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This week, read about: AzHHA submitting a comment letter to CMS asking to reduce subjectivity and in

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Connection Newsletter

By AzHHA Communications July 24, 2025

Smart Brevity® count: 6 mins...1655 words

This week, read about:

  • AzHHA submitting a comment letter to CMS asking to reduce subjectivity and increase transition period for provider tax changes.

  • Early bird registration for the 2025 Arizona Hospital Leadership Conference.

  • CMS posting proposed 2026 OPPS rule.

AzHHA asks CMS to reduce subjectivity and increase transition period for provider tax changes

Illustration of a book shelf with a health plus made from negative space.

AzHHA submitted a comment letter on Monday, July 14, 2025, to the Centers for Medicare and Medicaid Services (CMS) on the “Preserving Medicaid Funding for Vulnerable Populations – Closing a Health Care-Related Tax Loophole Proposed Rule.”

  • The proposed rule largely mirrors changes made in the One Big Beautiful Bill Act that restricts states’ use of provider taxes by redefining the “generally redistributive” requirement.

AzHHA expressed concerns that the proposed rule introduces excessive subjectivity into the evaluation of provider taxes, lacks an adequate transition period and fails to account for the new statutory mandates enacted since the proposed rule was published.

  • AzHHA indicated a concern to CMS that the combined changes will significantly affect Arizona’s Medicaid financing framework and pose serious risks to healthcare access if implemented without clearer guidance and more time for states to adjust.

  • AzHHA urged CMS to adopt specific regulatory safeguards to reduce subjectivity, provide states the full transition period authorized by the statute and reissue the rule to align with the new federal law.

Take advantage of the early bird rate: 2025 Arizona Hospital Leadership Conference

Loews Hotels Tucson

The bottom line: The 2025 Arizona Hospital Leadership Conference will be held at the exquisite Loews Ventana Canyon Resort in Tucson on Oct. 29-31.

The big picture: This will be an inspirational gathering of more than 200 hospital and healthcare executives seeking opportunities for continuing education, meaningful discussion and relationship building. This year’s conference theme is “Advocacy in action: shaping the future, leading forward.”

What’s next: You can:

  • Register now to receive an early bird discount. This discount ends Tuesday, Sept. 9, 2025.

Register today!

CMS posts proposed 2026 OPPS rule

Illustration of a health plus peeling back revealing a hundred dollar bill on the reverse side.

Last week, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule for the outpatient prospective payment system (OPPS) for calendar year (CY) 2026.

Why it matters: In addition to changes to OPPS, the 913-page rule includes changes that are particularly problematic for hospitals.

  • They include the adoption of site-neutral payments, the expansion of hospital price transparency requirements, the reduction of inpatient-only services and the acceleration of hospital 340B discount repayment obligations.

  • These developments cannot be overlooked, as they pose significant challenges to the operations and financial stability of healthcare institutions.

The proposed rule would:

  • Increase payments by a net 2.4%. This includes a market basket rate of 3.2% less a productivity factor cut of 0.8 percentage points.

  • Accelerate the timeline for clawing back $7.8 billion in overpayments associated with the 340B drug program. Payments would be spread over CY 2026 to 2031 instead of CY 2026 to 2041.

  • Expand site-neutral payments to pay for drug administration services furnished in grandfathered off-campus hospital outpatient departments at 40% of the OPPS rate. This would reduce payments to hospitals by $280 million.

  • Expand price transparency rules to require hospitals to disclose 10th, median amount and 90th percentile allowed amounts in machine-readable formats.

What’s next: AzHHA members should be on the lookout for a more detailed analysis of the proposed rule in the coming days, including facility-specific estimated impacts.

  • Hospitals may report feedback on the proposed rules to AzHHA’s Director of Financial Policy and Reimbursement Amy Upston.

  • CMS is accepting comments on the rule until Monday, Sept. 15, 2025.

Mercer survey: Large employers plan to shift more costs to employees and steer towards HPNs

Illustration of a neon sign in the shape of a health plus with an information "i" in the center.

Mercer’s April 2025 survey of 504 large employers (defined as 500+ employees) found that healthcare costs increased by 4.5% in 2024 and employers expect costs to rise by 5.8% in 2025.

  • Prescription drug spending increased by 8%, partially driven by GLP‑1 weight-loss treatments, such as Ozempic, that may cost approximately $1,000 per month.

    • Over three-fourths of employers flagged managing the costs of GLP-1 drugs as extremely or very important. Nonetheless, employers were more likely to report that they plan to add coverage for GLP-1 drugs rather than to drop it.

Fifty-one percent of the surveyed large employers intend to shift more costs, such as higher deductibles and copays, onto employees in 2026, up from 45% in last year's survey.

  • Employers plan to keep steering workers toward high-performance networks (HPNs)—18% already use them and another 24% plan to adopt them by 2026 or 2027.

  • Health plans create HPNs of selected hospitals and physicians based on factors such as clinical quality metrics, cost efficiency and patient satisfaction.

  • Employers are also embracing alternative plans to balance affordability: 37% offer low or no-deductible plans and 12% offer free employee-only coverage in at least one health plan.

Premium costs to increase by over 75% for ACA enrollees if enhanced tax credits expire

Illustration of a red cross spinning to reveal money

The Affordable Care Act (ACA) enhanced premium tax credits that assist low- and middle-income individuals with purchasing insurance will expire at the end of 2025 if Congress does not act.

  • These enhanced ACA subsidies were first enacted via the American Rescue Plan Act of 2021 and later extended through 2025 under the Inflation Reduction Act of 2022. 

Why it matters: A new analysis by the Kaiser Family Foundation and The Peterson Center on Healthcare of 105 ACA Marketplace insurers in 20 markets has found that insurers are planning to increase premiums by a median of 15% in 2026.

  • Part of the reason for the planned increases is the scheduled expiration of the enhanced tax credits.

  • According to the analysis, premium payments for subsidized enrollees will increase by over 75% starting in January 2026 without an extension.

  • Because a large number of enrollees would be expected to leave the market under those circumstances, insurers expect the risk pool to become less healthy and more expensive to cover.

If the enhanced premium subsidies are not extended, many Arizonans would not be able to afford coverage, especially those with lower incomes and those living in rural areas.

  • Additionally, these coverage losses would translate into spikes in uncompensated care costs for Arizona’s providers.

What you can do: Discuss the importance of extending these subsidies when you speak to your representatives and senators during the upcoming August recess.

Better Health for Mothers and Babies webinar series

A computer displaying a healthcare symbol.

In collaboration with AzHHA, Region One Health and Tuba City Regional Health Care Corporation, the American Hospital Association (AHA) is launching the Better Health for Mothers and Babies four-part webinar series.

Why it matters: This webinars will shine the spotlight on real-world strategies to improve maternal and infant health.

Join the first session on Thursday, Aug. 21, 2025, which will include Vicki Buchda, senior vice president of Care Improvement for AzHHA, and Katherine Glaser, MD, an OBGYN physician from Tuba City Regional Health Care Corporation, as presenters.

  • This event will share strategies on collecting and evaluating maternal health data, implementing quality improvement initiatives and making real change for mothers and their babies.

Register now

Q2 2025 Contract Labor Market Report

Stethoscope

From stabilizing bill rates to evolving labor laws, the healthcare workforce continues to change — and staying ahead of the curve is more important than ever.

Inside Adaptive Workforce Solutions’ Q2 2025 Contract Labor Market Report, you’ll find:

  • National and regional bill rate trends.

  • One Big Beautiful Bill Act’s implications for hospital workforce strategy.

  • Healthcare workforce news.

Why it matters: Whether you’re navigating contract labor challenges today or planning for tomorrow, this report provides the insights you need to make informed decisions.

Download the report

To connect with an Adaptive Workforce Solutions representative, email Nick Harvick.

Nominate a peer for the AzONL Leadership in Action Awards

Illustration of a smiley face in a golden trophy cup

Do you know a nurse leader who goes above and beyond - demonstrating excellence, innovation and unwavering dedication?

  • Now is the time to recognize their incredible impact by nominating them for the Arizona Organization for Nurse Leaders (AzONL) Leadership in Action Awards!

Award recipients will receive:

  • Statewide recognition from AzONL and nursing peers.

  • A spotlight in AzONL communications and events.

  • Complimentary registration to the AzONL Annual Conference.

  • A commemorative award celebrating their leadership.

  • A platform to inspire and mentor future nurse leaders.

What’s next: The deadline to submit applications is Friday, Aug. 15, 2025.

  • Submit your nomination here.

PAC promotion

UPCOMING EVENTS

Sept. 7-12 - National Tribal Health Conference
This is a week-long event that serves American Indian and Alaska Native Tribes in the space of health - behavioral and public health. The conference will showcase the interconnectedness of policy, advocacy and Indian health best practices. Register now.

Friday, Sept. 26 - Arizona Bioethics Network 13th Annual Conference
This hybrid event will bring together scholars from various disciplines to explore the ethical questions that shape health in a global context. This year’s conference theme is “The Interconnected World: The Ethics of Global Health Policy.” Learn more and register.

Wednesday, Oct. 1 - Introduction to POLST
Join physician orders for life-sustaining treatment (POLST) paradigm for their one-hour virtual workshops equipping healthcare professionals with knowledge and resources to begin using POLST in Arizona. Register here.

Oct. 29-31 – 2025 Arizona Hospital Leadership Conference
The 2025 Arizona Hospital Leadership Conference will be held at the exquisite Loews Ventana Canyon Resort in Tucson on Oct. 29-31. This will be an inspirational gathering of more than 200 hospital and healthcare executives seeking opportunities for continuing education, meaningful discussion and relationship building. Register by Tuesday, Sept. 9, 2025, to receive an early bird discount.

IN THE NEWS

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