This week, as President Donald Trump begins his second term in office, many physician groups are probably wondering what impact the change in Presidential Administrations will have on various healthcare policy issues and ultimately, their practices. And while there are currently a lot of unknowns and TBDs in this regard, here are several key issues physician groups might want to keep an eye on:
Medicare physician payment reforms
As a result of CMS’s 2025 Medicare physician payment final rule that was released in November 2024, Medicare is set to implement an across-the-board 2.8 percent cut to physicians’ reimbursements this year. Like last year, hopefully Congress will step in and pass legislation early in the year to partially mitigate or eliminate the cut. However, Congress is also likely to look more seriously at legislation that would implement permanent Medicare physician payment reforms. Those could include tying annual payment rate updates to a measure of inflation (like the Medicare Economic Index which would have provided a 3.5 percent boost in 2025) and/or revising aspects of the Merit based Incentive Payment System (MIPS). Through its annual rulemaking process, CMS will also look to make its own changes to physician payment programs like MIPS and the Shared Savings ACO Program, but as of now, it is unclear what those reforms would look like.
Certified EHR technology requirements
In 2023, the Biden Administration finalized its “Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing” final rule, nicknamed “HTI-1”. The rule finalized a new approach for HHS’s EHR certification program that would require EHR developers and providers in federal programs that require the use of a certified EHR (like MIPS and ACOs) to update their EHR systems every year (as opposed to the previous approach which required updates about every 3–5 years. More specifically, HTI-1 set new EHR certification requirements for 2025 and 2026. Then, in the summer of 2024, the Biden Administration proposed an expansive HTI-2 rule to add new requirements for 2026, 2027, and 2028. Despite its best efforts, the Biden Administration did not finalize this HTI-2 rule, meaning the Trump Administration will decide its fate. At stake is the future path for this EHR certification program, which if it remains an “annual update” program, would likely result in significant new annual compliance and technology costs for physician practices.
Price transparency and surprise billing requirements
During the later stages of the first Trump Administration and the early stages of the Biden Administration, HHS focused heavily on the implementation of price transparency and surprise billing regulations. While the price transparency rules primarily impacted payers and hospitals, the surprise billing regulations that stemmed from the 2020 No Surprises Act created new compliance requirements for physician groups. Even though those rules went into effect in 2022, they have never been fully enforced, with HHS announcing in 2022 that they would be indefinitely delaying enforcement of the “co-provider” and “convening provider” good faith cost estimate requirements. It remains to be seen whether the Trump Administration will pursue additional regulations or enforcement actions in these areas, but it is likely given President Trump’s publicly stated interest in and support for these initiatives.
Beyond these issues, action on cybersecurity (in December the outgoing Biden Administration proposed a major rewrite of the HIPAA Cyber Rule) and artificial intelligence (Trump’s team has indicated he will repeal President Biden’s AI Executive Order and institute his own policies), could have big implications for physician groups.
A lot will also depend on policy decisions made by new leaders at HHS and its sub-agencies and offices, including HHS Secretary nominee Robert F. Kennedy, Jr. If he is confirmed by the Senate, the former Democratic Party and Independent presidential candidate would likely focus heavily on pharmaceutical and food safety issues. Broader healthcare system reforms and legislation impacting insurance industry rules and pharmacy benefit managers (PBMs) are also possible. Although physician groups would be unlikely to be directly impacted by any of this, any serious changes impacting pharmaceutical or insurance companies would surely have an indirect or trickle-down impact on physician groups. Lastly, it will be important to see what the new Department of Government Efficiency (which has been tasked with cutting government spending and regulations) has to say about the numerous federal healthcare programs and regulations.
Overall, even though healthcare policy wasn’t a major focus of the 2024 campaign, with these issues and others, the second Trump Administration’s policies have the potential to have a big impact on physician groups moving forward.
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