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Overton Window

August 20, 2026

Welcome to TrustWorks On Call, here with your healthcare business and strategy 411 for the week. If you enjoy our work, please consider forwarding it along to a friend and encouraging them to subscribe.

This week, we go Beyond the Whiteboard to detail the Trump administration's regulatory agenda for healthcare, before Dialing In on the frustrations of carrying your scans on a CD to a neurology appointment. But first the news, starting with the nominee for FDA lead exemplifying how far the Overton Window has shifted on agency appointments under Trump that she seems like a plausible pick. 

Behind the Headlines

Unpacking the forces driving healthcare's biggest stories.

1. Trump names White House policy aide for FDA lead.

  • President Trump selected White House deputy director of domestic policy Heidi Overton, MD, PhD, as his nominee for Food and Drug Administration (FDA) commissioner to replace Marty Makary, MD, who resigned in May. 
  • Dr. Overton, whose resume includes a surgical residency at Johns Hopkins under Dr. Makary and serving as the chief policy officer at the America First Policy Institute, has emerged as the point person for health policy at the White House, where she has managed interagency communications and helped draft health-related executive orders, including last week’s order on vaccines.
TrustWorks Take: An Atlantic profile of Overton from last month paints her as a savvy political operator and the “traffic cop of health policy at the White House,” who frequently positions herself in the middle of factional infighting within the administration. Her relative commitments to pragmatism and evidence-based science (e.g., opposing the outright legalization of peptides, slow walking drug legalization) have led her critics to label her a “bureaucratic institutionalist,” but her ideological commitments, seen in her opposition to the childhood vaccine schedule and medication abortions, keep her within the current Republican orthodoxy. Most importantly, she enjoys the public support of President Trump and Health Secretary Kennedy.
 
She was picked because the White House trusts her, not because she will have a smooth confirmation hearing. She was educated as a physician and scientist, but she left medicine after residency to work in politics, leaving her without the industry, clinical, or managerial experience of previous FDA commissioners. She is aligned with the Make America Healthy Again movement but has plenty of detractors from within, which means she could face scrutiny for being anti-vaccine and not being anti-vaccine enough. With the GOP effectively only holding a one-seat majority in the Senate, the fate of her nomination likely lies in the hands of lame-duck Senator Bill Cassidy, who has already expressed "strong concerns about her nomination." 
 

2. SCAN strikes MA deal with Costco.

  • SCAN Health Plan, a Long Beach, CA-based nonprofit insurer with 460K Medicare Advantage (MA) lives across 6 states, announced a deal with retail giant Costco to sell co-branded MA and supplemental plans.
  • The companies intend to launch these products, which will combine Costco’s pharmacy, vision, and audiology services with SCAN’s health plan offerings, in the coming years.
TrustWorks Take: These are two well-respected, consumer-friendly brands attempting to lean on each other’s strengths. SCAN just hit a growth spurt, having added 127K MA lives last year (a 41 percent increase), and is looking to “transition from being a small regional health plan to a national, not-for-profit [MA] plan.” Partnering with Costco will sweeten SCAN’s plan offerings, with convenient pharmacy, vision, and audiology services presumably networked in. Costco lending SCAN its trusted brand and distribution network, including a broker-free sales channel, may be even more valuable than its healthcare services. 
 
Costco’s side of the deal shows why you can never count these mega retailers out of the healthcare game. A few years ago, we were talking about Walmart Health and its co-branded MA plan with UnitedHealth Group, which involved more care delivery assets than the Costco-SCAN partnership, only for Walmart Health to fold. Just as Walmart drew back from healthcare, Costco stepped in, announcing a telehealth partnership with Sesame in 2023 that has expanded into weight-management programs, and now Costco has its own co-branded MA plan too. These retail giants, including Amazon, will never stop trying different ways to participate in our industry because healthcare, making up nearly one fifth of our economy, is too large a pie for them to not want a piece.
 

3. Epic faces FTC antitrust probe.

  • The Federal Trade Commission (FTC) has reportedly opened an antitrust investigation into electronic health records (EHR) company Epic Systems, over concerns that the company is using its dominant market share to block competitors from accessing patient data.
  • The federal probe is in its early stages and likely years away from any charges filed, but Epic is also facing suits from aggrieved external vendors, former employees with restrictive non-compete agreements, and state attorneys general.
TrustWorks Take: Epic finds itself in hot water because it believes that it can deliver more value by controlling everything for their clients, rather than encouraging third-party vendors to plug in compatible solutions. When a third-party vendor wants to use MyChart data to develop a product that would compete with Epic, the company has an incentive (that it insists it does not act on) to restrict third-party access to data. Although Epic’s strong internal culture has a track record of results, it now finds itself in regulators’ crosshairs because of the emergence of two federal health priorities: AI adoption and data interoperability. Because so much runs through Epic, it risks becoming a chokepoint for health tech advancement, one that apparently warrants an antitrust investigation. Epic has positioned itself at the forefront of the healthcare AI rollout, but it cannot maintain its place by holding its competitors back.
 

Beyond the Whiteboard

Visualizing key trends from the healthcare industry

Trump’s Health Policy Runs Through HHS, Not Congress
With midterm election season upon us and divided government likely waiting for us next year, any meaningful piece of healthcare legislation could be years away. This Congress left its mark on healthcare with $1T of Medicaid cuts from the One Big Beautiful Bill Act, as well as its decision not to extend the enhanced Affordable Care Act subsidies, but the health policy world can now shift its collective attention to the regulatory sphere. 
 
Outside of Health Secretary Kennedy and his personal projects, like vaccines and nutritional guidelines, policymakers at the Department of Health and Human Services (HHS) have pursued a focused agenda aimed at modernizing healthcare at the federal level. To combat ballooning healthcare spending, they have steadily advanced site-neutral payments, proposed cutting 340B payments, and introduced prior authorization to traditional Medicare. To facilitate technology adoption, they have taken a hands-off approach to AI regulation, while promoting and standardizing interoperability frameworks to allow developers better access to health data. Finally, and most (in)famously, they have made a big show of combatting fraud, increasing the funding for and salience of audits, while freezing grants they deem suspect. All of these efforts can continue without Congress, and also notably without about one fifth of the HHS workforce under President Biden. Certain parts of the federal government have been defanged through workforce and budget cuts, but HHS and its subdivisions remain on a mission. 

Dialing In

Sharing insights from our work with clients

Healthcare Consultant Turned Patient Turned Delivery Boy
Last week, my neurology appointment at a large academic medical center (AMC) was preceded by a comically confusing confirmation call, with a well-intentioned but difficult to follow set of instructions for how to navigate the building. There was no opportunity for pre-registration or to verify my insurance, nor was there an invitation to upload relevant health information. That resulted in me wandering through their medical offices carrying my MRI disk I had received from an independent outpatient imaging center that was unable to transmit it to the AMC. I felt less like a patient and more like a delivery boy. I also have no way of getting my primary care physician, who I will be seeing in two weeks, to talk with my neurologist, so I am playing messenger boy between them as well. 
 
I’m sharing my frustrating experience not because it was exceptional, but because it is all too common. Just over a year ago, CMS launched its Health Technology Ecosystem aimed at improving communication and data sharing between providers and patients, including a “Kill the Clipboard” campaign to replace paper intake forms. These efforts are largely voluntary and will take some time to trickle into everyday use (if ever, given how far behind my local AMC appears to be), but the need for them is so glaring. When the onus is on the patient to ferry medical records from one provider to another, or to coordinate their own care across initial visits and follow-ups, the patient becomes the interoperability layer. This manifests as not just an IT problem but a barrier to quality and accessible care.