The first 100 days of the new Trump administration have been marked by numerous executive actions, many of which have significantly impacted—or have the potential to impact—healthcare organizations’ finances. Notably, executives responding to our 2025 Mindsets survey identified regulatory and reimbursement restructuring as a top concern in 2025. As a result, a growing number of executives are approaching reimbursement as a strategic function of their organization—72% in 2025 compared to 64% in 2024.
Acting strategically within this dynamic environment is critical to maintaining regulatory excellence—a core capability for Achieving Health identified in our Market Point of View. As healthcare organizations determine how best to respond to the administration’s actions, it’s helpful to step back from the specific changes put forward and look at a few key themes. Organizations with strong regulatory functions can use these themes to better understand the landscape and prepare for future changes.
Theme 1: Revisiting Prior Policies
Healthcare organizations can better understand and anticipate the new administration’s executive actions by reviewing policies from the first Trump administration. As of March 20, President Donald Trump has signed 19 executive orders1 directly related to healthcare. These include orders on price transparency and immigration, both of which are familiar topics from Trump’s prior term.
Price Transparency
On February 25, 2025, Trump issued an executive order requiring that within 90 days, the secretaries of treasury, labor, and health and human services take steps to require the disclosure of actual prices for healthcare services, issue additional regulations to help ensure pricing information is comparable, and increase enforcement actions for noncompliant organizations. Forvis Mazars took a closer look at the executive order here.
CMS has already ramped up price transparency enforcement. It has fined twice as many hospitals as of February 2025 (seven) than it fined in all of 2024 (three).2 However, the average penalty has decreased significantly, suggesting that smaller facilities are being penalized. Based on the executive order, it is likely that a forthcoming rule from CMS will propose increased penalties for noncompliance and reduce hospitals’ opportunities to cure alleged instances of noncompliance. It may also revise hospitals’ options for complying with the shoppable services requirements.
To prepare for coming changes, healthcare organizations first need to take steps to test their compliance with existing requirements and come into compliance with any new requirements finalized in the anticipated rulemaking. Second, organizations that understand how to harness price transparency data can use it for benchmarking against competitors and peers, which may reveal opportunities to renegotiate rates or develop a competitive pricing strategy, helping to improve financial performance.
Public Charge
During the first Trump administration, the U.S. Department of Homeland Security (DHS) finalized a rule that included the use of non-cash benefits such as Medicaid and the Children’s Health Insurance Program (CHIP) as factors that indicate an individual seeking permanent residency in the U.S. is a “public charge.” Being labeled a public charge makes it more difficult for immigrants to obtain a green card or temporary visa. The Biden administration rescinded the rule; however, while it was in effect, enrollment in Medicaid and CHIP by individuals in impacted communities was noticeably lower.3
On February 19, 2025, Trump issued a new executive order entitled “Ending Taxpayer Subsidization of Open Borders,” which likely opens the door to reinstate a similar policy in a future DHS proposed rule. For providers in affected communities, such a policy could exacerbate challenges with patient collections—which was already noted as a top revenue cycle challenge by 61% of executives responding to our 2025 Mindsets survey. Hospitals can be proactive by developing a comprehensive patient liability strategy and reviewing their financial assistance policies, which can help increase realized revenue, reduce bad debt, and increase patient satisfaction. In addition, 340B hospitals located in impacted communities that are close to the qualifying threshold may want to consider strategies to enhance the likelihood of continued eligibility for the program.
Theme 2: Follow the Litigation
Many of the Trump administration’s new policies have been challenged in federal court and subjected to an injunction barring implementation. Two examples that would directly impact healthcare organizations are the attempted temporary freeze on federal grant funding and efforts to reduce indirect cost reimbursement for National Institutes of Health (NIH) research grants.4 In both instances, a federal district court imposed a nationwide injunction on the policies.
While healthcare organizations should continue following these cases, there is a non-healthcare case that could limit federal district court judges’ ability to issue nationwide injunctions. The Trump administration is asking the U.S. Supreme Court to limit federal district court judges’ ability to impose injunctions blocking the administration’s executive orders (or regulatory changes) nationwide. At the macro level, if the Supreme Court sides with the president, administrative policy changes may apply immediately to jurisdictions or impacted entities that are not party to the case where a federal district judge has applied an injunction.
Regarding the temporary federal grants freeze, healthcare organizations should analyze the list of grants targeted for review to identify their potential exposure if the Supreme Court limits federal district court judges’ injunction ability or the courts ultimately decide in the administration’s favor on this issue. While the administration has rescinded the implementing Office of Management and Budget memo, the White House has claimed the executive order underpinning the policy is still in effect,5 suggesting the administration may revisit this policy in the future if it survives the legal challenges.
The NIH research grant funding cap also reflects a similar policy during Trump’s first term. It is reasonable to assume the administration may try again if the current effort fails. The injunction order issued in March clearly articulated the legal issues with the administration’s attempt,6 which may provide a road map for constructing future efforts that are more likely to survive a legal challenge.
Given the potential for reductions in NIH indirect cost reimbursement, academic medical centers should focus on improving operational efficiency. Our 2025 Mindsets survey found that efficiency is a top priority for 57% of executives, and that many organizations have opportunities to improve by targeting initiatives that balance financial performance, throughput, and outcomes in overlooked areas.
Theme 3: Value-Based Refocusing
In March 2025, the CMS Innovation Center eliminated four existing models (Maryland Total Cost of Care, Primary Care First, ESRD Treatment Choices, Making Care Primary) and two models in the planning stage related to pharmaceuticals (Medicare $2 Drug List, Accelerating Clinical Evidence) and announced it is considering scaling back an additional model (Integrated Care for Kids). In its notice, CMS acknowledged that because the ESRD Treatment Choices model is mandatory, the agency would conduct subsequent rulemaking to officially cancel the model.
Notably absent from the list of canceled models is the Transforming Episode Accountability Model (TEAM), the mandatory Medicare bundled payment model finalized in the 2025 Inpatient Prospective Payment System (IPPS) final rule. While there had been speculation that TEAM would not move forward under the new administration, the IPPS proposed rule for 2026 signals the model will commence as planned on January 1, 2026.
Selected hospitals should prepare for TEAM by using Medicare claims data to conduct a current state assessment of their performance in the model and develop an implementation playbook that helps them take advantage of opportunities to improve patient outcomes and performance.
How Forvis Mazars Can Help
Our professionals at Forvis Mazars are committed to helping healthcare organizations achieve and maintain the regulatory excellence required to understand and adapt to the impact of evolving federal policies and congressional legislation. If you have questions about upcoming policy changes and how they may affect your organization, please reach out to a professional on our team.
- 1“Trump Administration Executive Order Tracker,” mcdermottplus.com, March 20, 2025.
- 2“CMS Ramping Up Enforcement of Hospital Price Transparency Rule,” modernhealthcare.com, March 25, 2025.
- 3“With Public Charge Rule Looming, One in Seven Adults in Immigrant Families Reported Avoiding Public Benefit Programs in 2018,” urban.org, May 21, 2019.
- 4“Injunction Granted on Policy Change That Would Hamper Funding for Teaching Hospitals,” hfma.org, March 10, 2025.
- 5“White House Aide Says Spending Freeze Isn’t Being Rescinded Despite Memo,” thehill.com, January 29, 2025.
- 6“NIH’s Mandatory 15% Indirect Rate – Next Steps Following Preliminary Injunction,” mwe.com, March 6, 2025.