2024 Post-Election Landscape – November 15, 2024

The 2024 election results have immense yet unclear implications for health care policy. While the incoming Trump Administration will be accompanied by a unified Republican 119th Congress, the Republican Party’s 2024 health care platform was notably vague. Given this uncertainty, SPG believes the best approach for health care stakeholders is to understand the implications of the Administration’s core priorities, while preparing for a wider range of scenarios and contingencies for non-core areas.

Although the new Trump Administration may differ significantly from the first one, some principles are likely to continue to pertain:

  • Personnel is policy: The first Trump Administration’s approach to policy was highly dependent on personnel choices. After the initial failure to repeal the Affordable Care Act (ACA) in 2017, health care ended up as a comparatively stable area of policy, due in large part to the stability of personnel. Seema Verma remained the Centers for Medicare and Medicaid Services (CMS) Administrator throughout Trump’s first term, and there was only one change of Health and Human Services (HHS) Secretary, from Tom Price to Alex Azar. 
  • Regulatory rollback: The new Administration is likely to act aggressively to roll back federal regulations from the Biden Administration and before. The loosening of ACA regulations from the first Trump term could be resumed and redoubled. One major outstanding question is whether the new administration will be more assertive with actions that fall under agency discretion, such as rescinding regulatory approvals or revoking waivers.
  • Federal-state conflicts: Democratic-controlled states will push back on Trump Administration policies immediately. The more forcefully the Trump Administration acts, the more political and legal challenges will arise. While the outcome of these legal challenges may be uncertain, they will likely tie up many aggressive actions for a significant time.

In this spirit, SPG’s analysis and initial thoughts on the post-election landscape, available here, discusses the following areas in more detail:

  • The anticipated reconciliation package extending the 2017 Trump tax cuts, and potential impacts on health care;
  • A potential federal health care regulatory agenda for the Trump administration;
  • The impact on New York-specific policies, including:
    • The New York Health Equity Reform (NYHER) Medicaid waiver;
    • New York’s proposed managed care organization (MCO) tax; and
    • New York’s Essential Plan 1332 waiver.