The First 100 Days: Health Care's Critical Deadlines in 2025

The 119th Congress faces immediate health care deadlines amid significant leadership transitions. While much attention focuses on high-profile nominations like Dr Oz for Centers for Medicare & Medicaid Services (CMS) Administrator and Robert F. Kennedy Jr. for Department of Health and Human Services (HHS) Secretary, the real action lies in less visible but equally crucial areas: congressional deadlines, committee dynamics, and the quiet power of advisory bodies shaping health care policy.

March Madness: More Than Basketball (I don't really understand sports)

The continuing resolution (CR) enacted in December 2024 included several short-term extensions of health provisions, with a March 14, 2025, deadline looming. Congress must either pass another CR through the fiscal year’s end or complete a full fiscal year (FY) 2025 appropriations package. This deadline affects numerous health care programs and presents an opportunity to revisit the bipartisan health care package unveiled in December but left out of the CR.¹

The Stakes Are High

Several major health care initiatives hang in the balance as Congress approaches key deadlines and policy decisions:

• Medicare Drug Price Negotiations: The program completed its first round of negotiations in 2024, with prices set to take effect in 2026. The second round, covering 15 Part D drugs, faces selection deadlines by February 2025.
• Public Health Programs: Recently signed legislation includes reauthorizations for emergency medical services for children, autism research and coordination, and cardiomyopathy education. These reauthorizations, tied to the March 14, 2025, CR deadline, could face lapses if Congress does not act in time. Without timely funding, these programs could encounter delays or disruptions, potentially affecting research progress and public health outcomes.¹
• New Initiatives: HHS's artificial intelligence strategic plan demands coordination across medical research, health care delivery, and public health domains. This plan, scheduled for phased implementation beginning mid-2025, requires timely action to ensure advancements in health care technology and data integration remain on track. Delays in implementing this strategy could hinder advancements in health care technology and data integration.²

A Complex Web of Authority

The post-Chevron landscape adds another layer of complexity. Without automatic deference to agency interpretations, the relationship between congressional intent, agency action, and advisory committee recommendations becomes even more critical.

This shift significantly impacts how agencies like CMS and the Food and Drug Administration (FDA) interpret their statutory authority. It highlights the need for alternative approaches to evaluating evidence and making decisions that align with evolving health care demands.

The Quiet Power of Advisory Bodies

Federal advisory committees, such as the Advisory Committee on Immunization Practices (ACIP), play a pivotal yet often understated role in shaping healthcare policy. Operating behind the scenes, these committees convene experts from diverse fields to provide evidence-based recommendations that influence legislative and regulatory decisions. Their work ensures that policies are grounded in the latest scientific understanding and practical considerations, bridging the gap between complex data and actionable insights.

While high-profile nominations at HHS and the FDA often dominate headlines, it is the steady, methodical work of career staff and advisory committee members that drives the continuity of health policy. The power of these committees extends beyond their formal recommendations. Advisory bodies like ACIP create forums for stakeholders to engage in meaningful dialogue, identify emerging challenges, and foster innovation in policy design.

Their influence is particularly significant in areas demanding specialized expertise, such as vaccine distribution strategies, addressing health disparities, and integrating new healthcare technologies. As RFK Jr., a vocal advocate for vaccine transparency, steps into his potential role as HHS Secretary, the interplay between his vision and ACIP’s agenda could be profound.

Importantly, advisory committees are not passive entities; they can set their own agendas within their mandates. For ACIP, this could mean proactively addressing concerns around vaccine safety and efficacy or exploring new methodologies for public health communication. By taking a forward-looking approach, ACIP and similar bodies offer crucial insights into the future direction of healthcare policy, reinforcing their indispensable role in shaping a healthier, more equitable society.

Looking Ahead

The next few months will be pivotal for health care policy. Key dates to watch include:

• February 2025: Second-round Medicare drug price negotiation selections
• March 2025: Manufacturer data submission deadline
• March 14, 2025: CR and health extender deadline
• June 2025: Initial price offers due
• September 2025: Completion of negotiation meetings

The stakes of missing these deadlines are significant. Funding gaps or delays could disrupt critical health care programs and services, impacting patient care and research initiatives. Federal advisory committees will play a crucial role in mitigating these risks by providing timely insights and recommendations to guide decision-making.

The interplay between congressional deadlines and advisory committee work will shape health care policy implementation throughout 2025. Whether through legislation, regulation, or committee recommendations, these decisions will influence health care delivery and access for years to come.

Join me on Wednesdays as I highlight key court decisions, review notable health policies, and analyze what’s behind the bill in health care.

References

1. Committee for a Responsible Federal Budget. Upcoming congressional fiscal policy deadlines. Updated January 9, 2024. Accessed January 14, 2025. https://www.crfb.org/blogs/upcoming-congressional-fiscal-policy-deadlines

2. Assistant Secretary for Technology Policy. HHS artificial intelligence strategic plan. Updated January 10, 2025. Accessed January 14, 2025. https://www.healthit.gov/topic/hhs-ai-strategic-plan