Congress heading home without an ACA subsidy extension as the House advances a GOP health package.
A CMS bulletin that offers limited clarity on Medicaid community engagement requirements.
WISeR outreach.
Editor’s note: The Connection newsletter is taking a short holiday break! We’re pausing for the winter holidays on Thursday, Dec. 25, 2025, and Thursday, Jan. 1, 2026. The next edition will arrive on Thursday, Jan. 8, 2026. Wishing you a joyful, healthy holiday season!
Congress heads home without ACA subsidy extension as House advances GOP health package
On Wednesday, the House moved forward on a GOP healthcare package that would expand association health plans, which allow small employers to band together and provide health insurance, add new standards for pharmacy benefit manager contracting and transparency, and fund cost-sharing reductions to reduce out-of-pocket spending for some lower-income Affordable Care Act (ACA) enrollees.
Notably, the bill omitsany extension of the enhanced ACA premium tax credits set to expire on Wednesday, Dec. 31, 2025.
A Congressional Budget Office estimate released Tuesday found the bill would reduce the federal deficit by about $35.6 billionand lower gross benchmark premiums by roughly 11% on averagebut would increase the number of uninsured by about 100,000over the projection window.
Also on Wednesday, moderate Republicans escalated their break with leadership by joining Democrats on a discharge petition to force a vote on a clean, three-year extension of the enhanced ACA subsidies.
The discharge petition reached the 218-signature threshold with the votes of a group of GOP moderates including Brian Fitzpatrick (Pa.).
Fitzpatrick explained their reasoning, stating that “We have worked for months to craft a two-party solution to address these expiring healthcare credits. Our only request was a Floor vote on this compromise... Unfortunately, it is House leadership themselves that have forced this outcome.”
Due to House procedures, the first realistic window for the vote on the three-year extension of the subsidies is next month. Even if the House passes that measure, the path for passage in the GOP-led Senate will likely remain steep.
Meanwhile, the real-world consequences of Congress allowing the subsidies to expire are immediate.
The Kaiser Family Foundation has estimated that premiums will more than double on average for ACA enrollees without the enhanced subsidies.
This is fueling Republican moderates’ concerns about both constituent backlash and the GOP’s exposure in swing districts ahead of the 2026 midterms.
CMS bulletin offers limited clarity on Medicaid community engagement requirements
Last week, the Centers for Medicare and Medicaid Services (CMS) issued an Information Bulletin on the Medicaid community engagement requirements that states must implement by Jan. 1, 2027.
In the guidance, CMS reiterated the program’s core elements and timelines and included a few programmaticclarifications for states.
For example, CMS explained that a state must first attempt to establish a beneficiary’s compliance with the requirements (or that an exemption applies) using “reliable information” available to the state; it may only request additional information from a beneficiary if necessary.
CMS published an illustrated timeline exhibiting when states must begin the required three months of outreach to beneficiaries prior to the community engagement requirements taking effect. The start date depends on whether the state requires one, two or three months of compliance “lookback” at application.
If, for example, Arizona requires beneficiaries to demonstrate three consecutive months of compliance prior to applying, the Arizona Health Care Cost Containment System would be required to begin beneficiary outreach in July 2026, just over six months from now.
Unfortunately, CMS’s bulletin leaves major policy and operational questions unanswered.
The guidance does not shed any light on how states should define and operationalize exemption categories.
For example, CMS did not clarify the ambiguous exemption for those who are “medically frail or otherwise [have] special medical needs,” and the terms “substance use disorder,” “disabling mental disorder” and “serious or complex medical condition” were also left undefined.
CMS did not describe any verification standards or flexibilities that will apply when data sources cannot confirm beneficiary compliance or exemptions.
Although CMS explained how the $200 million in grants will be allocated among states, it did not specify when the funds will be made available, even as states must finalize policies and begin budgeting, procuring vendors and designing systems now.
What’s next: Under the law, CMS must issue an interim final rule by June 2026.
Waiting until then will leave states without vital information and direction needed to complete program design and implementation by the time detailed notices and instructions must be sent to beneficiaries.
WISeR outreach
AzHHA launched a coordinated effort this week to engage Arizona’s Congressional delegation on the Centers for Medicare and Medicaid Services (CMS) proposed Wasteful and Inappropriate Service Reduction (WISeR) model, set to begin in six states, including Arizona.
Why it matters: Starting on Thursday, Jan. 1, 2026, providers would need prior authorization for traditional Medicare or face post‑payment review for 17 procedures across non-critical access hospital (CAH) acute care outpatient departments, ambulatory surgery centers (ASCs), physician offices and patient homes. Hospitals have raised concerns about:
A rushed implementation timeline.
AI‑driven prior authorization delays.
Limited transparency from vendors.
Added administrative burden on strained teams.
Recent action: AzHHA has:
Partnered with the American Hospital Association and five other states to elevate concerns to CMS.
Distributed a Congressional template letter to impacted hospitals earlier this week.
Started outreach to Arizona’s Congressional delegation.
What’s next: We’ll continue advocating for a more realistic timeline, clear vendor reporting and protections that safeguard patient access and care quality.
Join the AzHHA PAC to be the voice for Arizona hospitals
Why it matters: Decisions made at the Arizona Capitol and on Capitol Hill ripple through every aspect of hospital operations - from funding and workforce pipelines to patient access and flexibility.
How your support drives impact
Safeguard care: Your support keeps essential services available in rural and underserved communities.
Influence outcomes: Together, hospitals speak with one voice on payment models, preparedness and oversight.
Build resilience: Strong advocacy ensures hospitals can continue supporting Arizona’s families, communities and workforce.
The bottom line: Your contribution fuels the advocacy that keeps Arizona’s healthcare system strong and responsive.
If you’d like to contribute to the AzHHA PAC, please consider making a donation before the end of the year.
The program provides comprehensive education for nurses new to specialty, continuing education hours, mentorship and a smooth transition into a new professional practice setting.
Why it matters: With these valuable benefits, the Arizona Transition to Practice Program is designed to foster excellence in nursing care and ultimately improve patient outcomes.
The big picture: With this program, we aspire to create an environment where our nurses can transition seamlessly into new practice areas, gaining the confidence and competence they need to provide the best possible care to our communities.
Any Arizona healthcare facility licensed by the Arizona Department of Health Services that hires registered nurses may apply.
Specialty offerings are available in a variety of areas including emergency department, intensive care unit/critical care, progressive care unit, medical-surgical nursing, obstetrics and operating room.
The Arizona Department of Health Services (ADHS) continues to recommend the hepatitis B vaccine within 24 hours of birth, at 2-month and 6-month visits.
This recommendation algins with the current recommendations from the American Academy of Pediatrics and the American Academy of Family Physicians and is supported by evidence-based practice.
The big picture: At the Friday, Dec. 5, 2025 meeting of the Advisory Committee on Immunization Practices (ACIP), the committee voted to limit hepatitis B birth dose to clinical decision-making and recommend antibody blood tests before deciding if additional doses are necessary beyond the first vaccination.
Go deeper: Vaccine resources can be found on the ADHS website.
UPCOMING EVENTS
Friday, Feb. 13, 2026 - The Hertel Report Winter State of the State This bi-annual conference offers networking and timely insights on Arizona’s healthcare market, including Medicaid, Medicare Advantage, the Affordable Care Act Marketplace, ACOs and commercial trends. Speakers include AzHHA’s SVP of Policy and Advocacy Helena Whitney. AzHHA members can use coupon code AZHHA2026 for $15 off. Register here.
