The One Big Beautiful Bill Act Has Passed: What Healthcare Providers and Plans Need to Know Now
- Jessica Zeff
- Jul 10
- 3 min read
The One Big Beautiful Bill Act (OBBBA) has passed—and with it comes a new set of compliance challenges for healthcare providers, health plans, and hospitals of all sizes.
While much of the news coverage focuses on politics and funding cuts, the operational and compliance implications are immediate and real. Whether you are a health plan, hospital, critical access hospital, or physician practice, understanding these changes now can protect your organization from audit risk, civil rights complaints, and financial disruption.
What Does the OBBBA Do?
Key healthcare provisions include:
Medicaid work requirements (80 hours/month) and eligibility redeterminations, risking coverage losses for millions.
Bans Medicaid coverage for gender-affirming care and restricts funding for clinics providing abortion services.
Ends automatic re-enrollment in ACA marketplaces while tightening income verification.
Imposes 4% annual Medicare payment cuts over the next eight years.
Caps federal loans for medical education and ends certain loan forgiveness programs.
Compliance Implications for Providers and Plans
1. Medicaid Work Requirements and Eligibility Redetermination
Who is impacted?Health plans (especially Medicaid MCOs), hospitals (including safety-net and critical access hospitals), and practices serving Medicaid populations.
Compliance considerations:
Increased disenrollment risk among vulnerable populations could disrupt revenue and care continuity.
Health plans must build or enhance eligibility verification and work tracking systems.
Providers will need scripts and workflows to help patients navigate new requirements.
Potential ADA and Section 1557 exposure if disenrollments disproportionately impact people with disabilities or caregivers.
2. Gender-Affirming Care Bans
Who is impacted?Hospitals, clinics, and providers delivering gender-affirming care; Medicaid plans.
Compliance considerations:
Conflict between state bans and federal nondiscrimination rules (Section 1557).
Potential for OCR complaints, litigation, and reputational risks.
Need to review clinical and billing policies, ensure consistent documentation of medical necessity, and prepare staff for sensitive patient communications.
3. Medicare Payment Cuts (4% Annually)
Who is impacted?Hospitals, critical access hospitals, skilled nursing facilities, physician practices, and health plans managing Medicare.
Compliance considerations:
Reduced payments may cause providers to reassess participation in Medicare, impacting network adequacy.
Risk of improper cost-shifting to other payers or patients, creating False Claims Act or Anti-Kickback exposure.
Contract amendments with payers and providers may be needed to align with reduced rates.
Possible increased CMS audits on cost reports and billing practices.
4. ACA Marketplace Changes
Who is impacted?Health plans participating in ACA marketplaces, hospitals providing charity care, and providers treating uninsured patients.
Compliance considerations:
Stricter income verification and enrollment limitations will increase administrative burden.
Potential spike in uninsured patients, leading to higher uncompensated care.
Plans must update eligibility and enrollment procedures, staff training, and documentation practices.
5. Workforce and Training Implications
Who is impacted?Academic medical centers, residency programs, and hospitals reliant on trainees.
Compliance considerations:
Loan caps and loss of forgiveness programs may reduce interest in medical education, exacerbating staffing shortages.
Potential risk to GME program accreditation and HRSA/CMS reporting compliance.
Hospitals should evaluate succession plans and coverage requirements under participation agreements.
6. Expanded Audit Authority
Who is impacted?All providers and plans billing Medicare and Medicaid.
Compliance considerations:
OBBBA expands CMS and OIG audit capabilities, including extrapolated audits.
Providers must reinforce documentation practices, ensure consistent coding, and prepare for medical necessity reviews.
Proactive internal auditing and training will be essential to mitigate repayment and penalty risks.
Next Steps for Healthcare Compliance Teams
Review and update SOPs for enrollment, eligibility, and billing in light of OBBBA changes.
Train front-line staff on new Medicaid and ACA requirements to avoid inadvertent errors that lead to complaints or coverage disruptions.
Prepare for reduced Medicare revenue with a compliance lens to avoid risk-prone shortcuts.
Conduct an internal audit of current documentation and billing practices to strengthen readiness for increased federal audits.
Engage legal and compliance teams to assess conflicts between federal and state regulations, especially around gender-affirming care.
Brief leadership on anticipated operational and revenue impacts, advocating for resources to strengthen compliance infrastructure during this transition.
Final Thoughts
The OBBBA is not just another bill—it is a fundamental shift in how healthcare will be accessed, delivered, and audited in the coming years.
For healthcare providers, health plans, hospitals, and critical access hospitals, proactive compliance planning is essential to protect your organization, your patients, and your bottom line.
At Simply Compliance, we help you navigate these changes with clear guidance, policy updates, staff training, and audit readiness support—ensuring you can focus on delivering care while staying compliant in a shifting regulatory landscape.
Need help preparing for OBBBA’s implementation?
Contact us today to schedule a readiness review or policy update consultation tailored to your organization.
Do you have questions about this blog? Please contact jessicazeff@simplycomplianceconsulting.com
— Jessica
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