2025 was a year of nonstop movement in Washington, D.C. Sweeping federal proposals, regulatory changes, and an unprecedented government shutdown created constant turbulence for providers, insurers, and patients. While not every initiative became final policy, the debates and decisions of 2025 have set the stage for major shifts coming in early 2026.
As Congress heads into recess, here are the key federal developments impacting healthcarec and pharmacy, and what to expect next.
The One Big Beautiful Bill Act (OBBBA)
Passed in July, OBBBA brought major changes to healthcare financing and safety-net programs. For pharmacists, these shifts signal a more uncertain coverage environment where access, affordability, and continuity of care may vary significantly across states.
Key provisions include:
Large reductions in federal Medicaid funding
New work requirements for Medicaid and SNAP
Restrictions on state financing mechanisms
Competitive grants to support rural and underserved communities
Expanded behavioral health and chronic disease management initiatives
Eliminates the Grad PLUS Loan program, a major source of funding for PharmD students
Released by CMS on October 31, 2025, the CY PFS Final Rule outlines policy updates beginning January 1, 2026. The rule reflects CMS’s ongoing shift toward value-based, team-based, and digitally supported care.
Reimbursement increases across most Medicare services
New G-codes supporting behavioral health and advanced primary care management
Continued momentum toward value-based care arrangements
Major telehealth updates integrated across services
Adjustments to Merit-Based Incentive Payment System (MIPS)
Expanded Social Determinants of Health (SDoH) related coding and billing
Why does this matter?
Strengthens team-based care models where pharmacists often collaborate under CPAs or incident-to structures by expanding opportunities to support chronic disease management, medication optimization, and behavioral health integration
Creates pathways for pharmacists working in community-based settings or health equity initiatives to be incorporated into SDoH workflows
Permanent Telehealth Flexibilities (Effective January 1, 2026)
Direct supervision may be provided through real-time, two way audio/visual technology
Removal of frequency limits for inpatient, nursing facility, and critical-care telehealth visits
Temporary Telehealth Flexibilities (Extended through January 30, 2026)
Under the short-term funding bill (H.R. 5371), pandemic-era flexibilities remain in place. Congress must act again in January to prevent these from expiring.
No geographic restrictions for telehealth
Patients may continue receiving telehealth at home
Expanded list of eligible telehealth providers
Audio-only telehealth for certain mental health and evaluation services
Flexibilities for FQHCs and RHCs as telehealth providers
Delayed-in-person visit requirements for mental health telehealth
Why does this matter?
Physician/NP/PA no longer has to be physically on site
Supports rural sites, small practices, and pharmacist-led clinics (especially relevant for pharmacists working in collaborative care teams, FQHCs/RHCs, and models leveraging incident-to billing)
Remote and asynchronous delivery now allowed (extended through December 31, 2029)
New billing codes for virtual sessions to simplify billing and payment pathways
Why does this matter?
For pharmacists, MDPP is often a part of a broader strategy to promote earlier intervention in vulnerable populations, reduce medication burden, and collaborate with primary care teams on diabetes prevention
Expand access for underserved, rural, and mobility-limited Medicare beneficiaries
Government Shutdown
The 43-day government shutdown was one of the year’s most disruptive events. The short-term funding bill (H.R. 5371) restored several expired health programs and extended key telehealth flexibilities, but only through January 30, 2026.
We are now preparing for:
Another funding deadline at the end of January
Potential instability across federal health programs
Possible delays in regulatory rulemaking and implementation
ACIP: Hepatitis B Vaccination Recommendations
The Centers for Disease Control and Prevention’s (CDC) Advisory Committee on Immunization Practices (ACIP) voted on December 5, 2025 to change a longstanding childhood Hepatitis B vaccine policy that has been in place for more than 30 years. ACIP’s recommendations must be formally adopted by the director of the CDC before becoming part of the CDC immunization schedule.
What Changed:
ACIP voted to remove its universal recommendation that all newborns receive the Hepatitis B vaccine at birth
They now recommend shared clinical decision-making between parents and clinicians for infants born to mothers who test negative for hepatitis B
For infants who do not receive the birth dose, ACIP recommends that the first dose be given no earlier than two months of age
Why does this matter?
The change may increase clinical discretion and parent choice, but can potentially lower infant protection and complicate vaccination schedules
Prepare for more shared decision-making conversations with parents about Hepatitis B timing and risk
ACIP is able to change their recommendations, but it is ultimately up to the state to change laws surrounding what vaccines are needed for children to enter into public school and other such requirement.
What’s Coming in 2026: Key Policy Changes to Watch
Inflation Reduction Act (IRA) Drug Pricing
CMS will announce the next round of Medicare drug price negotiations for 2028
Maximum Fair Prices (MFP) for previously selected drugs begin taking effect
Pharmacists should expect more patient questions about out-of-pocket costs
Possible shifts in utilization as plans adjust benefits and formularies
Medicaid & Marketplace Changes Under OBBBA
States evaluating potential coverage reductions and new administrative requirements
Potential impacts on medication access for low-income and underserved communities
New CMS Models & Specialty Care Focus
Preparations begin for the Ambulatory Specialty Model (ASM) launching in 2027
Continued federal emphasis on specialty care cost containment and quality
State-Level Momentum for Pharmacy Practice
Many states are expected to advance legislation related to:
Test-and-treat authority
Contraceptive prescribing
Immunization authority
Technician roles and delegation
Payment and reimbursement reform
Bottom Line for NPhA Members
The federal policies, funding debates, and regulatory shifts of this year will directly shape pharmacy practice, patient access, and health care equity in 2026. As we look ahead, pharmacists must stay engaged and ready to advocate for the patients and communities who rely on us most. Together, we can shape a stronger, more equitable health care future.
Step Into Advocacy with Us!
Complete this month’s policy pulse check survey
Share your advocacy story with Chandler Fullington (chandler.fullingotn@npha.net). All stories are welcome, your voice matters!
If you’ve experienced challenges with reimbursement, medication access, workforce strain, telehealth, or patient care barriers, your story can help inform and influence legislators in the states they represent. These perspectives strengthen our messaging and ensure policymakers understand how their decisions affect care on the ground.
Join the NPhA Legislative & Regulatory Affairs Committee
The National Pharmaceutical Association is dedicated to representing the views and ideas of minority pharmacists on critical issues affecting healthcare and pharmacy, promoting racial and health equity, as well as advancing the standards of pharmaceutical care among all practitioners.
