Back
A small dog sits on a red couch, looking towards the camera with its head tilted.](https://cdn.prod.website-files.com/663379b068243e81cd1bd4fd/667c15c9f851bf3b02bc3982_Overview.svg)
Back
industry
Back
Back
Most compliance leaders are walking into 2026 already tired…and starting to confront 2027.
This isn’t the usual year-end tired (the kind that comes from closing audits or finalizing policies), but the deeper fatigue that sets in when emergency mode never really turns off.
2025 was a demanding year on many fronts. Teams were still implementing CY2025 requirements while simultaneously trying to keep one eye on CY2026 regulatory scenarios—all against the reality of constrained operational resources. Early in the year, organizations were managing the market rollout of their Inflation Reduction Act responses. By mid-summer, leadership teams were revisiting many IRA projects and whiteboarding new scenarios tied to the OBBBA (the One Big Beautiful Bill Act). Then came a prolonged government shutdown, followed closely by the realization that ACA (Affordable Care Act) enrollment would decline sharply in 2026.
All of this unfolded while the pace of agency rulemaking accelerated, bringing meaningful changes to eligibility, enrollment, access to care, and utilization management. At the same time, state legislatures and regulators began selectively responding—either aligning with federal direction or attempting to blunt its impact based on local priorities. On the horizon, substantial changes to agency guidance, audit posture, and enforcement actions are likely to complicate the risk management environment further.
Operationally, it has been relentless. The language used to describe how healthcare organizations are responding says a lot. “War rooms.” “Fire drills.” “Tiger teams.” Expressions used in crises, emergencies, and battle.
These aren’t exaggerated one-off metaphors anymore; they’ve become a default way compliance work is described. Key issues to foundational workflows, eligibility, and enrollment are triggering 360-degree reviews of member and patient engagement, pulling in legal, compliance, operations, IT, vendors, delegated entities, and external partners. Larger organizations are carrying multiple ad hoc working groups—structures that used to be reserved for once-in-a-decade initiatives—each with its own standing agenda and weekly update cadence. Quarterly business reviews have become extended, as the breadth of regulatory-driven change management has substantially widened.
Even professional conferences feel different. Sessions increasingly sound like crisis briefings rather than opportunities to step back, learn, and improve the craft.
What used to be exceptional—pandemic-level policy turbulence—has quietly become normal.
And the prevailing sentiment across the room is familiar: anxiety, time pressure, and a quiet but persistent question many leaders are reluctant to say out loud: Can we actually keep doing it this way?
As we look ahead to 2027, it’s becoming clear that 2026 will be shaped less by the sheer volume of regulatory change and more by how compliance leaders choose to respond. We can stay in permanent war-room mode. Or we can build calm, repeatable workflows that function even when the environment remains volatile. Beyond this, further innovation in new organizational capabilities will enable evolution towards an improved anti-fragile state of regulatory response and adaptation.
Compliance itself is a profession wired for stability. Rules, precedent, documentation, and defensible decision making are its foundation, and it seeks to promote reliability.
Yet, over the last few years, the language surrounding compliance has shifted dramatically. Speakers, consultants, and even internal leaders increasingly lean on crisis metaphors—firefighting, emergencies, existential threats. That framing made sense during the pandemic. But somewhere between 2020 and 2025, crisis mode stopped being temporary and started to feel permanent.
Before the pandemic, compliance work—while never easy—was largely incremental and predictable. From 2020 onward, teams adapted to crisis conditions, assuming they were short-lived. By 2025, something more unsettling had taken hold. Laws felt “under question.” Norms felt less stable. People began asking things they never used to ask: Will I actually be penalized if I don’t follow this law?
Federal changes, divergent state responses, and local market realities have combined to create a sense of institutional wobble. The problem is that compliance professionals are not built for chaos culture. Their credibility comes from precision, consistency, and reasoned judgment over time. When the surrounding environment speaks in panic but the profession itself demands restraint, the mismatch takes a toll on the organization and its team members.
Burnout. Paralysis. Endless deliberation.
Layered on top of this cultural tension is a very real timing problem. Government shutdowns and agency backlogs have delayed guidance. Rules arrive late, sometimes in the middle of the night, leaving implementation windows squeezed tighter than ever. Teams often don’t know when final rules will drop, how funding or eligibility thresholds will land, or how states will ultimately respond.
As a result, many compliance leaders are living in scenario limbo—holding best-case and worst-case outcomes in their heads at the same time, knowing that clarity may come only when there’s no room left for slow deliberation.
There’s a pervasive sense that “We’ll only know when it’s too late.”
It’s tempting to describe this moment as simply “more regulation.” But that misses what’s actually happening.
Today’s changes are often large, multi-program in scope, with downstream impacts that ripple across funding, eligibility, patient access, fraud and abuse scrutiny, and operational workflows. Interdependencies that were once assumed (tax treatment flowing cleanly into income and subsidy definitions, which then inform Medicaid or ACA enrollment) are now in flux.
Regulatory changes of this scale force organizations to revisit existing policies and workflows end-to-end. Consider eligibility tied to work requirements as one example. Adjustments to eligibility quickly cascade into how member communications are structured, how outreach is coordinated across mail, text, phone, and web, and how organizations avoid confusion or mass disenrollment. Those policies rarely stand alone; they’re entangled with vendors, delegated entities, and technology platforms.
This environment creates an opportunity—if compliance teams are willing to take it. Health policy and compliance functions can upgrade how they surface what’s just beyond the horizon and how they help operational teams internalize upcoming requirements. AI-enabled tools are increasingly capable of distilling regulatory impact and identifying gaps that are specific to each organization’s policies and footprint.
Telemedicine is another good illustration. Regulatory standards continue to evolve, but no two organizations are affected in the same way. Network composition, existing capabilities, and deployment models all matter for care access. Forward-looking teams are beginning to target automated policy review as an efficiency goal, recognizing that thinly stretched legal, compliance, and operations teams can’t manually re-evaluate everything every time.
The implication is clear: compliance leaders aren’t just updating policies anymore. They’re constantly leading the recalculation of reality for their members, patients, and markets.
State regulatory divergence has always existed, but today it’s also becoming decisive.
Different states bring different political appetites, population mixes, and economic structures to the table. Federal changes trigger very different reactions based on political alignment. Some states double down on Medicaid and access. Others allow enrollment to shrink with minimal intervention.
Local context matters more than ever. Medicaid operates very differently in California than in Texas or Florida. States dominated by employer-sponsored insurance have behaved differently from those with large gig-economy populations, significant immigrant communities, or aging rural demographics.
The takeaway for compliance leaders is uncomfortable but unavoidable: copying another organization’s response is risky. What works for a peer in a neighboring state—or even within the same state but serving a different population—may be wrong for you.
Jurisdiction isn’t just where the law comes from. It’s who lives there, how they work, and what the state is willing to fund. Compliance teams can’t copy their neighbor’s playbook anymore.
When budgets tighten, the instinctive response is to talk about cost. But in practice, most compliance leaders aren’t short on ideas—they’re short on time.
Delayed federal decisions, midnight rulemaking, and revisions to existing guidance compress and obfuscate timelines. Organizations still find themselves stuck in repeated meetings, re-litigating the same decisions because stakeholders weren’t aligned the first time. From a CCO’s perspective, one of the biggest mistakes is allowing circular debates to consume the one resource you can’t replenish.
The scarcest resource in 2026 isn’t budget. It’s decision time. Timelines between interim and final rules appear to become less manageable when the operationalization of enterprise projects comes in conflict with an unforgiving calendar of enrollment, onboarding, care delivery, and quality reporting.
Leaders who protect time—by standardizing decision paths, compressing analysis, and documenting once—will outperform those who rely on heroics.
Historically, large regulatory shifts were met by throwing bodies at the problem. The Clinton-era reforms, for example, required armies of analysts and years of manual work.
Today’s environment is different. We’re operating in an era of exploding data, powerful analysis tools, and nearly frictionless communication. It’s now possible to move from a new rule to an impact summary to actions and messaging in hours instead of weeks.
The distance between regulatory change and operational response can be dramatically narrowed—if AI is placed thoughtfully into the workflow.
Consider a simple example. New rules require revised disclaimers or notifications in member communications. Instead of manually searching policies, teams can synthesize the requirements and compare them against existing documentation to answer a focused question: “What does the CY2027 rule indicate that we currently do not have within our communications policy?” That gap analysis—across telemedicine access, broker marketing, benefits design, or cost-share monitoring—can be automated, freeing human expertise for judgment rather than document hunting.
What’s different this time isn’t just the volume of change. It’s that, for the first time, we actually have the tools to keep up.
So what does responding well actually look like?
Underneath all of this is a deeper shift in compliance psychology—from certainty to conditionality. Leaders increasingly need to evidence judgment, documenting not just what they decided but why, in an environment where rules feel politicized or unsettled.
Instead, standardize the newly deployed workflows and playbooks. Make time an explicit design constraint. Document the why, not just the what. Use AI to bring draft analyses into meetings rather than creating them from scratch. And scan beyond your four walls, deliberately adapting rather than copying.
Tools like Regology’s AI Agents exist to support exactly this shift: commoditizing aggregation, reading, extraction, and analysis so that compliance leaders can spend their time where it actually changes outcomes—deciding, prioritizing, and communicating.
Compliance leaders don’t have to accept permanent war rooms as the price of doing their jobs. By redesigning processes around time, structure, and AI-enabled insight, they can reduce angst, protect their teams, and actually improve compliance outcomes in a more volatile regulatory environment. Firefighting may feel productive, but it’s better workflows that will endure.
The environment for 2026 will not be calmer and the outline of 2027 is beginning to emerge to be of similar fashion. But it can be easier for organizations to navigate.
The regulatory shock is real. So is the opportunity to build better systems.
