Quadruple 180
February 24, 2026
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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 forecast the next ten years of healthcare volumes growth, and we’re Dialing In on the conflicting incentives limiting GLP-1 adoption.
But first, a programming note before we get to the news. As if commemorating the end of the Winter Olympics, the Trump administration has performed what we have deemed the rare “quadruple 180”— reversing its decision by agreeing to review Moderna’s flu vaccine, getting most of its tariffs struck down by the Supreme Court, dismissing yet another acting CDC director and replacing him with NIH director Dr. Jay Bhattacharya, and (perhaps most impactful to our lives as road-weary consultants) resuming TSA precheck after a threatened pause due to the government shutdown.
We will be keeping a close eye on these developments, but this week we have chosen to spotlight a few lower-profile stories with massive implications for healthcare: |
Behind the Headlines
Unpacking the forces driving healthcare's biggest stories.
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1. Medicare Advantage enrollment growth slows again.
- The Centers for Medicare and Medicaid Services (CMS) published data showing that, as of February 1, 2026, Medicare Advantage (MA) enrollment grew 3.2 percent in the last year, after a 4 percent increase from 2024 to 2025.
- Humana gained 1.2M beneficiaries, the most of any insurer, whereas UnitedHealthcare and Elevance lost 930K and 325K respectively, the two largest declines.
- MA Special Needs Plans (SNPs), which cater to specific chronic conditions, such as chronic heart failure and diabetes, or serve the Medicaid dual-eligible population, helped drive overall MA growth, increasing 12 percent year-over-year, and now cover nearly a quarter of MA beneficiaries.
TrustWorks Take: From 2007 to 2025, MA enrollment averaged 9 percent annual growth, increasing from 8M to 34M, or from 19 percent of eligible beneficiaries to 54 percent. Insurers’ projections of an enrollment contraction this year did not materialize, but two successive years of low and declining growth attest to their shifting perspectives on the program. Facing shrinking per-member profitability amid higher-than-expected utilization and declining reimbursement, large insurers have pivoted by exiting certain markets, tightening supplemental benefits, and focusing on their most profitable plans. As long as MA continues to cost taxpayers more than traditional Medicare, lawmakers and regulators are likely to keep ratcheting up the pressure on insurers. Their hope is that stingier plan payments will incentivize care management efficiencies, but it is easier for payers to tighten networks and claw margins back from providers than to generate cost-savings by proactively managing, say, an 80-year-old with Alzheimer’s disease.
It is also no coincidence that enrollment in SNPs, which receive higher per-capita payments, is rapidly growing at a time when regular MA plans are faltering as a source of insurer profitability. Chronic Condition SNPs (C-SNPs) grew by almost 500K members in 2025, after averaging less than 15K per year from 2019 to 2022, more in keeping with a change in insurers’ diagnosis and enrollment tactics, rather than an underlying change in population health. That UnitedHealthcare is responsible for over 50 percent of C-SNP enrollees, as compared to 29 percent of the total MA market, also suggests some gamesmanship from the recently beleaguered insurer. Expect SNP plans to be a target of increasing Congressional and regulatory scrutiny in response to their sudden proliferation. |
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2. FTC premerger rule in judicial limbo.
- Earlier this month, a district court judge struck down a 2024 Federal Trade Commission (FTC) rule that substantially increased the amount of information merging parties had to submit to regulators, finding that the agency had failed to show how the benefits of the regulation outweighed “its significant and widespread costs.”
- Last week, the Fifth Circuit Court of Appeals intervened to preserve the expanded Hart-Scott-Rodino premerger reporting requirements until at least this Thursday, February 26, while the court considers the FTC’s appeal.
TrustWorks Take: Healthcare mergers, especially among hospitals and health systems, were one of the primary targets of this Biden-era rule, leading the American Hospital Association to join the effort to overturn it. After the rule went into effect in February 2025, hospital M&A activity slowed significantly. (Other market trends and policy changes, along with general environmental uncertainty, have also contributed to this drop. Ironically, the district court's decision to vacate the rule, followed by the circuit court’s temporary stay, has created even more uncertainty to chill dealmaking activity, as merging parties may be advised to prepare documents under both the old and new rules while awaiting the court’s final ruling, or wait for more certainty.
These premerger requirements deterred dealmaking by tripling the hours it took to complete the filing, but they did not change the grounds upon which the FTC can reject a merger. Moreover, increased regulatory scrutiny of mergers is only one tool in the federal toolkit to combat what may be deemed anticompetitive behavior in healthcare. For example, the Department of Justice and the state of Ohio filed suit last week against OhioHealth, a 16-hospital not-for-profit system based in Columbus, OH, alleging that OhioHealth’s insistence on commercial insurance networks including all its providers has harmed policyholders and patients through inflated prices. If regulators cannot stop alleged monopolies from forming, they can still prosecute them for anticompetitive behavior after the fact. Although, in both cases, they do not have an exceptional record of success.
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3. All NYC hospitals reach deals with striking nurses.
- Last Saturday, over 4K nurses at NewYork-Presbyterian/Columbia (NYP/C) hospital voted to end their six-week strike, almost two weeks after the other 10K striking nurses from Mount Sinai Health System and Montefiore Medical Center returned to work.
- NYP/C nurses stayed on strike after the other nurses ratified their contracts because of what they saw as inadequate commitment from the hospital to hire more full-time employees, creating a temporary rift between the striking nurses and union leadership.
- The New York State Nurses Association (NYSNA), which represents the striking nurses, reached an agreement with all three health systems for a roughly 12 percent average salary increase over the three-year contract, as well as “safeguards against artificial intelligence,” commitments to maintain or improve staffing standards, and various other employment protections.
- In related news, the 31K workers striking at Kaiser Permanente facilities in California and Hawaii since January 26 also reached a deal on Monday to return to work.
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TrustWorks Take: Given that NYSNA reportedly opened negotiations requesting ten-percent annual salary increases, the ratified contracts’ four-percent annual salary increases landed somewhere in the reasonable middle. NYSNA is celebrating these contracts as a victory, whereas health systems issued congenial statements welcoming the nurses back to work. What should worry hospital leaders most, more than finding room for this round of wage and staffing increases, is the viability of NYSNA calling for another strike once this contract ends in three years. If it worked so well this time, with picket lines persisting despite record-cold temperatures, what is to stop the union from approaching the negotiating table more emboldened than before? In high-cost cities like New York, where nurses already command far higher salaries than the national average, there will always be a sense of precarity motivating escalating salary demands. |
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Beyond the Whiteboard
Visualizing key trends from the healthcare industry
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Ten Years of Site-Shifting Care Delivery
As gold-medal-game winning USA Olympic-team hockey players Jack Hughes and Megan Keller could tell you, a good strategy requires skating to where the puck is going, not where it has been. This is as true in healthcare as in hockey (even if the our industry moves at a comparatively glacial pace), which is why prognostications like Sg2’s annual Impact of Change Forecast are useful for long-term planning. The slowed growth of inpatient services, propped up by rising acuity in an aging population, and the continued expansion of outpatient services, unlocked by new technologies and regulatory changes, has been central to their forecast for years. The new rising star is home-based care, now projected to grow 32 percent by visit volume through 2035. These low-acuity visits will often be delivered by lower-license nurses to an aging and infirmed population, which will reward businesses focused on scale and efficiency more than sophistication. For most health systems, it would be unwise to ignore this emerging channel. For example, health systems evaluating whether and how to move procedural specialties to ambulatory surgery centers should consider this an opportunity to redirect post-op and follow-up visits to the home setting as a complementary low-cost, consumer-friendly option.
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Dialing In
Sharing insights from our work with clients
The Problem with Diagnosis-Based Reimbursement
Although TrustWorks is mostly focused on the delivery side of healthcare, I can count on and call on many friends and colleagues from “across the aisle,” in the insurance industry, to give it to me straight on how the other side thinks. While chatting the other week with one such colleague, who works near the top of a regional, nonprofit payer, I was not surprised to hear him say that his company is trying to pump the brakes on GLP-1 adoption. To him, “There are far cheaper alternatives, with far lower quit rates, that we prefer our commercial members try first. Even those who stick with them may not stick with us, so we won’t get the full benefit of a well-managed life.” Not my favorite way to think about healthcare, but a familiar argument from those who take seriously insurers’ responsibility to manage costs and “unnecessary utilization.” To his point, the cost of generic drugs managing hypertension and diabetes are a fraction of the cost of GLP-1s, for more than a fractional benefit.
He added that there was another issue at play for their MA population. “We get paid by the diagnosis. If these expensive peptides really do cure someone’s obesity or cardiovascular disease, then not only are we on the hook for the drug spend, but we also get punished with lower risk scores and reduced payouts.” This phenomenon is the opposite of what taking on risk is supposed to accomplish. I was stunned by my colleague’s admission, so he clarified that this was not official policy, but rather a cold, logical interpretation of the incentives currently present in our system. I cannot fault his analysis, but I can fight for a system where effective care is effectively incentivized. Moments like this are reminders of how far we have to go.
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