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It has been a little over six months since the signing of the One Big Beautiful Bill Act (OBBBA), legislation projected to shift nearly $1 trillion in federal spending through FY2034.
Initially, much of the attention understandably focused on the effects and speed of the change. More than 300 pages of policy language introduced new eligibility requirements for government health plans, expanded administrative procedures around enrollment, modified how states can access federal funding for Medicaid, and allowed enhanced Affordable Care Act (ACA) premium subsidies to expire.
But as most compliance leaders recognized early on, OBBBA was never going to be confined neatly to Medicaid, Medicare, or ACA lines of business. A wide range of coverage and funding implications will slowly ripple through the ecosystem.
Healthcare financing, access, and delivery are deeply interconnected. Changes to eligibility definitions ripple into enrollment operations. Enrollment changes affect patient panels, utilization patterns, provider relationships, and vendor workflows. Administrative rules flow downstream into communications, billing practices, data exchanges, and delegated entity oversight.
That reality has kept policy, legal, compliance, and risk management teams busy well beyond the initial implementation window—and it will continue to do so for the foreseeable future. Keep in mind that much of OBBBA's policy impact is back-end loaded, meaning its downstream effects will be felt for years to come.
While many of OBBBA’s broader policy goals had been discussed for months leading up to passage, its enactment immediately triggered formal operational reviews across the healthcare ecosystem.
Fast-moving organizations—often led by compliance and legal leadership—moved quickly to assess and plan how new statutory requirements compared to existing policies, procedures, and controls. These assessments were rarely narrow. They involved mapping current compliance frameworks against the new law to identify gaps, overlaps, and areas requiring modification.
Common focal points included member and patient engagement practices, billing transparency, external communications, and the responsibilities of vendors and delegated entities. For many organizations, this meant running parallel workstreams to ensure open-enrollment readiness while also laying the groundwork for the 2026 operational change.
The pace and scope of change management during this period were striking. In many cases, it rivaled the intensity seen during the first year of the pandemic. That level of effort was particularly challenging for large care delivery and risk-bearing organizations that had already undergone significant administrative reductions in 2024.
The priority in 2025 was clear: build viable pathways to meet regulatory expectations quickly, develop readiness to shift operations in 2026 and 2027, and avoid disruption during enrollment.
With 2025 now firmly in the rear-view mirror, healthcare organizations enter 2026 facing a new market landscape.
Patient panels have shifted. Enrollment profiles look different. Operational infrastructure has been updated—sometimes hastily, sometimes unevenly. The focus for legal and compliance teams is no longer on broad programs at speed.
It has shifted from broad implementation to refinement and surgical buildout.
This next phase is less about project plans and Gantt charts and more about finishing the last mile. It requires a different mindset—one oriented toward stability, risk management, and consistency rather than crisis response and rapid deployment.
For many organizations, this also means revisiting cultural norms that emerged during the implementation rush. Emergency governance structures, once necessary, are not sustainable as permanent fixtures. As discussed in earlier reflections on decision making under pressure, the work now is to rebalance growth and risk management without defaulting to constant escalation.
High-resolution refinement is the work of 2026.
As compliance teams plan for the next stage of OBBBA implementation, several priorities are coming into sharper focus:
1. Re-review official regulatory language and updated agency guidance
Much of the activity in 2025 was necessarily urgent, focused on getting changes underway to meet end-of-year expectations. In 2026, compliance teams should intentionally return to the source material—statutory language, final rules, and agency guidance governing CY2026 and CY2027 implementation. Relying too heavily on third-party interpretation increases the risk of missed nuance. Regular, structured review of official language is a healthy risk-management practice, particularly as agencies continue to clarify expectations. Tools like Reggi, Regology’s Research Assistant, can help teams quickly look up primary regulatory text, surface relevant sections, and answer targeted questions without relying solely on secondary interpretation.
2. Formal checks for new guidance and regulatory updates
OBBBA implementation is still evolving. Federal and state agencies continue to issue guidance, clarifications, and technical updates that can materially affect operations. Organizations should move away from ad hoc monitoring and toward formalized checks for regulatory change. Automated alerting and tracking help ensure that updates to rules and guidance are identified consistently, rather than discovered after they’ve already created downstream issues. Regology’s Regulatory Change Agent continuously monitors federal and state agencies for updates to specific rules and guidance, helping ensure that compliance teams are alerted to meaningful changes as they occur—not weeks later through informal channels.
3. Ongoing awareness of enforcement actions and market signals
Enforcement activity often provides the clearest insight into how regulators interpret and prioritize new requirements. Compliance teams should actively track enforcement actions and share relevant developments internally, using them to inform risk assessments and operational decisions. These signals help move discussions from theoretical compliance to practical application across the ecosystem. Regology platform surfaces enforcement actions and regulatory commentary to help teams understand emerging patterns and prioritize areas requiring additional controls or documentation.
4. Internal monitoring following the recent enrollment period
Although the most significant eligibility changes will not fully take effect until 2027, the 2026 enrollment cycle offers early indicators of member behavior, confusion points, and communication gaps. Reviewing enrollment outcomes and stakeholder responses now allows organizations to refine messaging, outreach, and operational processes before larger shifts occur.
5. Planned updates to internal policies and external communications
Many policies—particularly those related to member and provider communications, IT configuration, and engagement workflows—were adjusted quickly in late 2025 to meet immediate needs. In 2026, these policies require more deliberate updating as part of the annual review cycle. Completing and propagating these updates by mid-year helps avoid misalignment and confusion heading into the next enrollment season. Regology’s Compliance Agent can assist by comparing existing policies against current and forthcoming regulatory requirements, highlighting gaps and areas needing refinement before changes are propagated across the organization.
6. Updated training and compliance materials
OBBBA provisions must be reflected across employee onboarding, compliance testing, audit preparation, and ongoing training materials. This work is often underestimated, but it plays a critical role in consistency and defensibility. Ensuring that staff understand not just what changed, but why, supports stronger execution across the organization.
7. Alignment with vendors and delegated entities—and preparation for review
Organizations should not assume that vendors and delegated entities have fully incorporated OBBBA requirements into their own policies and systems. Key provisions should be addressed explicitly in monthly or quarterly operating committees, with attention to how new functionality around eligibility, pricing transparency, and data exchange aligns with internal expectations. At the same time, compliance teams should begin informal internal reviews of audit readiness, considering how policies, documentation, and infrastructure will support eventual regulatory examination.
The opportunity in 2026 is not simply to “finish” OBBBA implementation.
It is to use this period of high-resolution refinement to strengthen compliance operations more broadly—to create clearer pathways for risk management, improve consistency of execution, and raise the overall quality of compliance effort across the organization.
Growth and innovation depend on this foundation. As healthcare markets continue to evolve, compliance and legal teams are uniquely positioned to lead—not just by interpreting rules, but by helping organizations adapt thoughtfully and sustainably.
OBBBA implementation will extend well into the future, with key milestones still ahead in 2027. But the work of 2026 matters just as much. It is where compliance shifts from reaction to stewardship, ensuring that organizations are not only compliant but prepared as healthcare markets transform.
