Skip to main content
The Keckley Report

An Open Letter to Hospital Boards of Directors: Long-Term Strategic Planning needs Your Attention

By January 1, 2024No Comments

As 2023 comes to an end and prognostics for 2024 pepper Inboxes, high anxiety is understandable. The near-term environment for hospitals, especially public hospitals and not-for-profit health systems, is tepid at best: despite the November uptick in operating margins to 2% (Fitch, Syntellis), the future for hospitals is uncertain and it’s due to more than payer reimbursement, labor costs and regulatory changes.

Putting lipstick on the pig serves no useful purpose: though state hospital associations, AHA, FAH, AEH and others have been effective in fending off unwelcome threats ranging from 340B cuts, site neutral payments and others at least temporarily, the welcoming environment for hospitals in the throes of the pandemic has been replaced by animosity and distrust.

The majority of the population believes U.S. the health system is heading in the wrong direction and think hospitals are complicit (See Polling data from Gallup and Keckley Poll below). They believe the system puts its profit above patient care and welcome greater transparency about prices and business practices. In states like Colorado (hospital expenditure report), Minnesota (billing and collection), and Oregon (nurse staffing levels), new regulations feed the public’s appetite for hospital accountability alongside bipartisan Congressional efforts to limit tax exemptions and funding for hospitals. It’s a tsunami hospital boards must address if they are to carry out their fiduciary responsibilities:

  • Set Direction: The organization’s long-term strategy in the context of its vision, mission and values.
  • Secure Capital: The amount and sourcing of capital necessary to execute the strategy.
  • Hire a Competent CEO and Give Direction: Boards set direction; CEOs execute.

Regretfully, near-term pressures on hospitals have compromised long-term strategic planning in which the Board play’s the central role. But most hospital boards lack adequate preparedness to independently assess the long-term future for their organization i.e. analysis of trends and assumptions that cumulatively reshape markets, define opportunities and frame possible destinations for hospitals drawn from 5 zones of surveillance:

  • Clinical innovations.
  • Technology capabilities.
  • Capital Market Access and Deployment.
  • Regulatory Policy Changes.
  • Consumer Values, Preferences and Actions.

In reality, the near-term issues i.e. labor and supply chain costs, insurer reimbursement, workforce burnout et al—dominate board meetings; long-range strategic planning is relegated to an annual retreat where the management team and often a consultant present a recommendation for approval. But in many organizations, the long-term strategic plans (LTSPs) fall short:

  • Most LTSPs offer an incomplete assessment of clinical innovations and technologies that fundamentally alter how health services will be provided, where and by whom.
  • Most LTSPs are based on an acute-centric view of “the future” and lack input about other sectors and industries where the healthcare market is relevant and alternative approaches are executed.
  • Most LTSPs are aspirational and short on pragmatism. Risks are underestimated and strengths over-estimated.
  • Most LTSPs are designed to affirm the preferences of the hospital CEO without the benefit of independent, studied review and discussion with the board.
  • Most LTSPs don’t consider all relevant ‘future state’ options despite the Board’s fiduciary obligation to assure they do.
  • Most rely on data that’s inadequate/incomplete/misleading, especially in assessing how and chare capital markets are accessing and deploying capital in healthcare services.
  • Most LTSPs are not used as milestones for monitoring performance nor are underlying assumptions upon which LRSPs are based revisited.

My take:

The Board’s role in Long-Range Strategic Planning is, in many ways, it’s most important. It is the basis for deciding the capital requirements necessary to its implementation and the basis for hiring, keeping and compensating the CEO. But in most hospitals, the board’s desire to engage more directly around long-term strategy for the organization is not addressed. Understandable…

  • Boards are getting more media attention these days, and it’s usually in an unflattering context. Disclosures of Board malperformance in high profile healthcare organizations like Theranos, Purdue and others has been notable. Protocols for responding among Board members in investor-owned organizations is a priority, but less-so in many not-for-profit settings including hospitals often caught by surprise by media.
  • And Board members are asking for their organizations to engage them in more in strategy development. In the latest National Association of Corporate Directors’ survey, 81% of directors cited “oversight of strategic execution” and 80% “oversight of strategy development” as their top concerns from a list of 13 options. Hospital boards are no exception: they want to be engaged and cringe when treated as rubber stamps.

Hospital boards intuitively understand that surviving/thriving in 2024 is important but no guarantee of long-term stability given sobering realities with long-term impact:

  • The core business of hospitals–inpatient, outpatient and emergency services—is subject to market constraints on its prices, consumer and employer expectations and non-traditional competition. Bricks, sticks and clicks strategies will be deployed in a regulatory environment that’s agnostic to an organization’s tax status and competition is based on value that’s measured and publicly comparable.
  • The usefulness of artificial intelligence will widen in healthcare services displacing traditional operating models, staffing and resource allocation priorities.
  • Big tech (Apple (AAPL), Microsoft (MSFT), Alphabet (GOOG), Amazon (AMZN), Meta (META), Tesla (TSLA) and Nvidia (NVDA)—collectively almost 60% of all S&P 500 gains in 2023—will play a direct and significant role in how the healthcare services industry responds to macro-opportunities and near-term pressures. They’re not outside looking in; they’re inside looking out.
  • Private capital will play a bigger role in the future of the system and in capitalizing hospital services. Expanded scale and wider scope will be enabled through partnerships with private capital and strategic partners requiring governance and leadership adaptation. And, the near-term hurdles facing PE—despite success in fund-raising—will redirect their bets in health services and expectations for profits.
  • State and federal regulatory policies and compliance risks will be more important to execution. Growth through consolidation will face bigger hurdles, transparency requirements in all aspects of operations will increase and business-as-usual discontinued.
  • The scale, scope and effectiveness of an organization’s primary and preventive health services will be foundational to competing: managing ‘covered lives’, reducing demand, integrating social determinants and behavioral health, enabling consumer self-care, leveraging AI and enabling affordability will be key platform ingredients that enable growth and sustainability.
  • Media attention to hospital business practices including the role Boards play in LRSPs will intensify.

Granted: the issues facing hospitals are reliably short-term: as Congress returns next week, for instance, funding for the FDA, Community Health Center Fund, Teaching Health Center Graduate Medical Education Program, National Health Services Corps and Veterans Health is not authorized and $16 billion in cuts to Medicaid disproportionate share payments remains unsettled, so the short-term matters.

But arguably, engaging the hospital board in longer term planning is equally important. It’s not a luxury.

Happy New Year. Buckle up!


PS: The NCAA National Championship Game in Houston next Monday will mark the end of the 2023 Bowl season—43 games that started December 16, 2023 (GA Southern vs. Ohio U in the Myrtle Beach Bowl). But college football, like hospitals, now operates under a cloud of concern: “The four teams in the College Football Playoff used cash payments from fan “collectives” in unique ways to build their rosters, showing how much an influx of money has changed college sports…But they have also prompted red flags from the Internal Revenue Service, threatened to create a sense of imbalance within teams, and fostered a culture of secrecy and an uncomfortable push-pull between collectives and schools…”

Hospitals are not alone in dealing with money-driven pressures that seem out of sync with lofty aims like ‘student athletes’ and ‘community benefits.’ That’s why hospitals must embrace long-term strategic planning with an outside-in frame of reference now.


David A. Fahrenthold,  Billy Witz “The Best Teams That Money Could Buy” New York Times December 31, 2023

Director Outlook: Top Priorities for 2024 NACD 12/13/2023

Biden-Harris Administration Announces New Actions to Lower Health Care and Prescription Drug Costs by Promoting Competition December 7, 2023

Sanjay Mishra “7 medical breakthroughs that gave us hope in 2023” National Geographic


Re: healthcare regulation: “Government steps in when healthcare sectors fail to police themselves. Biased AI algorithms that exacerbate health disparities. Daily cyberattacks and breaches of protected health information. Questionable uses of tax-exempt revenue to benefit private interests. Short staffing that threatens patient safety. Chronic shortages of life-saving drugs. It’s a compelling argument to make.

Philosophically, I’d much prefer fair market competition to heavy-handed government regulation as the catalyst for the customer revolution in healthcare. Viva la revolution more than viva la regulation. But I’d expect more of the latter if I were you as this industry just can’t seem to get its act together.”

David Burda “Burda on Healthcare: Are you enjoying the Golden Age of Healthcare Regulation?” 4Sight Health December 26, 2023

Re: 2024 SCOTUS health docket: “This term, the court has a swath of hot-button cases pertaining to the right to bear arms, false and misleading health information, and the opioid crisis. We’re concerned the justices will solidify a long-term conservative project to dismantle the administrative state, potentially unraveling long-standing rules on access to health services, safe and effective medicines, food and nutrition, consumer protection, and climate change.

There was a time when the elected branches of government — the president and Congress — would shape health policy. Today, the justices are inserting themselves into the most socially controversial issues in our nation.”

Lawrence O. Gostin, Sarah Wetter On the Health Docket for the Supreme Court’s 2024 Term December 28, 2023

Re: role models needed: “Those of us privileged to hold leadership roles in healthcare have a special obligation and responsibility, especially now. We must not take the low road by emulating the pettiness, finger-pointing, egocentrism and narcissism that we see in too many corners of public life. We take the high road by promoting the opposite — those values of honesty, respect, and decency, which highlight the best of us.”

Michael Dowling, CEO, Northwell Health Beckers Hospital Review December 30, 2023

Re: 2023 year-end litigation in HIT: “There is no shortage of litigation, even in the health information technology space. Doctors and their patients are suing for the right to use virtual technology in New Jersey. The American Hospital Association sued the federal government over the new rule restricting third-party technology use, claiming that the HHS Office for Civil Rights’ (OCR) stance upsets the balance between information sharing and privacy facilitated by HIPAA. Legal battles against UnitedHealthcare and Humana may decide whether the use of algorithms to make health insurance coverage decisions is okay or not. The American Medical Association is anticipating a legal battle (or many) over who should be liable when artificial intelligence tools in healthcare cause patients harm. This fighting about everything is about as uncomfortable as watching Zac Efron in a professional wrestling movie.”

Julie Barnes “One Thoughtful Paragraph” Maverick Health Policy December 22, 2023

Re: 2024 economy: “America’s economy in 2023 provided a lesson in humility for forecasters. Before the year began, almost all predicted that it was heading for sluggish growth at best, and a recession at worst. The logic was simple: beating inflation was bound to be painful. Instead, America powered ahead at an annualized pace of roughly 2% growth, even as inflation receded….

First, there is always a delay between when central banks raise interest rates and when the economy feels the effects. In 2023 consumers and companies had savings that limited their need for financing; in 2024 they will have thinner buffers, thus increasing their exposure to higher rates. Second, even though the Federal Reserve may have finished raising interest rates, real rates will become progressively more restrictive as inflation falls. Finally, cracks are showing. Unemployment, though still low, is ticking up. Once an economic slowdown gets under way, it risks.”

Three economic risks facing America in 2024” The Economist November 13, 2023

Re: Deal activity in 2023: “PE healthcare services deal activity in the US and Canada is on track to reach 767 deals closed in 2023, down 18.9% year over year. But this does not tell the whole story. Platform deals—defined as buyouts that are not add-ons—are projected to total just 48 for 2023, compared with 98 in 2022, 135 in 2021, and 111 per year on average in 2017 to 2019. What’s more, the vast majority of platform deals in 2023 have been acquisitions of small providers without existing institutional backing. Very few platforms have been sold from one sponsor to another, the traditional exit route in healthcare services. This means that sponsors are returning very little capital to their LPs, and some platforms are in dire need of recapitalization. “

2024 US Private Equity Outlook Our analysts’ outlook on the private equity market in 2024 Pitchbook December 19, 2023 2024_US_Private_Equity_Outlook.pdf (

Re: PE, VC deal activity in 2024: “Our prediction of a decline in global healthcare deal count in both the PE and VC asset classes is not a vote of no confidence in the industry’s growth, impact, or innovation potential—rather, it is a reflection of the industry’s unique position in an economic cycle shaped by a global pandemic and its aftermath…Healthcare’s share of global PE deal count peaked at 13.7% in 2020 and fell to 10.8%—its lowest level since 2015—in 2023. We predict that healthcare’s share of PE deal activity will fall further in 2024. We are making this prediction in spite of the fact that 2023 marked the best year to date for PE healthcare specialists by cumulative dollars closed…After reaching a peak of 18.4% in 2020—driven largely by an unprecedented flow of capital into biopharma—healthcare has dropped to 16.5% of global VC deal count in 2023. We predict that 2024 will see an even lower figure…”

2024 Healthcare Outlook Pitchbook December 18, 2023

Re: public opinion: “There’s going to be a reckoning about what to do about healthcare and it’s going to happen in the face of most, if not all the players, in the healthcare value chain being deeply unpopular…”

Paul Markovich, president and CEO of Blue Shield of California Blue Shield of CA CEO predicts ‘reckoning’ over healthcare costs Modern Healthcare December 18, 2023

Re: Media attention to hospital price transparency: “Some of the largest US hospital chains and most prestigious academic medical centers have violated federal rules by not posting the prices they charge for care, according to records obtained by Bloomberg News.

For-profit HCA Healthcare Inc., the nation’s largest hospital system, and big nonprofit operators including Ascension and Trinity Health have been cited for failing to make prices fully available to the public, enforcement letters Bloomberg obtained through a public records request show. So have marquee facilities such as New York Presbyterian Weill Cornell Medical Center, Emory University Hospital and the Hospital of the University of Pennsylvania.

The records reveal the challenges US regulators face as they try to force long-hidden prices into the open to address decades of rising medical expenses. Since 2021, hospitals have been required to be more transparent about what they charge. However, government data show that among 1,750 hospitals regulators evaluated as of early December, about 1,300 facilities — nearly 20% of the hospitals in the US — have been warned they violated rules.”

John TozziTanaz Meghjani “A Fifth of US Hospitals Have Been Warned Over Secretive Prices” Bloomberg December 20, 2023


Gallup: Changes in perception of care quality in provider settings 2010-2023: Based on its November 2023 poll compared to its 2000 poll: % who consider the care provided in these settings “Excellent/ Good” vs. “Fair/Poor”: Highlights:

  • In 2023, only 34% of Americans said they have a great deal or quite a lot of confidencein the U.S. medical system — more confidence than organized religion, less than the police, and the lowest score in a decade.
  • While nurses and physicians have maintained comfortable leads over other settings, erosion is noted in all settings except urgent care/walk-in clinics.
  • Traditional players i.e. physicians, hospitals and drug companies, saw the biggest declines.
Provider Setting 2023

% Excellent/Good

% Change since 2010
Nurses 82 -6
Physicians 69 -15
Hospitals 58 -14
Walk In/Urgent Care Clinics 56 +2
Telemedicine/Virtual Visits 52 NA
Hospital Emergency Rooms 47 -13
Pharmaceutical/Drug Companies 33 -21
Health Insurance Companies 31 -11
Nursing Homes 25 -8


“Nurses First, Doctors Distant Second in Healthcare Provider Ratings” Gallup December 18, 2023

Keckley Poll: 4Q 2023: Opinions about the overall state of the healthcare industry (Survey of 817 US adults conducted November 2023):

  • 60% of adults agree that “the U.S. health system puts its profits above patient care” vs. 13% who disagree and 27% who have mixed feelings.
  • 72% of adults think “the US system heading in the wrong direction” vs. 28% who think it’s heading in the right direction
  • 69% agree that “the U.S. health system is fundamentally flawed and needs major change” vs. 31% who disagree.
  • 55% think “the tax exemption given not-for-profit hospitals is justified by the community benefits they provide” vs. 45% who disagree.

The Keckley Poll 4Q 2023


EPI Report: Minimum wage increase in 2024: Per the Economic Policy Institute report, 22 states and an additional 38 counties and cities will increase their minimum wage Jan. 1; 9.9 million workers will see $6.95 billion in added wages from the state increases. with about 58% being women and 47.4% being below twice the poverty line.

Twenty-two states will increase their minimum wages on January 1, raising pay for nearly 10 million workers Economic Policy Institute December 2023


Study: private equity ownership of hospitals: “In a difference-in-differences examination of hospitalizations at 51 private equity–acquired hospitals and 259 matched control hospitals using Medicare Part A claims data, private equity acquisition was associated with a 25.4% increase in hospital-acquired conditions, which was driven by falls (=27.3% increase) and central line–associated bloodstream infections (+37.7%). Medicare beneficiaries at private equity hospitals were modestly younger, less likely to have dual eligibility for Medicare and Medicaid, and transferred more to other acute care hospitals relative to control, likely reflecting a lower-risk population of admitted beneficiaries. This potentially explained a small relative reduction for in-hospital mortality that dissipated by 30 days after hospital discharge.

Kannan et al “Changes in Hospital Adverse Events and Patient Outcomes Associated with Private Equity Acquisition” JAMA December 26, 2023;330(24):2365-2375. doi:10.1001/jama.2023.23147

Hospital M&A: “Hospital merger and acquisition activity is expected to increase next year as hospitals manage financial pressure, competitors combine and insurers grow. The number of announced hospital deals through the third quarter rose by more than 50%, to 53 proposed transactions from 35 last year, according to data from consultancy Kaufman Hall. Deal activity was particularly pronounced among midsized health systems ranging from $1 billion to $5 billion in annual revenue. Nearly 40% of the 18 proposed hospital deals announced in the third quarter were driven by financial distress.”

Alex Kacik “Hospital merger activity to increase in 2024” Modern Healthcare December 26, 2023

JD Power Study: Patient experiences with hospitals: “Patients are not getting timely access to doctors while in the hospital, according to the J.D. Power 2023 U.S. Hospital Patient Satisfaction Study. The study provides patient feedback on their satisfaction during a recent overnight hospital stay. Key findings:

  • only 36% of patients say they are always able to speak to a doctor when needed–down from 43% in 2011, when the study was last conducted…
  • While doctors are hard to speak with, patients are more satisfied with their in-person experience with doctors. A majority (90%) of patients say the doctor answered all their questions. However, only 61% of patients say doctors always explained things in a way they could understand.”

“JD Power 2023 Hospital Patient Satisfaction Survey” December 18, 2023

Study: hospital billing procedures: “In 2021, 15% of US households reported medical debt, which disproportionately affects Black and Hispanic communities.1 Medical debt hardship can be worsened by inflated medical bills and aggressive hospital collections practices that diminish public trust in the medical profession and widen gaps in access to care. According to a 2022 analysis, 64% of people with medical debt avoided medical care because of it.

Researchers analyzed 3 measures necessary to self-monitoring of billing activity: legal actions taken by hospitals to collect medical debt, timeliness of sending patients an itemized billing statement, and patient access to a qualified billing representative. Results:

  • A total of 754 hospitals (33.2%) reported taking legal action against patients for late or insufficient payments, 1020 (44.9%) did not routinely send patients itemized bills within 30 days, and 125 (5.5%) did not provide access to billing representatives capable of investigating billing errors, offering price adjustment, and establishing payment plans.
  • Of all hospitals, 1415 (62.3%) did not report meeting all 3 billing quality standards. Data were missing for 3.5% for teaching status and 7.8% for safety grade. These hospitals were more likely to be rural (75.3% vs 56.0%; risk ratio [RR], 1.34 [95% CI, 1.28-1.41]) and have a low (C or lower) Leapfrog Hospital Safety Grade (61.6% vs 49.1%; RR, 1.25 [95% CI, 1.18-1.34]).

Rumalla et al “Reported Variation in Hospital Billing Quality “JAMA.  December 18, 2023. doi:10.1001/jama.2023.25318


AMGA Report:” Medical group revenue per physician jumped 16.7% in 2023 but expenses are also on the rise, according to the AMGA Medical Group Operations and Finance Survey. The median revenue per physician hit $719,901, which is up even 9.1% from pre-pandemic levels, while the median expense per physician soared 14.7%, hitting $1.03 million for the year. System-affiliated medical groups reported an annual loss of $249,000 on average.”

AMGA Medical Group Operations and Finance Survey


United (NaviHealth) restrictions get attention: “Health insurance giant UnitedHealth Group used secret rules to restrict access to rehabilitation care requested by specific groups of seriously ill patients, including those who lived in nursing homes or suffered from cognitive impairment, according to internal documents obtained by STAT.

The documents, which outline parameters for the clinicians who initially review referrals for rehab care, reveal that many patients enrolled in Medicare Advantage plans were routed for a quick denial based on criteria neither they, nor their doctors, were aware of….The directive to toss out the rules coincided with increased scrutiny of Medicare Advantage insurers from federal lawmakers and the Centers for Medicare and Medicaid Services….The restrictions were applied by clinicians working for a UnitedHealth subsidiary called NaviHealth, which not only manages rehab care within UnitedHealth’s Medicare Advantage plans, but also within Medicare Advantage plans run by Humana and many regional insurers, encompassing more than 15 million patients.”

Bob Herman, Casey Ross “UnitedHealth used secret rules to restrict rehab care for seriously ill Medicare Advantage patients” STAT December 28, 2023

Care Management, Social Determinants

Retail senior care: “Competition is heating up among healthcare retailers to provide services for the rapidly swelling senior population. About 1 in 6 people in the U.S. were age 65 or older as of 2020, increasing to roughly 1 in 5 by 2030…

Retail providers are stepping in where traditional healthcare has failed, working to develop holistic care plans in lower-cost settings to prevent acute illnesses…capturing the senior population also offers a long runway for potential profits for the retailers. Millions of baby boomers have yet to reach 65 years of age, ensuring a large aging population for many years to come.

Big retail players such as CVS, Walgreens, Walmart and Kroger want in. They are paying billions of dollars to scoop up senior-focused primary care operations or forming their own to attract a population with whom they see the biggest returns. The strategy, supported by retail brand recognition, involves aggressive plans for clinical expansion and increased investment in value-based health plans.”

Caroline Hudson “Why retailers are targeting seniors for growth opportunities” Modern Healthcare December 28, 2023

Study: Food as medicine: “Food-as-medicine programs are becoming increasingly common, and rigorous evidence is needed regarding their effects on health. ” This stratified randomized clinical trial using a wait list design was conducted from April 19, 2019, to September 16, 2022, with patients followed up for 1 year. The program provided healthy groceries for 10 meals per week for an entire household, plus dietitian consultations, nurse evaluations, health coaching, and diabetes education. Findings:

“In this randomized clinical trial, an intensive food-as-medicine program increased engagement with preventive health care but did not improve glycemic control compared with usual care among adult participants. Programs targeted to individuals with elevated biomarkers require a control group to demonstrate effectiveness to account for improvements that occur without the intervention. Additional research is needed to design food-as-medicine programs that improve health.”

Doyle et al “Effect of an Intensive Food-as-Medicine Program on Health and Health Care Use: A Randomized Clinical Trial” JAMA Internal Med.  December 26, 2023. doi:10.1001/jamainternmed.2023.6670

Weight loss drug development: “A steady stream of weight loss drugs, which mimic naturally occurring hormones, are in the pipeline. This competition may finally lead to lower prices and greater supplies of these highly effective drugs, and maybe replace some injectables with pills.

Ozempic (above) was not the first of the hormone-mimicking drugs to hit the market, but it was the first to become a household name as celebrities shared their weight loss success from its off-label use on social media.

The recent approval of another obesity drug, Zepbound, expands the options for medications to manage weight, but it comes with the same cost and access challenges that plague other weight loss drugs in its class.

The drugs in this class are agonists, or mimics, of natural gut hormones that affect the body’s metabolism and hunger signals in the brain. But the currently approved drugs, synthetic versions of these hormones, are large molecules that are expensive and time-consuming to manufacture, which has meant high prices for consumers and growing drug shortages. Further, most of these drugs are injections, rather than oral pills, and usually require refrigeration for storage. With more than four in 10 Americans—and nearly 2 billion people worldwide—affected by obesity, the promise of these new drugs to treat the world’s fastest growing chronic disease has been clashing with the reality of their cost and access problems..”

“New obesity drugs are coming. Here’s how they could change everything.” National Geographic December 22, 2023

Elaine Chen , Andrew Joseph , and Damian Garde “What comes after Wegovy? The quest to eradicate obesity” STAT December 27, 2023

Healthcare Investors

Global, US health spending projections: Per WTW, global health costs are projected to increase 9.9% in 2024 vs. +7.4% in 2022 and 10.7% in 2023. In North America, +9.4% in 2024 vs. 8.0% in 2022 and 9.8% in 2023.

Per CMS Actuaries, in the U.S., spending increased 9.6% in 2022 vs. 9.4% in 2021 and 9.3% in 2020 to $4.5 trillion/$13,493 per person. Other details:

  • The uninsured population declined in 2022 for the third straight year, falling from 28.5 million in 2021 to 26.6 million in 2022.
  • Private health insurance spending (5.9% growth)reached $1.3 trillion in 2022 and accounted for 29% of total health expenditures.
  • Medicaid spending (9.6% growth)—reached $805.7 billion in 2022, accounting for 18% of total national health spending.
  • Hospital spending (2.2% growth)reached $1.4 trillion in 2022, representing 30% of overall healthcare spending.

2024 Global Medical Trends Survey – WTW (

CMS Office of the Actuary

Federal Regulatory Recap (December 15-31, 2023)

FTC Report: 2022 consolidation actions:  In 2022, the FTC challenged 50 merger and acquisition proposals across all sectors of the economy including 6 in healthcare per its annual report for the fiscal year ended Sept. 30 on the Hart-Scott-Rodino Act premerger notification program issued last Thursday.

CMMI:  The Innovation Center announced the Transforming Maternal Health (TMaH) Model which will collaborate with state Medicaid agencies in reducing disparities in access and treatment with a focus on “whole person delivery”.

White House: March in rights proposal to set drug prices: — “The march-in proposal, if enacted, will confiscate property and America’s innovation engine will shut down. The Chamber is committed to using our convening power to mobilize the business community to stop the Administration from destroying America’s innovation sector.” Note: the US Chamber of Commerce and 100 large employers are opposed citing government intervention in pricing by private companies a ‘dangerous precedent’.

HHS: No Surprises Act Final Rule: Providers and insurers that use the No Surprises Act’s arbitration process will have to pay $115 per dispute per a final rule issued December 19– less than half of what they would have paid under the Biden administration’s proposed fee increase earlier this year.

DOJ-FTC issues Merger Guidelines: On December 18, the DOJ and FTC released 2023 Merger Guidelines suggesting a more aggressive approach to its consideration oversight by lowering market concentration factors that trigger their challenges.

Census Bureau Year end population growth: On January 1, 2024, the U.S. population was 335,893,238–an increase of 1,759,535 (0.53%) from Jan. 1, 2023; the projected world population, is 8,019,876,189, an increase of 75,162,541 (0.95%) from New Year’s Day 2023.