Health policy activity is not expected to slow down this fall. Several milestones on the horizon will present both challenges and opportunities for healthcare stakeholders seeking to advance their priorities by year-end.

Below is an overview of key issues to watch, their potential implications, and opportunities for engagement.

Government Funding Deadline Looms

• Status: Congress faces another government funding deadline at the end of September. While appropriators had been working to advance several bills through regular order, completion before the deadline is highly unlikely, teeing up another short-term funding patch through a continuing resolution. As of posting, Congress has not yet reached a funding deal with one week remaining until the deadline.
• Implications: There are also several healthcare extender policies, such as Community Health Centers and Medicare telehealth flexibilities, that are typically tied to appropriations or a continuing resolution, so there will be no lapse in funding for these programs. Whatever the path forward, Senate Republicans will need bipartisan support to bypass a filibuster, unlike the reconciliation process over the summer that only required a simple majority vote.

Drug Pricing and Coverage in the Spotlight

• Most Favored Nation (MFN) Executive Order
  • Status: The end of September also marks 60 days since President Trump sent letters to 17 drug manufacturers urging compliance with his May 2025 MFN Executive Order. HHS reports negotiations with 14 companies and, working with the Commerce Department, is using potential pharmaceutical tariffs as leverage to encourage action.
  • Implications: It is unclear what additional administrative actions might follow this upcoming deadline, but with the recent Presidential Memoranda on revisiting requirements related to direct-to-consumer (DTC) drug advertisements, the focus on pharma is not slowing down.

• Medicare Open Enrollment
  • Status: Additional detail on Medicare Advantage and Part D plan offerings for 2026 is expected in the coming weeks leading up to the start of open enrollment, October 15 through December 7.
  • Implications: Based on the national bid and premium amounts announced in late July and news of several notable plan departures from the market, it could be a challenging road ahead for the 2026 plan year with significant disruption and increased costs for patients.

• Medicare Drug Price Negotiation
  • Status: By the end of November, the Trump administration will announce the maximum fair prices (MFPs) for the 2027 cohort of drugs under the Inflation Reduction Act’s (IRA) Medicare drug price negotiation program.
  • Implications: While year two of the program, it is the first year that the Trump administration has driven the process. All eyes will be on whether they secured more significant price reductions relative to the Biden administration for the 2026 cohort of drugs. This will provide an additional data point on what to expect in future years of the program and how progress here might intersect with the administration’s efforts on MFN. With MFPs starting to get picked up by state Prescription Drug Affordability Boards (PDABs), there is the potential for these prices to spread beyond Medicare.

Expiration of Enhanced Affordable Care Act (ACA) Premium Tax Credits

• Status: The enhanced premium tax credits under the ACA are set to expire at the end of this year, and Congress is considering near-term action to extend the credits on a short-term basis. The enhanced premium tax credits were first enacted in 2021 and later extended through the end of 2025 through the IRA.
• Implications: Exchange markets are bracing for an average18% premium increase heading into 2026 if credits lapse. CBO previously estimated that an additional 4.2 million people would become uninsured over the next decade if the tax credits expire, on top of Medicaid changes in the recently passed reconciliation bill that are also expected to increase the number of uninsured individuals. Politically, Republicans face pressure: opposing an extension is unpopular with voters heading into next year’s midterm elections. This dynamic could drive bipartisan support for a short-term extension, potentially as part of the continuing resolution mentioned above.

Where To Head Next?

This fall’s packed health policy agenda presents both risks and opportunities for stakeholders looking to shape outcomes and advance their priorities. Now presents an optimal time to consider any need to refine your engagement strategies, sharpen and target your messaging, and uncover compelling evidence to support policy and advocacy strategies.