HCA Healthcare, Inc. (HCA) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that HCA Healthcare, Inc. surfaced in its latest filing.

• Total indebtedness was $46.492 billion as of December 31, 2025, with $5.779 billion available under the senior unsecured credit facility and $2.207 billion outstanding under the commercial paper program.December 31, 2025
• Enhanced premium tax credits from COVID-19 relief legislation expired at the end of 2025, and the FBA includes health care policy changes expected to reduce Medicaid spending and alter state Medicaid program administration.2025
• In March 2025, HHS announced a significant agency restructuring intended to reduce the HHS workforce and consolidate divisions.March 2025
• A June 2025 CMS final rule on Exchange affordability and consumer protections is subject to legal challenges, and a federal district court issued a nationwide stay of several provisions in August 2025.June 2025
• CMS finalized payment reductions under the outpatient PPS to offset invalidated 340B Drug Pricing Program changes, with non-drug service reductions in CY2023 and additional reductions starting CY2026.
• CMS is phasing out the Medicare inpatient-only list over a three-year period beginning in 2026, allowing more procedures to be performed on an outpatient basis, including in the ASC setting.2026
• In 2026, CMS is implementing the WISeR model, requiring providers to submit prior authorization requests or undergo post-service, pre-payment medical review under fee-for-service Medicare.2026
• Beginning January 2026, CMS requires hospitals in selected markets to participate in TEAM, a bundled payment model for five specified surgical episodes.January 2026
• Beginning January 2027, specialists treating heart failure and low back pain in outpatient settings in selected geographic areas will be required to participate in the Ambulatory Specialty Model.January 2027
• HHS announced a policy change limiting public participation in rulemaking.
• Loper Bright Enterprises v. Raimondo Supreme Court decision expands judicial scrutiny of agency authority.
• The FBA imposes work or community engagement requirements for adults under age 65 in Medicaid expansion states and restricts federal matching funds for state Medicaid programs.
• The FBA requires HHS to cap Medicaid managed care payment rates for specified services at Medicare rates, expected to impact states including Texas.
• CMS announced in September 2025 that it would expand eligibility for high-deductible catastrophic health insurance plans.September 2025
• Temporarily enhanced premium tax credits established by COVID-19 relief legislation expired at the end of 2025.2025