy. I also want to acknowledge what you didn't hear in today's conversations, and that's an update on what's happening with Medicare waiver programs. Reminder, these were due to expire at the end of January. For years, these programs survived on serial short-term extensions. That uncertainty about the future of the programs led to a lot of operational disruptions for providers, and they were often tied to broader budget fights and government shutdowns that actually weren't healthcare specific. What you need to know I know now is that Congress has at least partially broken that cycle by giving these programs multi-year runways. Although how much time each program has looks a little bit different. I want to provide an update on the hospital at home program and on Medicare telehealth flexibilities.

(30:17):
As part of the Consolidated Appropriations Act of 2026, which reminder ended the late January partial government shutdown, Congress enacted multi-year extensions for both programs. The Hospital at Home program received a five-year extension running through September of 2030. Medicare telehealth flexibilities were extended for two years through December of 2027. This is unquestionably good news for providers, although it's not the end of the story. Congress didn't permanently codify these programs, which means providers will face a policy cliff in 2027 for telehealth and 2030 for hospital at home. So this is medium term stability, not certainty, which is why I want you to remember, as always, we're here to help.

(31:11):
New episodes drop every Tuesday. If you like Radio Advisory, please share it with your networks, subscribe wherever you get your podcasts and leave a rating and a review. Radio Advisory is a production of Advisory Board. This episode was produced by me, Abby Burns, as well as Rae Woods, Chloe Bakst, and Atticus Raasch. The episode was edited by Katy Anderson with technical support provided by Dan Tayag, Chris Phelps, and Joe Shrum. Additional support was provided by Leanne Elston and Erin Collins. Special thanks to Chad Peltier.