Federal Insights: December Edition

Trump v. Slaughter and What’s Next for Independent Agencies: The Supreme Court recently heard arguments in a case that could reshape presidential control over regulatory agencies. At issue: whether the President can remove Federal Trade Commission members at will, overturning a 90 year precedent. A ruling favoring expanded removal power could affect roughly two dozen multi-member agencies. For banks, credit unions, insurers, and others that work with these agencies, the decision could mean a more politically responsive regulators. It could also mean continued legal uncertainty under existing bipartisan structures. Institutions should monitor the outcome closely, as it could influence regulatory priorities and enforcement across the financial services sector.

ACA Subsidies at a Tipping Point: Lawmakers are scrambling to extend enhanced ACA subsidies before they expire at the end of the year. As reported by Punchbowl News, a bipartisan proposal aims to stretch the subsidies for two more years, tighten income limits, expand health savings accounts, and rein in pharmacy benefit managers. Passage is far from guaranteed, and political maneuvering could drag this fight into January. Businesses, insurers, and healthcare stakeholders should brace for uncertainty and last minute deals , otherwise known as the new normal.

CMS Pushes Virtual Care Into the Medicare Mainstream: The 2026 final payment rule from CMS expands reimbursement pathways for telehealth, chronic care management, and remote monitoring, embedding virtual care and chronic disease oversight into core Medicare payment policy. This shows the agency is leaning into value-based care and digital health solutions rather than returning to pre-pandemic norms. For healthcare providers, payers, and patient advocacy stakeholders, the signal is clear: now is the moment to pivot toward telehealth and chronic care strategies because digital-first care is becoming more of a priority than ever under the Trump administration.

HUD Pauses Controversial Housing Plan: On December 8, 2025, HUD abruptly withdrew the new Continuum of Care Program (CoC) Notice of Funding Opportunity (NOFO) that had been issued just weeks earlier, following legal challenges from states, local governments, and nonprofit providers. The original plan would have capped permanent supportive housing at 30 percent of funding and shifted resources toward transitional programs with work or sobriety requirements.

For housing providers, the signal is clear: federal funding priorities are in flux. Existing permanent supportive housing programs remain funded for now, but any planning around transitional-only models should be paused. Organizations should monitor HUD closely for a revised NOFO and consider diversifying funding sources beyond federal grants to stay ahead of sudden policy shifts.