The Trump Administration’s Impact on Healthcare: A 2025 Outlook

12/06/2024
Revelation Partners: Courtney Munley (Associate), Rob Rein (Vice President), Mike Boggs (Partner)
Marwood Group: Jennifer Meyers (Managing Director), Stephen Williams (Director)

With the 2024 election results finally in, it’s time to look ahead at the outlook for the healthcare industry under the new administration. We connected with Marwood Group, a leading healthcare advisory firm, who gave us the scoop on what we can expect under a Trump administration and Republican controlled Congress. Marwood’s Jennifer Meyers and Stephen Williams, who together have a combined 40 years of experience in healthcare policy, gave us the rundown of the key changes to expect. According to Marwood, under Trump’s leadership, the healthcare sector will likely see a blend of deregulation, Medicare and Medicaid reforms, and continued opposition to provisions of the Affordable Care Act (ACA). Here’s a glimpse of what healthcare might look like under the new administration.


Federal Outlook: Non-Traditional Agency Heads Could Deviate From A Traditional De-Regulatory Approach Often Favored By Republicans

With full control of the House and Senate, the Republican party now has significant influence over healthcare policy. Republicans have proposed plans to restructure several federal agencies, including the Food and Drug Administration, National Institutes of Health, and the Centers for Disease Control and Prevention. On top of that, the potential confirmation of Robert F. Kennedy Jr. as Secretary of Health and Human Services (HHS) adds another layer of unpredictability to the mix. Here’s what is on the table for key federal agencies and legislation: 

Food and Drug Administration (FDA)

It’s safe to say that we shouldn’t expect “business as usual” for the FDA under a Trump administration. Trump recently tapped Dr. Martin Makary as the next commissioner. Dr. Marty Makary is a surgeon and author, known for his critiques of the U.S. healthcare system. He has authored several books and writings focusing on what he views as flaws in the system. Dr. Makary is a close ally of RFK Jr., who has promised to strip away industry influence from the FDA and re-focus the agency on chronic disease prevention. As it pertains to drug development, the Trump administration has historically pushed for more flexibility around drug approval standards, a potential tailwind for biopharma, but this could conflict with some of the potential goals of RFK Jr. and Dr. Makary.

Federal Trade Commission (FTC)

Under a Trump administration, the FTC is expected to be more lenient when it comes to healthcare M&A. This is especially true relative to the Biden-era FTC, which was notably aggressive and blocked a number of high-profile mergers including in healthcare. Marwood expects a friendlier FTC to reign under Trump, which could result in an uptick in M&A activity in healthcare.

The Inflation Reduction Act (IRA)

The IRA was introduced in 2022 and aims to curb inflation by allowing Medicare to negotiate prices for certain drugs. However, the IRA has been met with criticism by the pharmaceutical industry for its potential downstream effects on innovation and R&D. While Trump has expressed disapproval of the IRA, Marwood thinks it is unlikely the law will be repealed under his administration. However, Trump may make some tweaks to the law’s implementation.

Access to Healthcare Coverage: Uncertainty for ACA Exchanges and Medicaid

Dr. Mehmet Oz overseeing Medicare and Medicaid wasn’t on our 2025 bingo card, but in retrospect it’s no surprise given Trump’s pattern of unconventional appointments. So how will Dr. Oz and a Trump presidency impact healthcare coverage in the U.S.? Marwood predicts that there will be some puts and takes depending on the government program.

Medicaid

Medicaid is a joint federal-state program that provides coverage for low-income and disabled individuals. Under a Republican administration, Marwood believes we may see an attempt to control costs by way of increased work requirements and tightened eligibility standards. This could result in more uninsured individuals. Cuts to the program could also hurt private insurers, as several states have turned to private insurers to run Medicaid programs.

Medicare Advantage

Medicare Advantage – which are Medicare plans run by private insurers (e.g., United, Humana) – faced headwinds during the Biden Administration. Marwood expects that Medicare Advantage plans, brokers, and risk-based providers are likely to get a boost under a Trump presidency. However, the upside is not likely to be seen until late 2026 or 2027.

ACA Enhanced Subsidies

Enhanced subsidies for Affordable Care Act (ACA) exchange plans are set to expire at the end of 2025. Marwood does not expect the enhanced subsidies to be extended under a Trump presidency, especially given the balance of power in Congress. A Republican White House could also reduce support for the ACA exchanges, potentially making it harder for individuals to enroll in coverage and resulting in a higher uninsured population. However, Dr. Oz’s nomination could be a positive for the CMS approach to existing ACA plans, such as by protecting automatic reenrollment in ACA plans and continuing to allow states to silver load their risk on the exchanges. Overall, Marwood sees a full repeal of the ACA as unlikely.

Potential Reform to Medicare Payments to Physicians

Physician reimbursement under Medicare is governed by the Medicare Physician Fee Schedule (PFS). Marwood anticipates ongoing discussions about the PFS under a Trump administration.

Short-Term Relief for Physicians

In the short term, Marwood expects physicians to achieve some relief to statutory pressure on the Conversion Factor (CF) for PFS codes in 2025. For FY 2025, Congress is likely to provide relief of 1.25-1.5% to the CF, offsetting some of the planned -2.8% CF reduction for 2025 due to implementing the budget neutrality adjustment to the CF. However, this increase will likely only provide temporary relief as that would leave potential residual modest pressure for the CF in 2026 and structural reforms to the PFS are still needed.

Long-Term Reform Efforts

One area where Marwood believes Trump could impact physician pay is in the push for reforms to the PFS, including an annual Medicare Economic Index (MEI), reform of the budget neutrality requirements, among others. RVUs (Relative Value Unit) system, which underpins the PFS, determine how physician services are priced and are based on factors such time required for the service, cost of supplies, and malpractice insurance. Physicians have long lobbied for adjustments to the RVU system, arguing that the current structure does not account for inflation or the rising costs of medical practice. RFK Jr. is rumored to be drafting a proposal that would reduce the American Medical Association’s role in determining RVUs, a disruptive change that could have broad consequences. The implications of such a proposal remain to be seen, but structural reforms to the payment system are likely to be difficult to achieve. Marwood expects discussions around PFS reform to continue under the Trump administration, but the Congressional Budget Office (CBO) score/cost may be a significant barrier.



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