The presidential campaign trail has been full of talk about Project 2025 set of conservative policy proposals created by the Heritage Foundation, a conservative think tank. Project 2025 is controversial not just because of the conservative positions it takes, but also because of how detailed it is in presenting these policies. The Heritage Foundation created Project 2025 as a template for how a new Trump Administration could quickly implement a conservative agenda.

Vice President Harris’ campaign is trying to tie former President Trump to what it characterizes as an “extreme” set of policies. However, former President Trump has publicly distanced himself from the project (going as far as calling much of the document “ridiculous”) and claims to have no knowledge of who is behind the policy initiative. Rather, Trump has formally endorsed a policy agenda known as “Agenda 47,” on his campaign website.

Given Project 2025’s high exposure in the news, this week’s featured topic will summarize the health policy provisions of Project 2025. The health section was authored by Roger Severino, who served as Director of the HHS Office of Civil Rights (OCR) in the Trump Administration.

Abortion and Reproductive Health

Much of Project 2025’s HHS section focuses on abortion and reproductive health. Specifically, Project 2025 calls for a Republican President to use their full authority, along with Congress, to achieve the most robust pro-life policies possible. Additionally, it calls for the FDA to rescind its approval of mifepristone and misoprostol, two abortion pills which can be prescribed via telehealth and delivered to patients. Project 2025 also proposes ending the protection of abortion-related medical records from criminal investigations if the individuals to whom those records belong cross state lines.

Publicly Funded Health Insurance Offerings

Project 2025 seeks to completely alter the Medicare landscape by strongly emphasizing private Medicare Advantage of traditional Medicare. Most notably, Project 2025 states that Medicare Advantage should be the “default enrollment option” for Medicare beneficiaries.

Project 2025 proposes reforming Medicare with various legislative proposals. The Heritage Foundation calls for expanding site-neutral payments and to ensure payments are based on the health status of the patient or intensity of the service. Site-neutral payment policies would pay off-campus hospital outpatient departments the same (lower) rate independent physician practices receive under the Medicare Physician Fee Schedule. Site-neutral payments are already in place for many off-campus outpatient departments but there is still an opportunity to expand this policy to facilities that are exempt from that policy.

Medicaid financing would be modified to include “a more balanced or blended match rate, block grants, aggregate caps, or per capita caps.”

The policy agenda also proposes creating more alternatives to ACA coverage by codifying an expansion of association health plans, short-term health plans, and health reimbursement arrangements (including individual coverage HRAs) – all concepts championed by the first Trump Administration.

Value-Based Care

Project 2025 calls for Medicare to move towards more value-based care options, arguing that the “government’s use of non-market-based methods to determine reimbursement leads to overspending on low-value services and products and underpayment for high-value services and products.” Project 2025 does not provide a specific proposal for hastening the transition to value-based care, or what such a model may look like.

Telehealth

Project 2025 would upend current telehealth licensing requirements by changing the focus of the telehealth physician to the state in which the provider is located rather than the patient’s location. The current system says the patient’s location is the location for the visit, which means telehealth providers must be licensed in the state where the patient is located (or part of an interstate licensure reciprocity compact). Project 2025’s proposed telehealth plan aligns with in-person medical services.

Physician Issues

Reducing administrative burdens on doctors is one of the four key priorities for the Medicare section. Project 2025 also calls for major changes to the No Surprises Act (NSA) by proposing replacing the Independent Dispute Resolution (IDR) process with “a truth-in-advertising approach.”

Lowering Drug Costs

To help lower drug costs, Project 2025 would prohibit brand-name drug manufacturers from preventing generic manufacturers from producing generic drugs. Project 2025 hopes to restructure 340B drug subsidies are better directed to beneficiaries. The Project advocates for repealing the Inflation Reduction Act (IRA) in its entirety. However, it maintains a version of the IRA’s Part D benefit reform.

CDC Reorganization

Project 2025 offers major changes to the Centers for Disease Control and Prevention (CDC). Under the proposal, the CDC would be split into two agencies: an epidemiological agency tasked with publishing health data and a separate agency tasked with overseeing public health with a limited ability to offer policy recommendations.

Gender-Affirming Care & Discrimination

Project 2025 covers other controversial issues such as reconsidering Biden Administration policies for covering gender-affirming care and rescinding laws that prohibit discrimination on the basis of sexual orientation, gender identity, and transgender status.

It is an important to note that the healthcare focused section of Project 2025 is 54 pages long and this overview is non-exhaustive.

Democrats and/or Vice President Kamala Harris’s campaign has not produced any official policy agenda. If they do before the election, we will certainly cover it in Capitol Insights.

The Fifth Circuit Court has upheld a ruling that strikes down key parts of CMS’s arbitration methodology for resolving surprise medical billing disputes. This decision, challenged by the Texas Medical Association, argues that the methodology unfairly favors insurers, conflicting with the goals of the No Surprises Act. As a result, CMS may need to halt its current dispute resolution process as it considers its next legal steps.

A study conducted by the Commonwealth Fund found that 45% of insured working age Americans received an unexpected medical bill last year.

The Congressional Budget Office (CBO) found that insurance companies merging with pharmacy benefit managers (PBMs) often does not lead to lower premiums for enrollees.

 Starting in September, UnitedHealthcare says it will begin cutting down on prior authorization requirements. They estimate the prior authorization removals will impact 20% of its total prior authorization volume. Additionally, starting on October 1, physicians who earn gold card status will be able to override many traditional prior authorization requirements. Practices who demonstrate a prior authorization approval rate of 92% or higher for two consecutive years will be eligible to participate in the gold card program.

CMS finalized the Transforming Episode Accountability Model (TEAM). The model aims to improve coordination between health care providers during surgery and the month that follows.

CMS approved a North Carolina plan to offer hospitals incentives to eliminate patient medical debt.

A new report has found that a healthcare data breach costs the affected organization an average of $10 million so far in 2024.

The CDC estimates that over 8% of Americans did not have health insurance in the first quarter of 2024, up from 7.7% during the same period last year.

 Medicare finalized a 2.9% payment increase for acute care hospitals in its FY 2025 Inpatient Prospective Payment Systems Final Rule. This was more than the proposed 2.6% increase.

The CBO Director of Health Analysis claimed that expanding site-neutral Medicare payments should not increase costs to private insurers.

A Final Rule released by the CMS creates a new pathway for Medicare to cover some “breakthrough” medical devices. Devices will be covered on a case-by-case basis.