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As 2025 draws to a close, Congress finds itself at a crossroads on several critical health policy issues, with the fate of the Affordable Care Act (ACA) subsidies front and center. The year has been marked by intense negotiations and a flurry of proposals, many of which remain unresolved as lawmakers look ahead to a pivotal January 30 deadline for appropriations spending bills. In this article, policy experts from 黑料网 (HMA)鈥攊ncluding Leavitt Partners, an HMA company鈥攑rovide a comprehensive wrap-up of Congress鈥� work on ACA subsidies, executive agency actions, and what stakeholders should anticipate in early 2026.听

ACA Subsidies: A Year of Uncertainty and Political Maneuvering听

The听expiration听of enhanced ACA subsidies at the end of 2025 has been a focal point for congressional debate. Despite听numerous听bipartisan groups and a multitude of proposals circulating, consensus has proven elusive.听The Senate voted听on an ACA-related measure听December 11,听2025,听but neither the Democrats鈥櫶齪roposal for a three-year extension nor the Republican alternative to replace subsidies with health savings accounts advanced听and revise certain other Medicaid policies.听

The situation in the House has been equally complex. House GOP leaders unveiled a healthcare package designed to lower costs, expand association health plans, and increase transparency for pharmacy benefit managers. The package would not extend the expiring enhanced ACA subsidies, and even if the House bill passes, the Senate is unlikely to consider it. In addition, on December 17, House Democrats secured enough support to force a vote on a bill that would provide a three-year extension of enhanced subsidies, although House rules preclude scheduling a vote on the bill until January. 听

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The听prevailing sentiment among policy experts is that no substantial action will be taken before year鈥檚 end.听

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The White House briefly floated a two-year extension of the enhanced subsidies,听but听walked听back the proposal, signaling听fluidity in the policy discussions听within the administration and among congressional Republicans. The absence of consensus on both policy and political ramifications has left the ACA subsidy issue in limbo.听

Looking Ahead: January鈥檚 Appropriations Deadline and ACA Options听

December 15, 2025,听marked the last day for听consumers to enroll in ACA听coverage听policies that take effect听January 1,听2026,听meaning听that听for many听health insurance purchasers, choices for 2026 are already set.听Policymakers are now focused on听another听deadline for听potential听ACA subsidy action鈥擩anuary 30, 2026,听when temporary funding for the听current听federal fiscal听year听expires.听It is possible听that听a solution could be attached to the spending package, potentially听affecting听2026 premiums,听although operational challenges abound. The most听feasible option听at this stage would be a premium rebate, which would avoid reopening enrollment but require complex rate adjustments. Any substantive changes to the subsidy structure would demand significant actuarial analysis and could disrupt both听health听plans and state听activities.听

Congressional Dynamics: Appropriations, Extenders, and Policy Riders听

The appropriations process is center stage as Congress approaches the January 30, 2026, deadline. Lawmakers are seeking to continue passing 鈥渕inibus鈥� packages鈥攕mall groups of appropriations bills鈥攖o avoid another government shutdown. Most Medicare and Medicaid policy priorities, including must-pass extenders like telehealth flexibilities and the hospital at home program, are dependent on appropriations vehicles to advance. If Congress resorts to a stopgap continuing resolution, only the most essential extenders are likely to be included, with broader policy riders at risk of being sidelined.听

Policy Outlook听

Pharmacy听benefit听manager (PBM) reform stands out as a top bipartisan priority, with both House and Senate members eager to advance transparency and听de-linking听measures. Other lingering issues from the December听2024 healthcare package听include Medicaid spread pricing prohibitions, streamlined enrollment for out-of-state providers, and targeted benefits for military service members. In Medicare, multi-cancer early detection screening and digital health policies may resurface, though larger reforms like听Medicare听physician fee schedule changes are likely to be deferred听until听later in听2026.听

Agency Developments: CMS Innovation and Regulatory Changes听

Beyond Congress, the Centers for Medicare & Medicaid Services (CMS) has been active, rolling out new models and rules that will shape the landscape in 2026 and beyond. Highlights include the听2027 Medicare Advantage Policy and Technical Changes听Proposed Rule. Although it introduces no major policy shifts, the proposed rule addresses quality measurement, special needs plans, the Health Equity Index, and administrative burden reduction. It also codifies changes from the Inflation Reduction Act, such as cost-sharing and out-of-pocket limit reforms. The new ACCESS model听(Advancing Chronic Care with Effective, Scalable Solutions)听is听intended听to incentivize tech-enabled care for chronic conditions, with听the model beginning听July 2026.听

CMS also released updates to the outpatient, home health, and durable medical equipment rules, with a continued focus on site neutrality (aligning payments across settings) and removing barriers to beneficiary choice. The agency is placing ongoing emphasis on data collection, price transparency, and updated payment methodologies to reflect modern practice and technology. The 听(GENErating听cost Reductions听fOr听U.S. Medicaid)鈥疢odel introduces听most听favored听nation pricing for Medicaid, while听additional听mandatory Medicare drug pricing models are under review.听Rural health transformation听remains a CMS priority, with expectations for further announcements and awards before the end of the year.听

We expect 2026 to be another busy year for CMS with more new models being announced, continued policy refinements in the fee-for-service payment systems, and changes in Medicare Advantage based on feedback from the requests for information.听

Connect with HMA Policy Experts听

As the new year approaches, uncertainty remains the defining feature of federal health policy. The fate of ACA subsidies, the appropriations process, and a host of other reforms will hinge on negotiations in the coming weeks. For stakeholders navigating these complex dynamics, HMA鈥檚 team of policy experts stands ready to provide guidance, analysis, and support.听

As 2025 draws to a close, all of us across HMA want to thank you for your partnership this year. Together we have strived to meet complex, constant, and often unexpected听health and healthcare challenges in service to patients and communities.

Take a moment to watch our year end 鈥� we see you, we are here for you, and we are in this together.