Last year at this time, we enjoyed reading Dan Diamond's piece for the Washington Post on how reversing the recent decline in U.S. longevity has never been an explicit political priority. Basically because that goal seemed, as of December, 2023, like simply too much to take on, what with our fragmented healthcare system, the perversity of healthcare incentives, White House turnover being too fast for such a long-term goal, and more. Well, that was then, and this is now. Move over, "increasing US life expectancy," because the incoming Trump healthcare regime is flying the banner of an even broader public health idea: "Make America Healthy Again".
Make America Healthy Again is currently more slogan than blueprint
'Make America Healthy Again', sometimes abbreviated to MAHA, is a slogan popularized by Robert F. Kennedy Jr. (RFK Jr.), Trump's current nominee for HHS. While its sweeping scope boggles the minds of healthcare insiders, its fans are not yet asking too many questions about what it entails. Internet search data supports this: In first week of December, 2024, out of the top 100 searches for "Make America healthy again" by volume, ten were phrased specifically to discover what the plan might be. In contrast, 31 of the top 100 top searches looking for Make America Healthy Again hats, signs, stickers, sweatshirts, t-shirts and, uh, crop tops.
But what might actually go on such a blueprint?
OK but, if an actual Make America Healthy Again blueprint appears, what might be on it? Let's assume that this banner doesn't encompass all the potential actions that the Trump administration/GOP-controlled congress might take that would impact the industry. Assuming it primarily relates to public health and actions within the HHS world, we can do a bit of a thought experiment.
This post will:
Summarize Make America Healthy Again's major rhetorical themes
Crosswalk the themes with some some purely hypothetical "what would that look like" HHS actions
Do a quick reality check: How feasible are these ideas—especially the most unusual and/or disruptive ones?
Spoiler alert: This exercise showcases that while some actions would go over just fine in the industry (more primary care-oriented pilots from CMMI?), HHS would face significant hurdles in implementing regulations that line up with the fiercest of the Make America Healthy Again rhetoric. (If that is even a goal!)
Make America Healthy Again's main rhetorical themes
Here are the apparent pillars of Make America Healthy Again, based on on-the-record quotes by RFK Jr. and his allies.
Reducing the incidence of chronic disease
Emphasizing individual health choices over mandated interventions
Protecting the public against perceived-harmful environmental factors
Championing alternative/"natural" therapies and foods
Reducing corporate influence on public health
Overhauling federal health agencies
Potential HHS actions under a Make America Healthy Again regime
Taking "overhauling federal health agencies" off the list because it's SO non-specific, here are some hypothetical ways the themes could translate into actions by CMS, FDA, CDC, and NIH.
Because RFK Jr. himself has attracted quite a lot of resistance from the healthcare and scientific establishment, each hypothetical action is paired with an assessment of the degree of resistance that specific proposal could face from the healthcare industry and its political champions.
Hypothetical CMS actions under Make America Healthy Again
Focusing on community health.
What this could look like: Launching more (potentially old-school) primary care- or FQHC-focused reimbursement pilots in Medicare and Medicaid.
Industry resistance factor: Zero.
Incentivizing healthcare providers to prevent chronic diseases.
What this could look like: Recent reports suggest RFK Jr. and his advisors are considering tackling a rebalancing of physician RVUs in favor of primary care (and in disfavor of specialists). How about that for a mid-2000s flashback?
Industry resistance factor: Split. Depending on the magnitude of the rebalance, anywhere from high to sky-high among specialty-oriented providers. But this is a very popular idea among many traditional population health and primary-care oriented groups.
Ramping up enforcement on drug pricing.
What this could look like: Drug negotiations are likely going to proceed per the IRA schedule. But CMS might increase its monitoring of drug price trends, and step up enforcement and penalties for manufacturers who fail to make negotiated prices available to eligible individuals and dispensers.
Industry resistance factor: Medium. Life sciences would resist these steps but they are essentially an extension of current course and speed.
Adding reimbursement for alternative therapies.
What this could look like: Acupuncture, holistic medicine, maybe even psychedelic-assisted therapy (following FDA approvals).
Industry resistance factor: Medium to high. Depending on what is approved (and how weak its evidence base is), insurers and providers, especially professional associations, would fight this. Main concerns: Increasing health spending without evidence of cost-efficacy; malpractice risk; and concerns about decoupling the FDA approval threshold from what healthcare organizations believe to be a robust evidence standard.
Hypothetical FDA actions under Make America Healthy Again
Curbing D2C pharmaceutical advertising.
What that could look like: The FDA could tighten rules on the claims life sciences companies can make in DTC ads, requiring more explicit and extensive disclosures of risks versus benefits. They could require pre-approval for all DTC advertisements, with stricter public health standards. They could try to make a moratorium on advertising new drugs until they have been on the market for several years and had more post-market surveillance.
Industry resistance factor: Massive. Life sciences would fight this with everything they've got.
Curbing D2C online prescribing.
What this could look like: Making Medicare (and possibly Medicaid) reimbursement contingent on stricter patient identity verification and in-person evaluations for certain prescriptions.
Industry disruption factor: Massive. Note, in addition to being a blow to life science strategy, this would also sow chaos in today's digital health startup world.
Changing the new-vaccine approval process.
What this could look like: The FDA's purview extends almost entirely to new vaccines, not those already on the market. In theory, the agency could revisit the vaccine approval processes to align with vaccine skepticism. For example: Developing new guidelines for vaccine evaluation, possibly slowing the approval process, or mandating more extensive safety studies.
Industry disruption factor: High. Life science, political, and public health leader outcry would follow—but, not as drastic an upheaval as would greet efforts to undermine vaccines already on the market (see CDC hypothetical actions, below).
Strengthening chemical and additive bans.
What this could look like: Proposals to eliminate harmful chemicals and additives in food (e.g., pesticides, GMOs, fluoride in water). The FDA doesn't have the authority to do this by itself, these issues are spread across multiple agencies (EPA, USDA). But, the FDA could try to push some of these items off the GRAS (Generally Recognized as Safe) list for food additives and push for stricter safety studies.
Industry disruption factor: Medium. Would affect non-healthcare sectors more directly.
Expanding trials for alternative therapies.
What this could look like: Increasing funding for and approval of clinical trials for non-traditional therapies (e.g., psychedelics for mental health).
Industry resistance factor: Low. As long as it's just trials, this will be far from the most controversial move the FDA could make.
Hypothetical CDC actions under Make America Healthy Again
Here is where the rubber could meet the road with regard to the red-hot topic of vaccines that are already on the market. CDC actions could include:
Adjusting vaccination schedules.
What this could look like: Revising recommendations, reducing doses, narrowing population targets, or removing certain vaccines from routine recommended schedules.
Industry resistance factor: Sky high. Given the broad agreement on the safety, efficacy, and public health necessity of existing vaccines, life sciences, providers, insurers, and public health leaders would all band together to fight this, or even figure out ways around it (more commentary below)
Shift public health messaging on vaccines.
What this could look like: Emphasizing the risks or "informed choice" for vaccines, potentially reducing public confidence and uptake.
Industry resistance factor: Sky high, same as above.
Launching new, chronic-disease-prevention public health campaigns.
What this could look like: Campaigns targeting lifestyle and environmental factors.
Industry resistance factor: Depends on what these campaigns say. Could be anywhere from public-health-business-as-usual, to stirring up huge controversy, e.g., if they focus on food additives, pesticide use, or fluoride in public water.
Hypothetical NIH actions under Make America Healthy Again
Shifting research funding.
What this could look like: Redirecting funds from pharmaceutical research to lifestyle-based and environmental health research. For example: Increasing grant funding for studies exploring the links between environmental toxins and chronic illnesses; prioritizing funding for studies on diet, exercise, and sustainable farming practices.
Industry disruption factor: Depends, but a major shift away from discovery in high-revenue life science priorities could heavily affect AMCs and life sciences.
Reality check time: How feasible are these ideas?
Now let's now revisit these purely hypothetical regulatory actions and reality-check them. Here are some highlights.
Our view: Vaccine-related actions would be extremely hard to implement.
While it's powerful rhetoric to some, actually implementing vaccine-skeptic-type regulatory changes would cause such an uproar, we could see it touching off a 'separation of health and state'-type movement.
It's not every day that an issue unites providers, payers, and the life sciences, but any effort to undermine vaccine schedules would do just that. Providers could part ways with a politically-tainted vaccine schedule from CDC, with pediatric and primary care associations refusing to endorse such guidelines. Of course, it would cause a bureaucratic mess, as insurers, state governments, daycares, etc., would have to figure out what to require of families as many current standards say "comply with CDC recommendations."
Also, there is plenty of support for vaccines among traditional Republicans. Just last week, childhood polio survivor Mitch McConnell sent a shot across the bow: “Efforts to undermine public confidence in proven cures are not just uninformed — they’re dangerous. Anyone seeking the Senate’s consent to serve in the incoming Administration would do well to steer clear of even the appearance of association with such efforts.”
Of course even without concrete regulatory action, simply having an HHS official talking about such connections, and giving credence to conspiracy theories, is harmful because it gives oxygen to misinformation.
The assertive version of 'get corporate influence out of public health' initiative would put RFK Jr. et al on a collision course with the life sciences industry and its supporters
The life science industry would come out hard against many of these hypothetical ideas, especially any efforts to curb D2C consumer advertising or put the post-pandemic, post-telehealth waiver genie of D2C online prescribing back in the bottle. The life sciences industry would bring everything it's got to bear against these actions.
In general, and certainly when it comes to adverse policymaking against the life sciences, a number of Make America Health Again's ideas run counter to corporate interests. That means in terms of political support, these ideas will effectively split the GOP's traditional, anti-regulatory faction against the new, more populist, "fight big pharma and big food" faction.
Bonus speculation: The case of GLP-1s
The case of GLP-1s offer an especially fascinating mini-case study into the diverse ideological mix in the Team Make America Healthy Again talking points, and the implementation barriers its agenda may face.
Issue recap: Expanding coverage for GLP-1s; e.g., Ozempic, Mounjaro, etc., is a major open question for the healthcare industry. Demand for expansive coverage is tremendous, and there is running room for even more utilization than we have seen to date. Spending in this area is spiking, causing major concerns to payers (federal, private, and employer). It's unclear how much GLP-1s "pay for themselves" in health gains and/or chronic condition prevention and cost avoidance. The openness of this question is evident in GLP-1 coverage inconsistencies today among private payers.
And now, the Make America Healthy Again lens. RFK Jr. has been a loud critic of GLP-1s, so simplistically, one might think that an incoming Make America Healthy Again regime would spell disaster for drugmakers. RFK Jr. has pointed to GLP-1s as an example of over-spending and over-reliance on pharmaceutical interventions versus healthier lifestyles and greater access to healthy foods. Dr. Martin Makary, nominated for FDA head, is also a GLP-1 critic, pointing to their high price tags, question marks on long-term efficacy compared to non-pharmaceutical interventions, and issues with side effects, especially muscle loss.
Notable RFK Jr. quote: “When I’m working in the next administration, I will address our sick food system—and the corrupt government agencies—to help make our country healthy again, In the meantime perhaps we should consider replanting the kitchen garden before sending more money to Denmark."
(Why Denmark? Because it is home to Novo Nordisk, maker of Ozempic and Wegovy.)
Challenges with stemming the tide of GLP-1s
However, from a regulatory implementation viewpoint, there is insufficient reason for GLP-1 makers (or other pro-GLP-1 stakeholders) to panic yet:
As to HHS restricting D2C advertising and online prescribing, yes, that would be a major wrench that could be thrown into the GLP-1 works. But, we have already talked about how hard life science companies and their supporters would fight both these ideas.
Turning to Medicare and Medicaid, it's going to be hard for payers to resist coverage of GLP-1s if they continue to enjoy massive patient (voter) demand, while also boosting life science revenues, AND if they ultimately pay for themselves by reducing chronic disease burden. This is, of course, an unknown at this point; it's a classic population health bet with few facts behind it as of today. But, the CBO, at least, has recently came out with a vote for the long-term cost-efficacy of GLP-1s. Their model, released in October, forecasts that expanding Medicare and Medicaid coverage would increase federal spending in the short term, but pay for itself (just barely) in avoidable admissions down the road. This model offered fiscal justification for CMS's follow-on move to propose expanded GLP-1 coverage in Medicaid and Medicare, released Nov. 26 in the Medicare Advantage and Medicare Part D Proposed Rule for 2026 (open for public comment now)..
At a personal level, Team Make America Healthy Again itself appears to be divided on the value of GLP-1s. While RFK Jr. and Dr. Makary are not GLP-1 fans, Dr. Mehmet Oz, nominated for head of CMS, does appear to be one. Granted, this was a few years ago, but In February of 2021, Dr. Oz helped introduce the US public to semaglutides on an episode of his show titled, "Could a diabetes drug cure obesity?" Dr. Oz told his audience that "This medication is one and a half to two times more effective than any of the currently available medications on the market" for weight loss. If confirmed as CMS chief, Dr. Oz would presumably have the most direct influence over GLP-1 coverage and reimbursement policy.
More conciliatory signals, from milder quotes to friendly dinners
After having previously said that drugmakers were "counting on selling [GLP-1s] to Americans because we are so stupid and so addicted to drugs." RFK Jr. recently told reporters (very briefly) that actually, he views GLP-1s as 'having a place' in patient treatment, if other tactics fail. That's a pretty big switch.
And, according to the Washington Post, president-elect Trump recently hosted RFK Jr. for a friendly dinner at Mar-a-Lago along with chief executives of Pfizer, Eli Lilly and life science trade group PhRMA. At this dinner, Trump suggested that the reform focus would remain on PBMs, and also that while he supports RFK Jr. in researching the supposed (thoroughly debunked) link between vaccines and autism, that drugmakers have nothing to fear from such research.
Notable Eli Lilly CEO David Ricks quote about this dinner: “Probably shouldn’t say too much about it, but it was all you can imagine, and a little bit more, There’s often more common ground than you’d think just reading the newspapers.”
Of course, drugmakers are likely to continue to worry and watch this area like a hawk. Especially because, when it comes to coverage, the details matter so much. For instance, Trump ally Elon Musk recently came out in support of the population-level benefits of widespread use of GLP-1s-"at super low cost". Life sciences executives will be anxious to know what that might mean.
And now back to Union's regularly scheduled program: The full range of levers the GOP could to use to shape healthcare
I'd be remiss not to say, "we all need to keep watching to see how this plays out". And also, if the GOP really wants to alter the healthcare industry in 2025, there are plenty of levers to pull. Far more than would ever fit into the bounds of the HHS kingdom or onto a Make America Healthy Again t-shirt. The full 2025 possibility set includes everything from from PBM reform (lots of bipartisan support there!) to a potential flood of stakeholders challenging federal healthcare agency rules and regulations—newly a realistic possibility, given the fall of the "Chevron Deference" doctrine.
To read our full take on ALL these things, stay tuned for our forthcoming 2025 State of Healthcare report. You will know when it's ready if you're subscribed to receive updates! Scroll down to the bottom of this page to sign up for our mailing list. Members, please get onsite presentations and discussions scheduled for Q1; reach out to your main contact or info@unionhealthcareinsight.com. Non-members, please email that same address (info@unionhealthcareinsight.com) to learn more about getting access to all of our behind-the-paywall content in our ever-expanding research library.
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