Federal and State Policy

As the largest US healthcare payer, the federal government plays a dominant role in shaping the healthcare marketplace, while states take center stage when it comes to developing novel policy approaches. Our experts track, interpret, and model policies that affect insurance coverage, access, and consumer choice so you can see around the bend.

Brooke Fruman

Stakeholder Considerations for IPAY 2028 Guidance

Draft guidance for IPAY 2028 Medicare drug price negotiation includes the first-time inclusion of Part B drugs, refinement to MFP effectuation, and considerations around what qualifies as a single-source drug.

White Paper: Provider Survey on Part B Step Therapy in Medicare Advantage

Step therapy is a form of utilization management increasingly used by health plans, including Medicare Advantage plans, with the stated intent to guide prescribing decisions toward cost-effective, evidence-based therapies.

Avalere Health Experts React to the Most-Favored Nation Executive Order

A new EO revives international reference pricing as a core Trump administration priority, with a focus on Most-Favored Nation pricing through direct-to-consumer models, regulatory action, and broader enforcement measures.

Stakeholder Considerations for MFP Effectuation in Part B

Several pathways exist to effectuate the MFP for Part B negotiation with benefits and drawbacks for stakeholders across the drug supply chain.

Revisiting Medicaid Work Requirements

Federal policymakers are considering Medicaid work requirements as a mechanism to reduce spending; recent state experiences offer important considerations.

PBM Delinking: Policy Considerations

Legislation aimed at changing how PBMs operate, including “delinking” bills, could have unforeseen consequences for drug prices, contracting and competition.

Kylie Stengel

Recent Part D Final Policies Leave Open Areas for Future Action

After the release of the CY 2026 MA and Part D final rules, CMS may take further action on several key policy areas, including anti-obesity medications and premium stabilization.

Video: Unpacking the Final CY2026 CMS Part C and D Rule and Rate Announcement

Avalere Health Advisory experts explore how the Trump Administration approached Medicare Advantage and Medicare Part D policies proposed by the Biden Administration, ranging from anti-obesity medication coverage to plan payment increases

Update: Health Plans’ Perceptions of PDABs and UPLs

In interviews and a survey, health plans communicate concerns with UPLs’ potential impact on patient access, pharmacists, providers, and their own financial positions.

MA and Part D Enrollment Growth Slows in 2025

Year-over-year enrollment growth in MA and Part D slowed in 2025. Although, enrollment in chronic condition special needs plans experienced significant growth.

Haley Payne

Vaccine Policy and Access Under New HHS Leadership

Policy actions in the first days of the Trump administration raise questions about the future role of key vaccine advisory committees.

Mariia Salova

Rare Disease Advisory Councils: Opportunities for Engagement

Stakeholders should seek to engage with RDACs to develop a better understanding of rare disease care access, treatment, and populations in different states.

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