Weekly Health Care Policy Update – June 5, 2026

June 12, 2026

In this update:  

  • Trump Administration
    • White House Issues EO Backing Changes to Pediatric Vaccine Schedule
    • Trump Administration Issues Proposed Rule on Grantmaking
  • Federal Agencies
    • CMS Announces that MFN Deals Terminate at Administration’s End
    • CMS Issues Interim Final Rule on Medicaid Community Engagement Requirements
    • CDC Releases Report Showing 8.3% Uninsured Rate in 2025
  • Other
    • Nursing Associations Sue Education Department Over Loan Rule
    • Paragon Report Estimates 2026 ACA Improper Enrollment at 27%
    • Commonwealth Fund Releases 2025 Affordability Survey
  • New York State
    • DOH Issues Proposed Physician Reporting Requirements for Medical Aid in Dying

Trump Administration

White House Issues EO Backing Changes to Pediatric Vaccine Schedule
On May 29th, the White House issued an Executive Order, “Realigning United States Core Childhood Vaccine Recommendations with Best Practices from Peer, Developed Countries.” The EO signals President Trump’s endorsement of HHS Secretary Kennedy’s revised pediatric immunization requirements issued earlier this year. At the time, the CDC reduced the number of recommended pediatric vaccines from 17 to 11. The EO directs the CDC and its Advisory Committee on Immunization Practices to review the “scientific assessment” that led to the updated recommendation and take “appropriate steps” to update the schedule to align with its findings.
 
However, in March of this year, the American Academy of Pediatrics (AAP) and other medical groups sued HHS over the vaccine changes, and a federal judge in Boston ruled in their favor, temporarily blocking ACIP and the new schedule. As a result, the new EO has little practical effect.
 
The EO is available here.
 
Trump Administration Issues Proposed Rule on Grantmaking
On May 29th, the Office of Management and Budget (OMB) issued a proposed rule that would make significant changes to the Uniform Guidance governing federal grants, cooperative agreements, and other forms of federal financial assistance. The proposal is intended to increase federal oversight, accountability, and alignment with Administration priorities across grant programs. The rule would clarify OMB’s role in setting uniform, legally binding policies related to financial assistance across agencies, and also centralize the publishing of funding opportunities on grants.gov. Key provisions would require senior political appointees to review discretionary awards before issuance, allow agencies greater authority to terminate existing awards that no longer align with agency priorities or the national interest, and expand oversight of recipients’ compliance with federal requirements. The proposal would apply government-wide, including to NIH, CDC, FDA, HRSA, and other HHS funding programs.
 
Researchers, universities, and scientific organizations have raised concerns that the rule could reduce the role of peer review and increase executive office influence over funding decisions, while the Administration argues the changes are necessary to improve transparency, prevent waste, and ensure taxpayer dollars support lawful and Administration-approved activities. Stakeholders are also concerned that federal agencies would be permitted to terminate grants “for convenience,” a lower bar than the current guidance that researchers are not “effectuating agency priorities.”
 
The proposed rule is available here. Comments are due July 13th.

Federal Agencies

CMS Announces that MFN Deals Terminate at Administration’s End
On June 2nd, CMS Administrator Oz announced that the “most favored nations” deals the Trump administration has made with 17 pharmaceutical companies are scheduled to expire at the end of Trump’s term. The deals have allowed select drugs from major pharmaceutical manufacturers to be available for direct-to-consumer purchase at discounted rates. He encouraged Congress to codify the policies in the agreements to extend their applicability. Oz also announced that 160 additional drugs have been added to the TrumpRx website, bringing the total number of available drugs to over 800.
 
CMS Issues Interim Final Rule on Medicaid Community Engagement Requirements 
On June 1st, CMS issued an interim final rule implementing the Medicaid community engagement requirements of the One Big Beautiful Bill Act. The OBBBA requires certain adult Medicaid beneficiaries – in states that expanded Medicaid – to meet an 80-hour per month work requirement as a condition of eligibility. States are generally required to implement the policy no later than January 1, 2027, though they may implement the provisions earlier at their discretion. The policy was originally estimated to reduce federal Medicaid spending by $326 billion and reduce Medicaid enrollment by 5.3 million over ten years. A brief issued by HHS alongside the rule estimated that the policy would “reduce poverty” by 1.6 to 2.9 million people.
 
Key provisions of the interim final rule include: 

  • Application: The rule’s work requirements apply to non-pregnant adults between the ages of 19 and 64 eligible for Medicaid who are not entitled to or enrolled in Medicare, in states that have expanded Medicaid. These include low-income individuals (up to 133% FPL) and those eligible under a section 1115 waiver demonstration. Exempt individuals include those who are pregnant or in a postpartum period, disabled or medically frail, former foster care youth, veterans with a total disability rating, parents and caretakers of children under 14 years of age or people with disabilities, American Indians and Alaska Natives, participants in a drug or alcohol rehabilitation or treatment program, inmates of a public institution, or individuals who meet the TANF work requirements or are a member of a household receiving SNAP benefits and are not exempt from the SNAP work requirements.
  • Medically frail: “Medically frail” generally includes individuals who are blind or have disabilities, have a substance use disorder or disabling mental disorder, those with a physical, intellectual, or developmental disability, or those with a serious or complex medical condition. States may not add additional categories to the definition but have some flexibility as to the definition of “serious or complex medical conditions.” The rule suggests that such serious conditions may include cancer, ESRD, viral hepatitis, sickle cell, COPD, HIV/AIDS, cognitive impairment, heart disease, ALS, Parkinson’s, Huntington’s, sarcoidosis, cystic fibrosis, multiple sclerosis, spinocerebellar ataxias, muscular dystrophy, hemophilia, trauma disorders, and Thalassemia major. Notably, the rule goes beyond the statutory language on frailty, requiring such medical conditions to “significantly impair” an individual’s ability to work. CMS does not expect diagnoses such as asthma, hypertension, anemia, generalized pain, pre-diabetes, Type I or II diabetes, obesity, psoriasis, headaches, and ADHD to impair an individual’s ability to work to the extend needed to qualify, though in extreme circumstances or in conjunction with other conditions it may be possible.
  • Self-Attestation: Individuals newly enrolling or renewing on January 1, 2027 will be able to self-attest to their medical frailty. However, beginning in 2028, individuals can only self-attest once, after which they will need formal documentation to prove eligibility.
  • Short-Term Hardship Exceptions: States may also offer hardship exceptions in specific circumstances, including for individuals receiving inpatient or other medical services, those requiring medical care outside their community, those in a county with an unemployment rate at or above 8% (or 1.5x the national average), or residents of national emergency or disaster areas where that condition affects residents’ ability to work. States choosing to allow hardship exemptions must allow all federally specified types. At least 26 states are expected to offer the exemptions.
  • Qualifying Activities: Individuals will be required to demonstrate 80 hours per month of qualifying activities including employment, participation in certain work programs, community service, or enrollment in an educational program at least half time. These activities may be combined to meet the 80-hour requirement. Individuals may also meet the requirement by earning at least 80x the federal hourly minimum wage ($580 per month in 2026). New program applicants must meet the requirement for at least one month prior to application. Existing beneficiaries must meet the requirements for at least one month between renewals.
  • State Verification: States must verify compliance at application and renewal, and may conduct more frequent verifications. States determine how many months an individual must meet the requirement. States must send notices of noncompliance if they cannot verify fulfillment of the requirement, and provide 30 calendar days to demonstrate compliance or proof of an exemption. Individuals failing to do so can be denied or disenrolled from Medicaid, but can reapply at any time.
  • State Role: State implementation of the requirement must include identifying individuals for work requirement eligibility and exceptions, verifying individuals’ requirement fulfillment at application and renewal, providing outreach and notice to affected populations, taking “defined steps” when individuals are noncompliant or when compliance cannot be verified, and submitting data to CMS to support monitoring and program integrity.

The interim final rule becomes effective on July 31st. The interim final rule is available here and will remain open for comment through July 31st. A fact sheet is available here. The HHS brief estimating poverty reduction is available here.
 
CDC Releases Report Showing 8.3% Uninsured Rate in 2025
On May 28th, the CDC released early estimates from its National Health Interview Survey, finding that the uninsured rate in 2025 was 8.3%, just slightly higher than the 2024 rate of 8.2%. This was prior to the loss of enhanced premium tax credits in 2026. The uninsured rate among children (ages 0-17) increased slightly, from 5.1% in 2024 to 5.6% in 2025. Still, children have the second lowest rate of uninsurance; adults aged 18-64 have the highest rate at 11.6%, while adults aged 65 and older have the lowest rate at 0.7%.
 
Most adults aged 18-64 (69.4%) had private health insurance coverage in 2025, while 21% had public coverage. Notably, 2025 saw a meaningful increase in individuals younger than age 65 with ACA exchange-based coverage, which grew from 4.3% in 2024 to 6.4% in 2025. Most children (57%) had private health insurance coverage while 40% had public coverage.
 
The CDC report is available here.

Other

Nursing Associations Sue Education Department Over Loan Rule
On May 29th, the American Nurses Association and nine other health care organizations filed a lawsuit against the Department of Education challenging a rule issued on April 30th tightening the federal student loan system to comply with provisions of the One Big Beautiful Bill Act. The rule limits the amount of money that “professional degree” students can borrow to $50,000 annually (or $200,000 in aggregate) and to $20,500 annually (or $100,000 in total) for all other graduate students. The rule, following the OBBBA, also leaves many fields out of the definition of “professional,” including nursing. The plaintiffs argue that excluding nurses is unlawful and violates the Administrative Procedures Act, and that the Department failed to engage with public comments.
 
The formal complaint is available here.
 
Paragon Report Estimates 2026 ACA Improper Enrollment at 27%
On June 2nd, the Paragon Health Institute released a report examining improper enrollment in Affordable Care Act (ACA) Marketplace coverage during the 2026 open enrollment period. Using exchange enrollment data and Census Bureau population estimates, the report estimates that approximately 6.2 million Marketplace sign-ups – or roughly 27% of all exchange enrollments – were improper, resulting in up to $25 billion in excess federal subsidy payments. Paragon estimates improper enrollments as the number of people signed up in the lowest-income category (who receive the highest level of federal subsidies to purchase insurance) that exceeds the number of potentially eligible Americans in that income category across states. The authors argue that generous premium subsidies, widespread availability of zero-premium plans, weak income verification processes, automatic re-enrollment policies, and the actions of some brokers and enrollment intermediaries have created incentives for individuals to overstate income or be enrolled without their knowledge. Nationally, the report finds that improper enrollment remains concentrated in a small number of HealthCare.gov states, particularly Florida and Texas, which together account for 63% of the total.
 
The federal government recoups improper subsidy payments at the end of the year if an enrollee’s income is higher than estimated, or falls below 100% of FPL rendering the enrollee ineligible for premium tax credits. However, there are limits on recoupment and the full amount is generally not collected.
 
The report is available here.
 
Commonwealth Fund Releases 2025 Affordability Survey 
On June 4th, the Commonwealth Fund released its 2025 Affordability Survey, “How Health Insurance Coverage Denials Affect Americans.” The report includes data from a nationally representative sample of 6,353 adults, ages 19 to 64, with employer or ACA Marketplace insurance, from July through October 2025. The report also includes data from eight online focus groups of privately insured adults. Overall, one in five adults surveyed reported that they or a family member had experienced an insurance coverage denial of recommended care in the past year, either before or after the coverage was provided. Over 40% of those experiencing a denial said the denial led to a delay in medical care, and 28% said the denial caused a health problem to get worse. Almost 70% of surveyed adults said the denial resulted in higher costs for them or their household. Only half of those denied care appealed the decision.
 
The full report is available here.

New York State

DOH Issues Proposed Physician Reporting Requirements for Medical Aid in Dying
On June 3rd, the New York State (NYS) Department of Health (DOH) issued proposed regulations that establish physician reporting requirements for the State’s Medical Aid in Dying (MAID) law. The law, signed by Governor Hochul in February and effective August 5th, allows terminally ill New Yorkers with less than six months to live to make a voluntary, informed decision to request medication for medical aid in dying.
 
Under the proposed regulations, an attending physician who prescribes medication for MAID would be required to report information to DOH within five days of issuing the prescription, including information related to the patient’s illness or condition, prescribed medication, patient demographics, care setting, county of residence, and provider compliance with statutory requirements. The proposed regulations also require MAID prescriptions to include a “MAID” designation and specify that the prescription may not be filled until five days after it is written. Death certificates must list the underlying terminal illness or condition, not the MAID medication, as the cause of death.
 
Physician participation in MAID is voluntary. A health care provider who declines to honor a patient’s request for MAID must arrange for transfer of the patient.   
 
The DOH press release is available here. The proposed regulations are available here. Comments may be submitted to regsqna@health.ny.gov through August 3rd. Guidance and additional resources on MAID will be forthcoming from DOH.