MUSING

The peculiar dynamics of deflationary regulation in healthcare

Given the national conversation about healthcare costs, the question of “what would it look like to actually reduce healthcare spending?” is on my mind a lot lately. This week saw a confluence of news around three recent regulatory attempts to reduce healthcare costs that I thought would be interesting to unpack — the IRA, the NSA, and ACCESS:

The Inflation Reduction Act and drug costs.
As I generally understand the theory of the IRA, Medicare’s massive volume should create negotiating leverage, enabling it to secure meaningful price discounts from pharma. That should help reduce overall drug spending.

To that end, Eliquis, one of the highest revenue drugs in the US, was identified as one of the first ten drugs for the first round of IRA negotiations. Eliquis generated $12.2 billion of revenue in 2023. Medicare negotiated a 56% price decrease with Bristol Myers Squibb, the manufacturer of Eliquis, which would appear on its face to be a win for healthcare costs. In total, the negotiations across the first 10 drugs were celebrated for driving down seniors' spending by an estimated $1.5 billion in 2026, the first year the new prices go into effect. Great!

Given that, it was a bit odd to read in Bristol Myers Squibb’s earnings call earlier this month that it now expects Eliquis revenue to grow by 10% to 15% in 2026.

So, the same year that the IRA goes into effect and will slash the price of Eliquis by 56% in Medicare, Bristol Myers Squibb is somehow still growing revenue generated by that drug from $14.4 billion in 2025 to an expected ~$16 billion, an increase of ~$2 billion, or more than the entire expected savings from the IRA negotiation process. Analysts were apparently pleasantly surprised by this outcome, and BMY’s stock is up ~10% over the last few weeks. Lots of analysts focused on Eliquis in the Q&A, which apparently will see a revenue decline in 2027, driven by going off-patent OUS. By 2030, going off-patent is expected to drive Eliquis revenue down to nearly zero. The benefits of competition versus regulation.

One might ask, how is it possible that an already market-dominant drug sees growth while its price is slashed 56%? This article does a nice job walking through the dynamics at play here. It doesn’t appear that volume increases are driving revenue growth; instead, BMY appears to have changed its approach to list-to-net pricing differences, which more than offset the price decrease. An example of the oddities here… BMY has agreed to reduce the price of Eliquis in Medicaid to zero — literally free of charge! — and somehow that move is apparently actually a boost to BMY profitability because of some inflation rebate dynamic that I cannot claim to fully comprehend.

This is a wild quote to read about what was essentially the poster child drug for the IRA:

All things considered, the Inflation Reduction Act may be the best thing that ever happened to Eliquis.

The No Surprises Act & provider OON billing
Also on the list of regulatory oddities this week is the No Surprises Act, legislation that seemed designed to protect consumers from surprise medical bills from out-of-network providers while bringing more transparency to the market. Great!

There seemed to be some early wins from the NSA, as it drove a handful of PE-backed groups deploying these tactics into bankruptcy early on (Envision and American Physician Partners). Yet here we are now several years later, and other PE-backed groups apparently have figured out how to leverage the Independent Dispute Resolution process to their advantage.

So much so that Centene noted on its most recent earnings call that it is seeing a 1% increase in medical expenses for its ACA population in 2025 due to providers abusing the IDR process. It is now apparently initiating lawsuits against some providers as a result. If I assume Centene’s experience is accurate and representative of the overall exchange population, this would seemingly imply that the IDR process is increasing medical costs on the exchanges by $1 to $2 billion in 2025, driven by a small group of providers leveraging the process to increase the amounts they can charge payors.

Yet again, we have an example of legislation seemingly designed to reduce costs being outsmarted by the industry to drive up costs. It turns out that provider price transparency, while a noble goal, is actually a mechanism for provider groups to charge more. What appears to happen is that providers that have historically been paid lower prices can use the transparency to ratchet up rates, with the result being that the market as a whole is pulled up. Or at least that’s what the IDR process seems to suggest is the case.

The implications for ACCESS & digital health
The examples of NSA and IRA highlight the challenges the government has faced in implementing regulations that actually reduce healthcare spending, despite its best efforts. Companies that understandably want to protect their profit pools can find ways around them.

It was fascinating to juxtapose those conversations this week with the dialogue around the CMMI ACCESS Model, another program seemingly designed to deflate healthcare costs by encouraging the adoption of technology-enabled care and a new associated profit pool. As I mentioned in the newsletter last week, CMMI announced ACCESS payment rates that were lower than many in the industry expected.

It was really helpful to chat with CMMI’s Chief AI & Technology Officer, Jacob Shiff, about the model this week. You can listen on YouTube below (or Spotify, or Apple):

Listening to Jacob articulate the vision here, it very much seems that ACCESS is intended to improve access to high-quality, cost-effective care for a broad swath of the Medicare population, aligned with broader administration efforts to leverage technology to set healthcare on a better financial trajectory.

If ACCESS is successful, it will also create a new profit pool with billions in annual revenue for participants. That seems like a huge opportunity for entrepreneurs and investors to pursue. I’d imagine the “AI will make the marginal cost of care delivery zero” investor/entrepreneur crowd will be all over this opportunity. This is the most interesting aspect of this to me — ACCESS is inviting more competition and the opportunity to create a bigger overall market for digital health, albeit one at a fundamentally different cost structure than it exists today.

The rates seem intentionally set low to be deflationary for healthcare costs. They will necessitate a cost structure that will likely require rethinking approaches from the ground up rather than building on previous generations of digital health for chronic condition management. The labor costs in traditional approaches are too high to make the math work here. Inevitably, this tension will invite reasonable questions about the safety and quality of care provided by the participating companies, as the existing industry pushes back against more technology-centric approaches. It’s an issue that seems both important and very political in nature, as it puts jobs at risk. It will be worth keeping an eye on the outcomes data CMMI reports on participants as part of this. As we’re seeing with the NSA process, visibility into the data is helping people understand what is happening to program outcomes.

Ultimately, it strikes me as a good thing for regulators to be taking swings like this to deflate healthcare costs, encourage competition, and foster greater transparency in the market. The challenges facing these efforts seem fairly straightforward, and if previous attempts are any indication, it’s a steep uphill battle. Healthcare’s profit pools have proven to be quite resilient over time, and shrinking them is hard. If ACCESS is going to be successful in creating a new profit pool for tech-enabled care while also deflating overall costs, it will need to shrink profits somewhere else in the ecosystem.

There are undoubtedly a number of obstacles that make success here a challenge — from model awareness to industry pushback to questions on specific model tweaks — that’s how it goes with efforts like this. But I find myself growing more intrigued by the day in ACCESS as a new attempt here.

Public Markets

This was a relatively quiet week for earnings, ahead of a much busier week ahead (agilon, Alignment, Clover, Evolent, Hims, Privia, etc). Here were a few of the key takeaways:

  • GRAIL, maker of the cancer screening test Galleri, saw its stock plummet 50% on Friday. It reported earnings and shared that it failed to meet the primary endpoint of a major study it has been conducting with the NHS. Management still struck an optimistic tone about the results it saw in identifying more early-stage cancers and reducing late-stage cancer diagnoses, but investors were nonetheless spooked about the commercial implications in the UK and US.

  • Talkspace reported a solid quarter, with its stock up 20%+, as the business appears to be turning a corner, transitioning from a consumer-oriented model to one more focused on B2B healthcare. It hit $230 million in revenue in 2025, up 22% from 2024, while also achieving a 7% Adj. EBITDA margin. Exiting 2026, Talkspace expects to be at mid-teens quarterly adj EBITDA margin. The earnings call emphasized Talkspace’s AI capabilities in mental health and how it is using AI to extend the reach of clinicians, with the expectation that demand for therapists will grow with AI as more people who need mental health support are identified. Consumer revenue accounted for only ~6% of total revenue during the quarter, as Talkspace prioritizes payer and enterprise channels.

  • Community Health Systems traded slightly up after reporting earnings, slightly missing revenue estimates but beating EPS. CHS is at the tail end of a number of divestitures in 2025, which will cause both revenue and Adjusted EBITDA to shrink below 2025 levels. As Martin highlighted in the Slack conversation, it feels like health system performance can be categorized into haves and have-nots at the moment, and while most publicly traded health systems seem to be in the have category, CHS appears to have been operating in the have-not category and has been right-sizing its asset base to move out of that. As CHS nears the end of its planned divestitures, the hope is that its portfolio is in a much better spot moving forward.

Quote of the Week

Beckers featured an excellent read about Scripps Health’s decision to exit the Medicare Advantage market back in 2024 and how it has been paying financial dividends for the organization. The sentiment expressed by Scripps CFO Brett Tande below is fascinating to me — essentially noting his view that MA is such a low margin offering, the only way to make money in it is by vertically integrating:

Two things fascinate me in this case study on Medicare Advantage strategy:

  1. Scripps’ view that it was able to move most of its patients from MA to traditional Medicare + Med Supp, and that it didn’t see any meaningful volume decline. In a scenario where you are losing $75 million on a set of contracts and can exit those and move your patients to new, more profitable contracts, it seems like a no-brainer.

  2. Just a few weeks ago at JPMorgan, I listened to Cleveland Clinic leadership take the opposite side of the argument here, talking about how growing its global cap membership in MA from 46k in 2026 to 125k lives in 2028. Clearly its not a settled matter that there is no money to be made for health systems in MA

Needless to say, seems like two very divergent strategies are at play here for health systems with their approaches to MA, with interesting implications for the broader market.

Other Top Headlines

  • In a large M&A deal in the diagnostics market, Danaher announced its $9.9 billion acquisition of pulse oximetry platform Masimo. Masimo is being acquired for $180/share, which is down substantially from its COVID-era high of ~$300/share. Masimo’s recent investor day presentation in December 2025 highlights the state of the business well. Revenue growth had slowed, as its market-leading pulse oximetry offering is driving ~4% - 6% growth per year, while the rest of the business is adding a few additional percent, with the overall business targeting 7% - 10% growth per year.

  • Embattled D2C healthcare company Hims made a big acquisition this week, acquiring Eucalyptus for up to $1.15 billion. Hims appears to be buying international distribution with this move, acquiring ~$450 million of ARR and 775,000 customers in Australia and a few other markets. The investor release notes that Eucalyptus is operating “within line of sight of profitability,” a phrase that does an amazing job of hinting that it might be close to profitability without actually saying anything concrete. If you read the SEC filing, the earnout structure here seems fairly complicated, but essentially, Hims is paying $240 in cash at closing, with a set of guaranteed deferred payments over the next eighteen months and additional earn-out targets based on revenue and EBITDA milestones through 2029. Hims reports earnings on Monday, which will certainly be an interesting session. Even the retail community seems to have soured a bit on Hims in recent weeks and is asking some tough questions of management. Hims stock has traded down another 6% this week, leaving it with a market cap of only ~$3.6 billion, meaning it is trading at only ~1.5× 2026 projected revenue.

  • First Cressey Ventures announced a new $425 million fund, its fourth fund. Cigna, MedStar, and OhioHealth were mentioned as strategic LPs in the fund. FCV notes that Funds I and II rank in the top 5% of all VC funds for performance relative to their vintages, an impressive performance to be sure. The fact that Fund III isn’t mentioned in that sentence probably says a lot about the performance of digital health funds more generally in that vintage — Fund III was announced in April 2022.

Funding Announcements

Manager, Population Health at Town Square Health, a value-based care model serving Medicare patients. Learn more.
$100K - $115K | Remote or Hybrid (Chicago preferred)

Regional Director, Tennessee at Diana Health, a network of women’s health practices. Learn more.
$130K - $150K | Remote (Nashville preferred)

Third Way Health, an AI-enabled medical practice and payer operations solution, is hiring for the following roles:

  • Founding Client Success Manager $95K - $140K | Remote. Learn more.

  • Marketing Specialist (Part-Time) $55 - $65/hour | Remote. Learn more.

Lead Product Manager at Big Leap Health, an AI-enabled platform helping outpatient providers offer in-network mental health services. Learn more.
$160K - $210K | Hybrid (NYC) 

Contact us to feature roles in our newsletter.

Chart of the Week

A white paper from Wakely examined Medicaid MCO profitability between 2019 and 2024, based on NAIC data for 170 health plans that reported financials in all years of the period, which accounted for 63% of MCO membership in 2023.

It is wild to see the underwriting margin for that entire group of payors go meaningfully negative in 2024. Keep in mind that all the public payers talk about 2026 as the “trough year” for Medicaid profitability, which would seem to imply that the margin number on the chart below isn’t getting better for at least a few years.

What I’m Reading

Clinical Al: Evidence and Policy Requirements for Scaling Adoption by PHTI
A good read from an industry session offering some thoughts on how to drive AI adoption for hypertension and mental health. Nothing groundbreaking, but a good summary of thinking about evidence standards, performance benchmarks, etc., that would be useful for deploying clinical AI. Read more

Navigating Cell And Gene Therapy Risk In Medicaid: Lessons From The States by Will Shrank, Bruce Greenstein, and Hannah Katch
A Health Affairs article describes the challenges Medicaid programs are likely to face with cell and gene therapies, along with the opportunity for private sector partners to help states manage them. Read more

Primary care is in trouble. Doctors are banding together to increase market power by Karen Brown
An interesting read on the merits of Independent Practice Associations as a path forward for independent primary care, focusing on Valley Medical Group's experience in western Massachusetts. Read more

Before You Cry ‘Fraud’: What DOGE’s Open-Source Medicaid Data Is (and Isn’t) by Jocelyn Guyer, Avi Herring, and Laura Nolan
A helpful perspective on the Medicaid dataset that was released last weekend, what's in the dataset, and how roughly 80% of total Medicaid spending isn’t in it, and some of the conclusions being drawn from it are wrong. Read more

Beyond Minnesota: Four Medicaid Services Vulnerable to Fraud and the Case for Stronger CMS Enforcement by Chris Medrano and Brian Blase
A Paragon Institute report examines four areas with a high risk of fraud nationwide in Medicaid — home and community-based services, emergency medical transport, ABA therapy, and substance use disorder treatment. Read more

‘We Don’t See Savings’: Indiana Medicaid Restructuring Bill Draws Pushback by Casey Smith
This article highlights how the Indiana Pathways managed Medicaid program has apparently faced several obstacles during its rollout. There is currently a tense debate in the state over a proposed bill that would move long-term nursing stays back to FFS Medicaid in an effort to drive savings. Read more

HTN Radio

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