Fiscal period ending 2025-12-31 versus 2024-12-31
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Pervasive Medicaid regulatory risk dominates this filing, with newly quantified revenue exposure spanning more than a dozen state and federal supplemental payment programs totaling hundreds of millions of dollars annually, all subject to CMS approval uncertainty and compounded by federal legislation (OBBBA 2025) that structurally reduces Medicaid funding beginning 2026–2028. Liquidity pressure is emerging — current liabilities surged 52% YoY — while a $700M 2026 debt refinancing at materially higher rates adds a capital structure headwind. Professional liability reserve increases of $45–79M annually and self-insured exposure warnings round out a broadly deteriorating risk picture that spans regulatory, liquidity, debt, and litigation themes.
21 company-specific
· 2 eased/removed
· 2 common-mode
Company-specific changes
New
New federal legislation creates material revenue headwinds: estimated $432–480M annual reduction in Medicaid supplemental payments by 2032, plus Medicaid eligibility restrictions and work requirements that could increase uncompensated care.
Rural Health Transformation Program • Establishes a $50 billion rural health grant program for states between fiscal years 2026 and 2030 to be used for payments to rural health facilities. 50% of…
New
New disclosure of material risks: Medicaid enrollment/reimbursement cuts from July 2025 legislation, expired insurance subsidies, and tariffs on pharmaceuticals/medical devices. These substantively threaten revenues and margins.
Results of Operations Clinical Staffing, Inflation, future Medicaid reductions and Tariffs: The healthcare industry is labor intensive and salaries, wages and benefits are subject to inflationary…
New
New Nevada SDP program creates material revenue dependency (~$228M in 2025, $296M estimated 2026) subject to annual CMS approval and reconciliation risk, with no assurance of continuation beyond 2025.
Nevada State Directed Payment Program ("SDP"): As previously reported, in February, 2023, the Nevada Division of Health Care Financing and Policy (“DHCFP”) outlined a new provider fee on private…
New
New $689M state Medicaid program creates ongoing revenue dependency and regulatory/approval risk. $55M-$60M annual impact is material to operations and earnings.
Mississippi Hospital Access Program In September, 2023, subject to CMS approval, Mississippi announced a $689 million, two-part Medicaid payment proposal, effective retroactively to July 1, 2023…
New
New regulatory risk: Florida DPP program under CMS review; approval uncertain. Current $59M benefit at risk; potential $47M upside contingent on CMS decision.
Florida Medicaid Managed Care Directed Payment Program (“DPP”) The Florida DPP provides for an additional payment for Medicaid managed care contracted services. For the years ended December 31…
New
New Oklahoma Medicaid managed care DPP program creates material revenue risk: $26M annually at stake, CMS approval uncertain beyond June 2025, regulatory dependency.
Oklahoma (Transition to Managed Care and Implementation of a Medicaid Managed Care DPP) The current Oklahoma Medicaid supplemental payment program in effect, prior to the planned implementation of…
New
New disclosure of material Medicaid revenue uncertainty. $25–31M annual program revenue at risk; SFY 2026 payment levels unpredictable under planned replacement program.
Idaho Upper Payment Limit (“UPL”) In April 2024, the Idaho Department of Health and Welfare (“IDHW”) released its updated Medicaid UPL calculation for SFY 2024 (July 1, 2023 to June 30, 2024)…
New
New regulatory constraints on Medicaid supplemental payments (SDP and Provider Tax) with phased reductions beginning 2028. Company explicitly states inability to quantify financial impact, indicating material uncertainty.
Medicaid State Directed Payments (“SDP”) • In states that expanded their Medicaid programs under the ACA ("Expansion States"), the SDP payment rate is capped at 100% of Medicare. • For states…
Revised
New disclosure of $700M 2026 Notes refinancing at significantly higher rates, materially increasing future interest expense and reducing net income.
Capital Resources: Credit Facilities and Outstanding Debt Securities In September 2024, we entered into a tenth amendment ("Tenth Amendment") to our credit agreement ("Credit Agreement"), dated as of…
Revised
New legislation (OBBBA 2025) substantially decreases federal Medicaid funding to states, likely reducing state Medicaid payments to hospitals materially. Work requirements expected to reduce Medicaid coverage and increase uncompensated care.
Sources of Revenues and Health Care Reform: Given increasing budget deficits, the federal government and many states are currently considering additional ways to limit increases in levels of Medicare…
New
New disclosure of significant CMS regulatory changes: IPO list phase-out, $7.8B 340B budget neutrality offset reducing OPPS payments by 0.5% starting 2026 for ~16 years, and enhanced price transparency enforcement. Material financial impact.
Eliminating the Inpatient Only (IPO) List: CMS will phase out the IPO list over a 3-year period, beginning with removing 285 mostly musculoskeletal procedures for CY 2026. Procedures removed from the…
New
New disclosure of CMS MA payment methodology and Medicaid revenue concentration risk. Highlights payment uncertainty, state-level revenue dependency, and potential DSH payment reductions.
Medicare Advantage Payment Annual Update: On January 26, 2026, CMS released the calendar year 2027 ("CY 2027") Advance Notice of Methodological Changes for Medicare Advantage (“MA”) Capitation…
New
New disclosure of Medicaid supplemental payment reductions under OBBBA with quantified revenue impact and 2026 uncertainty. Material regulatory risk to healthcare provider revenues.
Summary of Various State Medicaid Supplemental Payment Programs: As noted elsewhere herein, the OBBBA has specific legislative language that will reduce Medicaid supplemental payments as well as…
New
New disclosure of material Texas Medicaid supplemental payment programs (CHIRP, QIF, HARP, UC) generating $50M+ annual revenue. CHIRP modifications introduce pay-for-performance risk with potential material reductions if quality metrics unmet.
Texas Supplemental Payment Programs: Certain of our acute care hospitals located in various counties of Texas participate in Medicaid supplemental payment Section 1115 Waiver indigent care programs.…
New
New disclosure of $68M annual hospital fee program revenue dependent on CMS approval. Uncertainty over 2025-2026 reimbursement amounts and timing creates material regulatory risk.
Hospital Fee Program Component CMS Methodology Approval Status CMS Rate Setting Approval Status Fee For Service Payment Approved through December 31, 2024 Approved through December 31, 2024; Paid…
New
New disclosure of $31M annual revenue dependent on CMS approval currently under review. Material revenue at risk if programs not renewed.
Illinois Medicaid Supplemental Payment Programs The Illinois Medicaid Supplemental Payment Programs are comprised of three components: (1) Medicaid managed care directed payment program; (2) Medicaid…
New
New state-directed payment program creates material revenue dependency (~$40-47M annually). Program requires annual CMS re-approval, creating regulatory uncertainty and potential revenue volatility.
Washington Safety Net Assessment Program On April 2, 2024, CMS approved an expanded state directed payment program in Washington whereby payments will now be based on the average commercial rates.…
New
New disclosure of material Medicaid DSH revenue ($38M in 2025) and pending federal cuts beginning 2026 that could reduce payments by ~33%, with $33M in reserves for adverse court decisions.
Texas DSH and Nevada SPA Programs: Texas DSH Upon meeting certain conditions and serving a disproportionately high share of Texas’ low income patients, our qualifying facilities located in Texas…
New
New material healthcare legislation enacted with explicit changes to Medicaid and related programs. Substantive regulatory risk requiring disclosure and investor awareness.
Legislation Commonly Known as the One Big Beautiful Bill Act ("OBBBA") The OBBBA was enacted into law on July 4, 2025. This legislation includes material changes to the Medicaid program and other…
Revised
New California Medicaid reimbursement methodology with cost-based ceiling effective December 2023 could materially reduce payment rates, requiring contract renegotiation and creating retroactive uncertainty.
Fee-For-Service Short-Doyle Medi-Cal (“SD/MC”) Hospitals Change In Payment Methodology: Under the California Medicaid prepaid inpatient health plan program, counties are required to ensure…
Revised
Current liabilities surged 52% YoY while current assets grew only 20%, sharply worsening the current ratio and signaling potential liquidity pressure.
December 31, 2025 December 31, 2024 Current assets $ 2,746,857 $ 2,279,988 Noncurrent assets (1) $ 9,453,432 $ 9,214,924 Current liabilities $ 2,837,781 $ 1,870,563 Noncurrent liabilities $ 4,828,865…
Eased / removed
Removed
Removal of $58M asset impairment provision and discontinued inpatient operations disclosure indicates resolution of prior-year crisis. Material easing of previously disclosed significant financial impact.
Provision for Asset Impairments 67 Our financial statements for the year ended December 31, 2022, include a pre-tax provision for asset impairment of approximately $58 million, which is included in…
Revised
DSH cuts deferred from FFY 2025-2027 to FFY 2028, reducing near-term financial impact and regulatory pressure on hospital reimbursement.
Medicaid Federal DSH Allotment The ACA (amended by subsequent federal legislation) requires annual aggregate reductions in federal Medicaid DSH allotment. In FFY 2028, DSH payments are scheduled to…
Also disclosed — common-mode (Social inflation litigation funding ×2)
Social inflation litigation funding
New
New disclosure of $45M–$79M annual reserve increases for professional liability claims due to unfavorable trends. Material financial impact and escalating risk exposure.
Adjustments to self-insured professional and general liability reserves: Our estimated liability for self-insured professional and general liability claims is based on a number of factors including…
Social inflation litigation funding
New
New disclosure of material self-insured liability exposure (professional, general, workers' comp) with explicit warning that sharp increases in claims could materially harm results.
Self-Insured/Other Insurance Risks: We provide for self-insured risks, primarily general and professional liability claims, workers’ compensation claims and healthcare and dental claims. Our…