Jen Garvey, of the Office of Legislative Council, briefed the Senate Health & Welfare committee on a series of 2025 health-related acts and flagged implementation and budget items the committee will need to track.

The most structural change Garvey highlighted is Act 2, which permanently unmerges Vermont’s individual and small-group health insurance markets so each market has separate community rating and risk pools. "This currently unmerged those markets so we stopped having to do a 1 or 2 year unmerging," Garvey said, noting the change ends the temporary unmerging that had been used to maximize federal dollars for people who qualify for assistance. Committee members asked for follow-up about how premium and subsidy dynamics will shift for people with chronic illnesses.

Garvey summarized several technical and administrative fixes across the package. Act 3 narrows the definition of "primary care provider" for prior-authorization exemptions to providers who are contracted and enrolled as primary care with a health plan and exempts out-of-state provider claims from certain Vermont claim-edit requirements unless the insurer and out-of-state provider agree. Act 11 reorganized Title 8’s health-insurance chapter and aligned statutory definitions and numbering.

On Medicaid policy, Garvey described a new requirement directing the Agency of Human Services secretary to calculate Medicaid payment rates for community-based service providers that are "reasonable and adequate" to achieve required outcomes. The act requires a methodology for periodic in-depth rate studies, annual inflation adjustments, and a requirement that the secretary report recommended rates and the estimated annual cost to fund them as part of the agency’s budget presentation. Garvey emphasized the statute requires reporting and analysis but does not itself guarantee rate increases.

Act 15 raises monetary thresholds that trigger a certificate-of-need (CON) review and adds several new CON exclusions (for example, fully depreciated medical equipment and certain state-funded projects) so fewer projects will require CON review; it also directs AHS to establish a stabilization-assistance process providers can request if they are at imminent risk of closure and to provide an implementation update to the committee.

On maternal and perinatal services, the committee heard that licensure requirements were created for freestanding birth centers, including staffing and transfer policies to hospitals when higher levels of care are necessary. Act 50 establishes a voluntary certification for community-based perinatal doulas through the Office of Professional Regulation and directs AHS to seek a federal state-plan amendment by July to allow Medicaid coverage of certified doula services; doulas may continue to practice without certification but must be certified to be reimbursed by Medicaid.

Act 21, a medical-debt relief measure from the treasurer’s office, appropriates $1,000,000 to contract with a nonprofit to acquire and repay qualifying medical debts for Vermont residents with specified eligibility criteria (residency, income at or below 400% of the federal poverty level or medical debt at least 5% of household income, and an outstanding patient balance after routine collection). Garvey noted a projection in the presentation that the appropriation could buy down substantially more than face value, saying the $1 million was projected to cover approximately $100,000,000 of written-off medical debt; committee members asked for an update from the treasurer’s office on program progress.

Pharmaceutical and hospital finance items include Act 55’s restrictions on certain manufacturer actions affecting 340B contract pharmacies, annual hospital reporting on 340B participation through 2030 (act expiration 2031), and a cap on amounts hospitals may charge insurers for outpatient-administered prescription drugs set at 120% of average sales price as of April 1, 2025. Garvey said the board may adjust hospital reimbursement rates if caps negatively affect access, quality or rural sustainability, and independent critical-access hospitals unaffiliated with a network are excluded from the cap.

Garvey also outlined Act 49, which grants short-term authority for the Green Mountain Care Board to reduce a domestic insurer’s reimbursement rates to one or more Vermont hospitals if the insurer faces an acute and immediate threat of insolvency; the authority includes limits tied to hospital fiscal criteria and is temporary unless extended. The act authorizes midyear adjustments to hospital commercial reimbursement rates to keep hospitals within approved budgets and allows appointment of an independent hospital observer under specified circumstances.

Other governance changes include Act 6’s expanded role for the Office of the Health Care Advocate (greater participation in rate reviews and access to confidential information when appropriate), and Act 62’s removal of some duties from the Green Mountain Care Board, adjustments to ACO certification and budget review processes, and new fees for certification and review.

Committee members asked operational and fiscal questions—how at-risk hospitals stay solvent, where state assistance has been used, and how the Green Mountain Care Board’s rate-setting and budget tools factor into hospital finances. Garvey and members agreed several items will move into the budget and implementation-review processes and that the committee should seek updates from AHS, the Green Mountain Care Board and the treasurer’s office on rollout and fiscal notes.

The briefing closed with Garvey noting fiscal notes and implementation actions are ongoing and that the committee will be watching the budget process and agency reports for details needed to evaluate the acts’ effects.