As healthcare organizations enter 2026, they face a landscape defined by regulatory uncertainty, financial pressure, and operational transformation. From heightened federal enforcement and workforce challenges to shifting care delivery models and funding strategies, the year ahead will test how well health systems adapt to rapid change. Advis’s leadership team have shared their 2026 healthcare predictions, highlighting the trends, risks, and strategic decisions that will shape the future of the industry.
Jake Beechy, J.D., MBA – Vice President
Continued Disruption in the 340B Program
Last year, I predicted that the 340B landscape was on the verge of fundamental change:
“Your 340B program will not look the same by December 2025. We will see an overhaul to the basic 340B qualification framework. Good or bad, best to prepare.”
I was right!… Unfortunately, the resulting changes, most notably the implementation of the 340B Rebate Model, have been far more harmful than helpful. Compounding the challenge, covered entities were afforded little meaningful time to prepare, with an effective runway of roughly 60 days. For more than two years, I anticipated that Congress would step in to provide a long-overdue regulatory overhaul, one that would clarify statutory intent and stabilize program operations. I was wrong. Congress has failed to deliver any meaningful legislative guidance.
There is little reason to believe the coming year will be any different. In 2026, it is likely that HRSA will expand its “pilot” Rebate program and continue to mirror the drugs subject to the Medicare Drug Price Negotiation Program. At the same time, manufacturers will continue to find ways to disrupt and restrict the program. Congress will ultimately point to the program’s continued operation as evidence that intervention is unnecessary.
What will remain unseen to legislatures is that the continued viability of the 340B program is not the product of policy stability, but rather the result of deliberate, resource-intensive actions taken by covered entities dedicated to preserve the program’s intent: enabling safety-net providers to stretch limited federal resources and continue serving vulnerable and underserved communities.
Bryan Niehaus, J.D., CHC- Vice President
2026 Healthcare Prediction: Regulatory Optimization as a Core Financial Strategy
Key regulatory schemes with revenue implications, including 340B, site-neutral / provider-based status, and related regulatory designations must be managed as core financial planning functions. As CMS continues to recalibrate payment policy and tighten alignment between site of care, ownership, and billing status, organizations that proactively model regulatory scenarios (rather than react to audits or rate changes) will protect margins and preserve capital flexibility. The advantage will shift to providers that integrate regulatory structure, reimbursement forecasting, and long-range planning into a single decision framework—ensuring policy shifts translate into strategic adjustments, not revenue surprises.
Monica Hon, J.D. – Vice President & Director of Client Solutions
Risk-Based Outsourcing Arrangements
In 2026, we will continue to see outside of the box thinking in the C-suite. As organizations increasingly seek specialized expertise without expanding their in-house teams, turning to risk-based outsourcing arrangements for key operational functions like enrollment, credentialing, billing, coding, and compliance will be a popular way for many to share the burden and benefits. This strategic approach allows organizations to leverage third parties’ best practices while implementing a structured framework to identify, assess, and manage compliance and financial risks. By ensuring robust controls, continuous monitoring, and clear responsibility-sharing, these arrangements allow organizations to access a high level of expertise while maintaining effective oversight and budgetary control.
Ryan Bailey, J.D., CHC – Vice President
Federal Agencies Shift from Guidance to Enforcement
In 2026, CMS, HRSA, and other agencies will shift from setting expectations to active enforcement, using price transparency files and claims data to identify hospitals that are operationally behind. Hospitals that treat compliance as a checkbox rather than a defensible, reconciled process will face heightened audit risk and potential financial exposure, particularly around site-neutral payment, 340B transparency and rebates, and outpatient services. Financial forecasting and downstream operational readiness — not just policy awareness — will be key differentiators for health systems in staying ahead of enforcement.
Robert Monroe, J.D. – President & CEO
Staffing Shortages Deepen for Rural Healthcare Providers
2026 will see exacerbated healthcare staffing shortages in rural areas. Rural providers are already planning and bracing for a future with fewer Medicaid-eligible and ACA-covered patients. Now rural providers must disproportionately contend with $100,000 H-1B visa fees in economically challenged areas. While the Rural Health Transformation Program as authorized by the One Big Beautiful Bill Act has a focus on clinician and allied professional workforce development, the program will not meaningfully stem an already present and growing problem for rural healthcare.
Preston Sisler, J.D. – Vice President
Annual Accreditation in 2026: A Turning Point for DMEPOS Suppliers
Suppliers of Durable Medical Equipment, Prosthetics and Orthotics, and Supplies (“DMEPOS”) are required, with limited exception, to be accredited by a CMS-approved accrediting organization to enroll in and bill Medicare. Beginning in 2026, DMEPOS suppliers will be required to be surveyed and reaccredited every year (as opposed to the current three-year cycle). CMS also plans for stronger oversight of accrediting organizations. For 2026 and forward, DMEPOS suppliers should plan for a potential increase in accreditation fees and focus more on resource allocation to compliance infrastructure. In the longer term, these additional requirements could disproportionately impact smaller DMEPOS suppliers, resulting in the reduction of active Medicare-enrolled suppliers in favor of larger organizations. Top performing organizations will be proactive in meeting the requirements of a shorter accreditation cycle in an already scrutinous regulatory environment.
Susan Maupin, J.D., R.N. – Vice President & Director of Healthcare Operations
Care Delivery Transformation Accelerates
Due to significant changes in the healthcare space, 2026 is anticipated to bring significant changes in the way care delivery is provided. Healthcare facilities will need to make changes in the manner healthcare is delivered, continuing to do more with less all while maintaining patient and provider satisfaction. With many healthcare providers already having gone through expense reduction exercises to address reimbursement shortfalls, 2026 is expected to focus on growth strategies to remain financially viable. For those unable to meet those needs, strategic plans will be necessary to explore potential partnerships, mergers, or joint venture opportunities.
Ryan Yokley, J.D., MHA – Vice President
FEMA Remains a Critical Funding Source for Hospitals
Although it is anticipated FEMA will wind up most COVID-19 funding activities in the coming year, Advis predicts FEMA will continue to serve a significant source of critical federal funding for private non-profit hospitals in 2026 and beyond. Climate change and other factors are resulting in natural disasters/major weather events to occur with increased frequency and intensity. As such, Advis recommends health systems act now in anticipation of future disaster events. The Advis team are experts in FEMA funding matters and are available to assist your organization with implementation of key operational practices crucial for optimizing your opportunities to receive FEMA funding.
Natasha Shukla, J.D., CHC – Senior Consultant
Coverage Changes Drive New Cost-Effective Care Models
Changes to the regulatory framework in 2025 will likely precipitate a shift towards more cost-effective care models in 2026. As key provisions of the One Big Beautiful Bill Act begin impeding coverage eligibility for patients, hospitals will likely need to reevaluate financial assistance and charity care policies. Additionally, health systems will continue implementing cost mitigation strategies, like patient education and the potential for increased home-based care opportunities.
Sylvie Brick, M.S. – HSM – Senior Consultant
Price Transparency Becomes an Operational Cost Center
In 2026, hospital price transparency will evolve from a compliance requirement into a standing operational function requiring dedicated resources, systems, and cross-functional ownership. CMS’s recent transparency proposals raise expectations around data standardization, update cadence, and internal consistency, making “publish and forget” approaches unsustainable. Health systems will need to intentionally invest time and money across contracting, finance, revenue cycle, and IT to maintain accurate, defensible files as payer complexity increases. Organizations that fail to operationalize transparency will experience rising administrative burden and reputational risk, while those that embed transparency into contracting and financial workflows will be better positioned to manage costs and understand true net reimbursement.
Published January 15, 2026
