Legislative Updates July 2025
Earlier this month Congress passed – and President Trump signed into law – the FY25 budget reconciliation package referred to as H.R.1-One Big Beautiful Bill Act. The law includes provisions that will impact hospitals and health care systems nationwide, and Sanford Health’s policy team has been tracking those closely over the past few months.
Here are a few key provisions related specifically to health insurance:
- Medicaid expansion beneficiaries with incomes above 100% of the federal poverty level will need to pay up to $35 in cost sharing per service. Primary care, pregnancy-related care, mental health and care for substance use disorders are excluded. Cost sharing for non-emergency services provided in a hospital emergency department may exceed $35.
- States will need to redetermine eligibility once every six months for Medicaid expansion beneficiaries, beginning in calendar year 2027.
- Certain non-pregnant, non-disabled adult Medicaid beneficiaries will need to meet community engagement requirements beginning Dec. 31, 2026. These individuals must work or engage in qualifying activities for no less than 80 hours per month.
- Certain non-citizens will no longer be eligible for Medicaid or Medicare coverage.
- Individuals who do not actively verify income and other requirements annually will not be eligible for premium tax credits; this will prohibit automatic reenrollment for beneficiaries receiving premium tax credits.
- Beneficiaries who enroll in health coverage on the marketplace through a special enrollment period associated with their income are not eligible for premium tax credits.
- Health Savings Accounts or HSAs will be available to beneficiaries with bronze and catastrophic plans purchased on the exchange; currently, this option does not exist.
- The legislation permanently extends the safe harbor for high-deductible health plans to cover telehealth and other remote care services without a deductible.
Our teams are conducting a thorough analysis of the law’s direct and indirect impacts and tracking any next steps from state and federal officials. We’ll share more information as we continue to dig into the implications. In the meantime, slides from last week's presentation by Dylan Wheeler are available here.
Finally, as Congress wraps up the federal fiscal year and heads toward the August recess, our teams continue to monitor the Enhances Advanced Premium Tax Credits (EAPTCS) extension, Medicare Advantage reform efforts and the expiration of key telehealth flexibilities for Medicare beneficiaries.