By Brian Kaminski, Managing Director, Co-Founder, Health Practice Chair
As Washington rapidly moves into the post-election transition to a second Trump Administration, here are five health policy insights, considerations, and developments the Rational 360 Health Care team will be keeping our eyes on:
#1 – Lame Duck Opportunity for Bipartisanship, Health Policy Deck-Clearing.
The lame duck session will feature debate and bipartisan negotiations around a range of health policy issues, potentially including the physician fee schedule, site neutrality, prior authorization, telehealth, the BIOSECURE Act, and PBM reform. For some retiring members of the Republican Doctors Caucus, this will be a legacy issue. And incoming members of the Trump Administration may be eager to clear the decks before they introduce their own priorities next year.
#2 – Make America Healthy Again (MAHA) Creates New Health Policy Center of Gravity.
President-elect Trump has repeatedly signaled the influence that Robert Kennedy Jr. and his ‘Make America Healthy Again’ (MAHA) movement will have over health policy, which could include a reconsideration or reshaping of federal health agencies, food policy, water fluoridation, approach to chronic illnesses, or even existing liability protections for vaccine makers. The real measure of MAHA’s impact in the early days of the Administration may be its ability to effect personnel, both at the leadership level – even with a comfortable Republican Senate majority some of the more controversial figures may have difficulty being confirmed – and with other significant appointments.
#3 – A Mixed Bag for the Pharmaceutical Industry.
Republican-controlled government will give the pharmaceutical industry an opportunity to drive proactive policy priorities such as PBM reform and to pursue industry-preferred fixes to pieces of the IRA. The threat of expansion of the Medicare Drug Price Negotiation Program is diminished, and the Trump Department of Justice (DOJ) will be in the uncomfortable position of defending the controversial program – which every Republican member voted against – against industry challenges in court. However, the new influence of Make America Healthy Again (MAHA) will give a mainstream platform to anti-vaccine and anti-science rhetoric, and the industry may again have to play defense against President Trump’s populism on drug pricing, which, during his first administration, resulted in support for insulin price caps and the exploration of policies such as drug importation and ‘most favored nation’ drug price controls.
#4 – Who Will Replace Lina Khan at the Federal Trade Commission (FTC)?
After an aggressive tenure that included efforts to ban noncompete agreements, challenges to pharmaceutical patent practices, blocking health system acquisitions, and investigations into pharmacy benefit managers (PBMs), the healthcare industry will be watching for the appointment of a new FTC Chair to replace antitrust regulator Lina Khan. It is not a given, however, that the new Chair will be a more traditional conservative who marks a return to the consumer welfare standard. Instead, it could be a Republican populist – a so-called “Khanservative” – who, like JD Vance, shares Khan’s skepticism of mergers and big business, particularly in tech.
#5 – Revisit or Reshape, but Not Repeal (the ACA).
Although there appears to be little appetite to revisit efforts to repeal the Affordable Care Act (ACA), President Trump and congressional Republicans will have opportunities to reshape the law, which could result in significant changes to ACA marketplaces. Most immediately, congressional Republicans will consider whether to extend ACA subsidies that kept premiums low, which are set to expire at the end of next year. Allowing the subsidies to sunset would increase premiums and ultimately cause many to drop coverage.
The Rational 360 team will continue to monitor the transition and its health policy implications. If it would be helpful to talk through your 2025 strategy, the changes we are recommending companies consider, and ways to reach Trump administration decisionmakers, please complete the form below.
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