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US healthcare policy Report Interpretation

Goldman Sachs summarizes Washington discussions indicating low near-term risk of major drug-pricing action and limited capacity for broad legislation before the midterms. The panelists instead highlighted durable OBBBA Medicaid financing reforms, potential GLP-1 coverage extension, PDUFA-related China policy, and growing bipartisan interest in PBM, 340B and No Surprises Act reforms.

InstitutionGoldman Sachs
Date20260911
Industryhealthcare policy

Summary

Goldman Sachs summarizes Washington discussions indicating low near-term risk of major drug-pricing action and limited capacity for broad legislation before the midterms. The panelists instead highlighted durable OBBBA Medicaid financing reforms, potential GLP-1 coverage extension, PDUFA-related China policy, and growing bipartisan interest in PBM, 340B and No Surprises Act reforms.

No subject-specific rating, target price or price objective stated
US healthcare policydrug pricingMedicaidMedicare AdvantagePBM reformPDUFAbiopharmaGLP-1 coverage
  • Panelists viewed near-term drug-pricing changes as likely incremental and saw a low likelihood of MFN codification.
  • Medicaid financing reforms under OBBBA were described as among the year’s most consequential and likely durable policy changes.
  • The Medicare GLP-1 pilot, currently scheduled through end-2027, could be extended.
  • PDUFA VII reauthorization may become a vehicle for China-related biotechnology and outbound-investment provisions.
  • Major Medicare Advantage reform appears unlikely before the midterms, although Star Ratings modernization remains under discussion.

Report Interpretation

Overview

This policy-trip report compiles panelist views on the US healthcare-policy outlook ahead of the 2026 midterm elections. Its central message is that major legislative change is unlikely in the near term, but implementation of existing Medicaid reforms and a set of drug-pricing, coverage, reimbursement and China-policy issues could materially affect healthcare sectors over 2027–28.

Core views

The panelists generally expected healthcare policy through the 2026 midterms to focus on implementation, oversight and routine updates rather than sweeping new legislation. They cited a likely divided government and the recent emphasis on executive rather than legislative action. Drug-pricing containment remains bipartisan, but disagreement over mechanisms—such as most-favored-nation pricing (MFN) versus the Inflation Reduction Act (IRA)—makes near-term changes more likely to be incremental. Panelists saw a low likelihood that MFN will be codified, although CMMI pilot programs remain an administrative lever. They identified expansion of the IRA, MFN codification and finalization of the GLOBE and GUARD CMMI demonstrations as non-imminent risks to monitor. Medicare Part D spending was identified as a key pressure point, with a recent CBO estimate showing an additional $700bn beyond the previous baseline projection. PBM reform was described as a bipartisan priority, with some panelists believing legislation enacted earlier in the year did not sufficiently address PBM practices. Areas under discussion include commercial-market reforms, Medicaid spread pricing, transparency around net drug costs and reporting requirements. Reform of 340B and Part D also has traction, although hospital funding pressure from OBBBA could slow near-term 340B action. The panelists also viewed the Independent Dispute Resolution process under the No Surprises Act as not functioning as intended; they expect a durable solution to require congressional legislation, but noted that resolving the economics of provider behavior, arbitration volumes and award levels will be difficult. For biopharma, the report highlights a possible extension of CMS’s Medicare GLP-1 obesity-drug pilot for LLY and Novo, currently scheduled to end in 2027. Options being evaluated include renewing the program beyond 2027 or until affordability improves, legislative action, or an approach resembling the 2024 Biden proposal for Medicare coverage and required Medicaid coverage. The report notes that generic semaglutide entry in 2032 could lower GLP-1 prices, while mandatory Medicaid coverage would impose a substantial financial burden on state programs. PDUFA VII, which expires on September 30, 2027, is characterized as a must-pass FDA funding vehicle that could carry China-related measures involving clinical trials and outbound investment. Panelists were awaiting Treasury’s Notice of Proposed Rulemaking, with a statutory deadline of March 2027, for clarity on whether biotechnology investment in Chinese entities would be subject to formal screening under the COINS Act. Key questions include the definitions of covered technology and covered transactions, and the breadth of restrictions. The report notes that Congress could seek tougher provisions through PDUFA even if Treasury takes a balanced approach. Separately, the ITC’s investigation into Chinese biotechnology trade practices has findings due January 22, 2027. The discussion framed potential outbound-investment controls as targeted efforts to reduce dependence on China rather than a blanket prohibition on business with Chinese companies. The report treats OBBBA Medicaid financing reforms as the day’s most financially consequential takeaway. Changes affecting state-directed payments, provider taxes, work requirements and 1115 waiver budget neutrality are expected to remain a CMS and state-government focus. Panelists believe Democrats could increase oversight or seek targeted changes if they regain congressional control, but that reversal of core provisions would require control of both Congress and the White House and could not occur before 2029 at the earliest. Projected federal savings were cited as reinforcing the reforms’ durability, implying sustained effects on state financing, provider funding and Medicaid managed-care fundamentals through 2027 and 2028. In Medicare Advantage, Washington policymakers were described as cautious but not inclined to pursue another broad reform round after V28 reduced a meaningful share of excess risk-adjustment revenue capture. Near-term activity is more likely to involve fee-for-service extenders and physician reimbursement relief, while broader debates move into 2027. Policymakers continue to scrutinize Part B reimbursement and Star quality bonuses. The panelists saw growing interest in modernizing the Star Ratings framework and curbing selective measure challenges, gaming and litigation distortions, but concluded that durable changes would be better achieved legislatively following the Clover ruling. Finally, the report sees healthcare affordability and coverage expansion as issues likely to return in 2027. Expiring enhanced ACA premium tax credits, elevated premiums and greater consumer out-of-pocket exposure are increasing concern about marketplace affordability. The panelists expect little major action before the midterms, while Democratic debate broadens beyond restoring subsidies to include ACA-centered approaches, a public option, broader Medicare eligibility, Medicare for All and other paths to durable coverage expansion. They also expect Congress to tolerate some Part D premium pressure and market disruption over the next 12 to 24 months; the expiration of the current 6% Part D premium-growth cap in 2030 was identified as a longer-term legislative catalyst.

Analysis framework

The report synthesizes views from Washington policy panels and assesses each issue through its legislative feasibility, administrative implementation path, political timing and likely effects on healthcare funding, reimbursement and market economics.

Methodology notes

  • Event-Driven and Behavioral FinanceEvent-driven analysis

    Policy-event analysis

    The report evaluates scheduled policy catalysts—including the midterm elections, PDUFA VII expiration, Treasury rulemaking, the ITC findings date and the Part D premium-cap expiration—and links them to potential healthcare-sector policy outcomes.

Asset mapping & comparison

Structured mapping from thesis to named assets (strengths, weaknesses, peers, risks).

  • LLY
    Its GLP-1 obesity drugs are included in the CMS Medicare GLP-1 pilot program.
    Strengths
    Potential extension of Medicare pilot coverage beyond 2027.
    Comparison
    Referenced alongside Novo as a supplier of drugs covered by the pilot.
    Risks
    Future program design and affordability constraints remain uncertain.
  • Novo
    Its GLP-1 obesity drugs are included in the CMS Medicare GLP-1 pilot program.
    Strengths
    Potential extension of Medicare pilot coverage beyond 2027.
    Comparison
    Referenced alongside LLY as a supplier of drugs covered by the pilot.
    Risks
    Future program design and affordability constraints remain uncertain.

Key data

  • Medicare GLP-1 pilot durationThrough the end of 2027CMS pilot coverage for obesity drugs from LLY and Novo could potentially be extended.
  • PDUFA VII expirationSeptember 30, 2027The must-pass reauthorization could provide a vehicle for China-related policy items.
  • Treasury NPRM statutory deadlineMarch 2027Expected to clarify possible screening of outbound biotechnology investment in Chinese entities.
  • ITC biotechnology investigation findingsJanuary 22, 2027Findings could support later Treasury or congressional action on Chinese biotechnology trade practices.
  • Additional Medicare Part D spending estimate$700bnA recent CBO estimate cited by panelists as additional spending beyond the prior baseline projection.
  • Generic semaglutide entry2032The report notes this could reduce GLP-1 medication prices.
  • Part D premium-growth cap expiration2030Identified as a longer-term catalyst for broader Part D legislative review.

Impact & implications

The report suggests that healthcare policy risk is shifting from immediate broad drug-pricing legislation toward implementation of Medicaid financing reforms, targeted reimbursement and transparency initiatives, and policy catalysts in 2027 and beyond. It highlights potential implications for biopharma, providers, Medicaid managed care, Medicare Advantage, PBMs and ACA marketplace participants.

Risks

  • Drug-pricing risks identified by panelists include IRA expansion, MFN codification and finalization of the GLOBE and GUARD CMMI demonstrations.
  • More stringent China-related biotechnology investment restrictions could be added through PDUFA reauthorization.
  • OBBBA Medicaid financing reforms could create sustained pressure on state financing strategies, provider funding and Medicaid market fundamentals.
  • Part D affordability pressures, expiring stabilization measures and ACA marketplace affordability concerns could drive later policy intervention.

What to watch

  • Treasury’s NPRM and its treatment of biotechnology under outbound-investment screening, with a statutory deadline in March 2027.
  • PDUFA VII reauthorization and its legislative timetable ahead of the September 30, 2027 expiration.
  • The ITC’s Chinese biotechnology trade-practices findings due January 22, 2027.
  • Whether CMS extends the Medicare GLP-1 pilot beyond 2027.
  • Implementation and congressional oversight of OBBBA Medicaid provisions through 2027 and 2028.
  • Progress on PBM, 340B, No Surprises Act and Medicare Advantage Star Ratings reforms.
Zhejiang ICP No. 2022035445-5
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