The AHA Power Map

Where the Fights Stand (November 2026)

The status of every major law and rule AHA lobbies on, as of November 6, 2026.

Read it this way: Congress still protects AHA on site-neutral pay, the POH ban, and 340B statute. CMS and reconciliation do not.

Total Spend & Trajectory

The American Hospital Association is one of Washington's largest lobbying spenders. The figures below come straight from AHA's own quarterly LD-2 filings with the Senate Office of Public Records. These are the expenses AHA reports for itself as the registrant, which already include the fees it pays its outside lobbying firms.

Roughly $194 million since 2018. That is what AHA has reported spending to lobby the federal government from 2018 through September 2026.

The 2026 pullback. In-house spending for the first three quarters of 2026 is down 24% from the same period in 2025 ($14.39M vs. $18.90M). Q3 2026's $3.84 million is AHA's lowest quarter in any filing since at least 2018. The drop came after AHA lost the Medicaid reconciliation fight and while it was changing CEOs (Rick Pollack out, Steve Walsh in). It also came before the hardest fights of the year were settled: the CY2027 outpatient rule's 340B cut and the year-end appropriations deal.

Outside firms on retainer. On top of its 28 in-house registered lobbyists, AHA pays five outside firms. In 2025 they were the Nickles Group ($360K), Red+Blue Strategies ($320K), Bockorny Group ($440K), the Smith-Free Group ($200K), and Morrison Public Affairs Group ($80K). Two more firms, O'Neill, Athy & Casey ($200K) and Plurus Strategies ($80K), had dropped off by 2026. That came to $1.68M in 2025 and $1.05M in Q1–Q3 2026. The Nickles Group was co-founded by former Sen. Don Nickles, whose chief of staff Stacey Hughes now runs AHA's lobbying shop.

PAC money: For the 2025–2026 cycle (through October 14, 2026), AHAPAC raised $3.49 million and spent $4.22 million. That included $2.30 million in contributions to candidates and other committees and $1.26 million in independent expenditures. The PAC spent $727K more than it took in, and its cash on hand fell from $1.41M to $683K heading into the midterms (FEC). In the 2023–2024 cycle, AHAPAC raised $3.77 million. Its giving stays bipartisan.

Coalition force multiplier: AHA founded the Coalition to Strengthen America's Healthcare, a 501(c)(4) grassroots operation that claims 2.8 million advocates. In 2025 it drove 575,000+ letters to Congress opposing Medicaid cuts. Those letters did not stop the cuts.

Member and ally lobbying adds up: AHA's members and allies file their own reports. Trinity Health reported $1.08M in 2025 (LDA filings matched by client name). Corewell Health reported $830K, Sanford Health $800K, and Houston Methodist $200K. The Federation of American Hospitals, the investor-owned hospital lobby, reported $4.99M. All of this sits on top of AHA's own spending.

What AHA Fights: Status as of November 6, 2026

The old story was that AHA blocks everything. The 2025–2026 record is mixed. Congress still has not touched site-neutral payment, physician-owned hospitals, or 340B in statute. CMS and the reconciliation process handed AHA its worst run of losses in a decade. AHA's wins came mostly in court and in appropriations riders that delayed cuts.

1. Site-Neutral Payment: Losing on Regulation, Holding in Congress

Site-neutral pay is still AHA's top defensive priority. It means equal Medicare rates for the same service, whether the hospital bills it or a physician office does. CBO has put full statutory site-neutral pay at about $170 billion over ten years.

• ►In Congress, AHA is still winning. No site-neutral payment cut has passed. The Lower Costs, More Transparency Act passed the House 320–71 in December 2023, then died in the Senate. A 2026 version (H.R. 9393) is pending. HFMA called site-neutral "the most likely healthcare policy change to pass Congress this year" (August 2026). Whether it rides on the year-end spending package is the live question for the lame duck.
• ►The one enacted provision is the off-campus department NPI and attestation requirement in the Consolidated Appropriations Act, 2026. Billing under one hospital number has hidden which off-campus clinics get which rates. Starting January 1, 2028, each one needs its own number or loses outpatient payment. The data it produces is the groundwork for the next site-neutral fight.
• ►At CMS, AHA is losing. The CY2026 OPPS final rule (November 21, 2025) moved drug administration at off-campus departments to physician-office rates, a $290M cut in year one. TechTarget reported that CMS projects about $11B in savings over the decade from its off-campus and related policies. The CY2027 final rule (November 4, 2026) adds imaging without contrast from January 1, 2027. On August 19, 2026, AHA sent out an action alert against the site-neutral and NPI provisions. CMS finalized both provisions in the CY2027 final rule on November 4, 2026.

AHA's line hasn't changed: "There is nothing 'neutral' about site-neutral policies." What it protects hasn't changed either: the facility-fee markup that makes buying physician practices pay.

2. Price Transparency: Sued, Lost, Now Facing Tighter Rules

AHA sued twice to block the original federal price transparency rules (2019–2020) and lost both times. The rules took effect January 1, 2021. The 2025–2026 cycle raised the bar further:

• ►Executive Order 14221 (February 25, 2025) ordered actual prices, not estimates, and real enforcement.
• ►The CY2026 OPPS final rule carried it out. Hospitals must now post 10th-percentile, median, and 90th-percentile allowed amounts drawn from remittance data, along with their NPIs, and a senior official must attest to the file. Enforcement began April 1, 2026. CMS also offers a 35% discount on penalties to hospitals that admit violations and waive a hearing.
• ►Federal legislation is pending, not enacted. AHA's Q3 2026 filing shows it lobbying on every major bill: the Patients Deserve Price Tags Act, the Health Care Price Certainty for All Americans Act, the Prices on the Wall Act of 2026, and the LCMT Act of 2026.

What it looks like on the ground: CMS found only 27% of hospitals fully compliant in 2021. As of April 2025, Houston Methodist, whose CEO chairs AHA's board in 2026, posted 350 line items against a comparable competitor's 5,313. The maximum penalty is still only $5,500 a day for the largest hospitals.

3. The 340B Program: AHA Won the Courtroom, Lost the Rate Fight

AHA treats the 340B program as untouchable. The program has outgrown any "safety net" story. According to HRSA's own August 2026 notice, it reached $100 billion in purchases at 340B prices in 2025, across 15,249 covered entities and 49,214 associated sites. That is up from $53.7B in 2022.

• ►The rebate pilot. AHA and other hospital groups sued in the District of Maine on December 1, 2025. They won a preliminary injunction on December 29, 2025. The First Circuit denied HHS a stay. HHS dropped its appeal (granted January 20, 2026), said on February 5, 2026 that it would scrap the pilot, and the court formally vacated it on February 10, 2026. HRSA started over: an RFI in February 2026, then a revised pilot notice on August 3, 2026, targeting January 1, 2027. AHA sued again in the District of Maine on October 9, 2026, and on October 21 it opposed the drug industry's bid to intervene. Status: pending, in litigation.
• ►Manufacturer rebates. On July 21, 2026, the D.C. Circuit held in Novartis v. Kennedy that drugmakers cannot impose rebates without HHS approval. The ruling cuts both ways: it blocks unilateral rebates but confirms HHS's power to approve them.
• ►The rate cut. CMS's CY2027 final rule (November 4, 2026) pays 340B-acquired drugs at ASP minus 28% from January 1, 2027, based on CMS's own hospital survey of acquisition costs. CMS had proposed minus 33.4%. The cut is $4.35B in Medicare drug payments in year one, redistributed to all hospitals through higher non-drug rates. CMS also raised the annual remedy clawback from 0.5% to 2% (it had proposed 3%). AHA won AHA v. Becerra at the Supreme Court in 2022 because CMS cut rates without survey data. This time CMS ran the survey first. Status: proposed; final rule pending.
• ►Legislation. AHA is lobbying against or trying to shape the 340B PATIENTS Act, the 340B Access Act, the SECURE 340B Act, the SUSTAIN Act, and a Senate discussion draft. Ways & Means approved a 340B reporting bill for nonprofit hospitals on July 1, 2026. None has been enacted.

The program still has the same accountability gap. Houston Methodist made $50M in profit from 340B in a single year by acquiring outpatient sites. A study co-authored by Intermountain's own Delivery Institute found 340B participation had limited impact on charity care.

4. Physician-Owned Hospitals: Ban Intact

The ACA's ban on new or expanded physician-owned hospitals is unchanged as of November 2026. AHA's Q3 2026 filing lists the Physician Led and Rural Access to Quality Care Act (H.R. 2191), which would loosen the ban, as an active issue. That bill is pending. At a March 2026 House Energy & Commerce hearing, AHA was the lone voice among six panelists for keeping the ban. AHA's case is still that physician-owned hospitals "cherry-pick" patients. Its Chief Physician Executive supplies the "physician imprimatur." This is the purest piece of incumbent protection in AHA's portfolio, and Congress has left it alone for 16 years.

5. Antitrust: Enforcement Shifts to Contracts and Outpatient Deals

• ►DOJ and Ohio v. OhioHealth (complaint February 20, 2026). The suit alleged that a 16-hospital nonprofit system used contract terms to stop insurers from offering lower-cost tiered and steered plans in Columbus, in violation of Sherman Act §1. A proposed final judgment filed June 16, 2026 voids those terms. AHA's Q3 2026 filing lists "hospital mergers and acquisitions" as a lobbying issue.
• ►FTC and Ascension/AmSurg. The FTC required divestiture of seven surgery centers in five metros as the price of Ascension's ~$3.9B purchase of AmSurg (consent order published June 10, 2026). Six went to an affiliate of UnitedHealth Group and one to a physician group.
• ►The history: the FTC blocked Sanford-Mid Dakota (75–85% market share) and Advocate-NorthShore (2017), and a state AG investigation killed Sanford-Fairview. Sanford's CEO, Bill Gassen, chairs AHA's board in 2027.

6. Medicaid: The Biggest Loss in a Decade, Plus a $50B Consolation Prize

AHA reported $7.03M in Q1 2025, its biggest quarter of that year, and ran its grassroots machine at full volume. The One Big Beautiful Bill Act (signed July 4, 2025) passed anyway:

• ►Provider taxes (Sec. 71115): frozen at July 4, 2025 levels. The new hold-harmless threshold took effect October 1, 2026. Starting in FY2028, the expansion-state safe harbor drops from 6% toward 3.5% by FY2032. CMS finalized a rule closing the managed-care-tax loophole (effective April 3, 2026) and proposed the threshold rule on July 23, 2026.
• ►State-directed payments (Sec. 71116): capped at 100% of Medicare in expansion states and 110% in non-expansion states. Grandfathered payments shrink 10 percentage points a year starting with rating periods on or after January 1, 2028. CMS proposed its implementing rule May 22, 2026.
• ►Work requirements: the interim final rule took effect June 1, 2026, and states must implement by January 1, 2027. CMS projects 2.3 million fewer enrollees in FY2027. Twenty-three states and D.C. sued on June 29, 2026.
• ►The consolation prize: the $50 billion Rural Health Transformation Program, $10B a year from FY2026 to FY2030 for the 50 states. Half is split equally and half is allocated by CMS. AHA now lobbies on "how it is distributed to hospitals." Medicaid financing took a structural cut, and in exchange the industry got a new federal grant stream to fight over.

7. Everything Else Enacted or Finalized in 2026

• ►Consolidated Appropriations Act, 2026 (P.L. 119-75, signed February 3, 2026): shrank the Medicaid DSH cut from $24B to $8B and delayed it to FY2029, a clear AHA win. It also extended telehealth through December 31, 2027, extended the low-volume and Medicare-dependent hospital payments through December 31, 2026, enacted the off-campus department NPI and attestation rule, and added PBM reforms.
• ►Enhanced ACA premium tax credits: expired December 31, 2025, and were not revived. AHA was still lobbying for an extension in Q3 2026. Coverage losses mean more uncompensated care at the same hospitals that got the subsidy money.
• ►FY2027 IPPS final rule (published August 4, 2026; effective October 1, 2026).
• ►Continuing Appropriations and Extensions Act, 2027 (P.L. 119-103, September 2, 2026): funds the government through December 11, 2026, with no Medicare hospital extenders. The low-volume and Medicare-dependent hospital programs expire December 31 unless the lame duck acts. That makes the year-end package the next big lobbying moment.

The Bottom Line

AHA has reported about $194 million in federal lobbying since 2018, and it still holds the line in Congress. Site-neutral pay, the physician-owned hospital ban, and 340B are all untouched in statute. AHA also wins in court, as its 2025 rebate-pilot injunction showed, and it went back to court on October 9 against the revised pilot. But that defense has stopped working at CMS and in reconciliation. In 18 months AHA lost a structural Medicaid financing cut, the expiration of the enhanced subsidies, a regulatory site-neutral rule, and much tighter transparency enforcement. It now faces a proposed 340B rate cut of nearly 40%. Its in-house lobbying spend fell 24% in 2026 while its PAC spent more than it raised. A new CEO from the Massachusetts state-association world now inherits the year-end package, the CY2027 outpatient rule, and a 340B rebate pilot due to start January 1.

Sources: Senate LDA filings (lda.gov API, AHA registrant and client filings 2018–Q3 2026); FEC committee C00106146; CMS fact sheet, CY 2027 OPPS/ASC final rule (CMS-1850-F), Nov. 4, 2026 (https://www.cms.gov/newsroom/fact-sheets/calendar-year-2027-hospital-outpatient-prospective-payment-system-opps-ambulatory-surgical-center-0); Federal Register; govinfo.gov public laws; HFMA; Holland & Knight; King & Spalding; ArentFox Schiff; TechTarget; Bass Berry & Sims; JD Supra; Healthcare Dive; prior research files (aha_intel_*.md). Full URL list in powermap.lobbyingPacRevolvingDoor.changes.md.

The Organization

AHA is a 501(c)(3)/501(c)(6) hybrid. Its 2023 filings, the latest detailed figures in our files, show ~431 employees, $145 million in revenue, and $300 million in net fund assets. AHA spent $169 million against $147 million in revenue in 2023, a $22 million deficit covered from $435 million in reserves. It is spending down its savings to keep the lobbying and executive pay machine running.

The PAC is now spending down too. For the 2025–2026 cycle (January 1, 2025 to October 14, 2026), AHAPAC reported to the FEC:

AHAPAC spent $727,000 more than it raised and cut its cash in half heading into the 2026 midterms. In the 2023–2024 cycle, it raised $3.77 million. The money keeps flowing to both parties.

Pay at the top (2023 Form 990 data): total compensation was $78 million across 431 staff, an average of about $181,000. The top 16 executives took $17 million, nearly 22% of the pool. The top 10 executives collectively received $62 million from 2017 to 2023.

Executive perks (SVP and above): first-class air travel (CEO, two EVPs, three board members), companion travel for the CEO, discretionary spending accounts, and a supplemental non-qualified deferred compensation plan analysts call "extremely generous for a trade organization."

Health Forum LLC: AHA's for-profit subsidiary sells data products, market intelligence, and sponsorships, with estimated revenue of $10–50 million. The EVP/COO also serves as Health Forum's CEO, so one executive runs both the nonprofit mission and the commercial revenue engine.

The C-Suite (November 2026)

Steve Walsh: President & CEO (fall 2026 to present)

The new face of the hospital lobby. The AHA board unanimously named Walsh on June 30, 2026, after a national search. He took over in early fall 2026; AHA has not announced an exact start date. Before AHA he was President & CEO of the Massachusetts Health & Hospital Association (since 2017). Before that he served six terms as a Massachusetts state representative, where he chaired the House Committee on Health Care Financing.

Revolving door, state edition: Walsh wrote health care financing law as a legislator, then lobbied that legislature for the hospitals it funds, and now runs the national association. Massachusetts has the highest per-capita health spending in the country and is home to some of the most consolidated hospital markets anywhere, Mass General Brigham above all. That is the model he brings to Washington. Board Chair Marc Boom called him "a proven healthcare leader, innovator and accomplished advocate for healthcare improvement."

What he inherits: a Medicaid financing structure that the One Big Beautiful Bill Act starts cutting in FY2028; a proposed 340B rate cut of nearly 40% in the CY2027 outpatient rule; a revised 340B rebate pilot due January 1, 2027 (AHA sued to block it on October 9); site-neutral as a possible pay-for in the year-end spending bill; in-house lobbying down 24% year over year; and a PAC that spent more than it raised. His AHA compensation has not been disclosed; the first Form 990 covering him will not be public until 2028.

Rick Pollack: Former President & CEO (CEO 2015–2026; at AHA 1982–2026)

Former. Pollack announced his retirement in December 2025 and left when Walsh took over in fall 2026. He spent 43 years at AHA. Career arc: Capitol Hill staffer, then nurse-association lobbyist, then AHA lobbyist, then AHA EVP for Advocacy & Public Policy (1991–2015), then CEO (2015–2026). He was a registered federal lobbyist for most of that time. Pollack is not listed among AHA's registered lobbyists on any 2025 or 2026 LD-2.

Compensation trajectory:

That is about $23 million from 2017 to 2023. His final-year pay and any departure or deferred-compensation payout will show up on AHA's 2026 Form 990. Pollack called grassroots lobbying "absolutely king." His last cycle was a test of that idea: 575,000 coalition letters did not stop the Medicaid cuts in the One Big Beautiful Bill Act.

Stacey Hughes: EVP, Government Relations & Public Policy (2021 to present)

The top lobbyist. Still listed as a registered AHA lobbyist on the Q3 2026 LD-2 (filed October 20, 2026). She supervises all legislative, political, regulatory, grassroots, and legal advocacy. She replaced Tom Nickels, who had held the role since 1994.

Revolving door career: 18 years as Senate staff, including Sen. Connie Mack III (R-FL), Sen. Don Nickles (R-OK), where she rose to Chief of Staff, and the Senate Republican Policy Committee. She then co-founded a lobbying firm with Nickles, lobbied for AHA from the outside, and was hired as AHA's top in-house lobbyist. The Nickles Group is still on AHA's payroll: $90,000 a quarter, $360,000 in 2025, in every quarterly filing through Q3 2026.

Her description of the team: "They have all worked largely on Capitol Hill or they were deeply, deeply immersed in the issues."

Michelle Hood: EVP & COO / President & CEO, Health Forum LLC (2020 to present)

The operational backbone. Over 40 years in health care: Emory University Hospital, Norton Healthcare, St. Vincent Healthcare, Sisters of Charity of Leavenworth Health System, Northern Light Health (CEO, $1.8B system, ~14 years), then AHA. She runs AHA operations and its for-profit subsidiary at the same time, which ties the nonprofit mission and the commercial franchise together under one person.

Chad Golder: SVP & General Counsel (2024 to present; at AHA since ~2018)

The litigation strategist. About eight years at DOJ on healthcare regulatory enforcement, then a partner at Munger, Tolles & Olson, then AHA Deputy GC, now GC. "People talk about the revolving door like it's necessarily a bad thing."

His 2025–2026 scorecard: AHA's biggest win of the cycle came from his shop. AHA v. Kennedy (D. Me.) won a preliminary injunction against HHS's 340B Rebate Model Pilot on December 29, 2025. The First Circuit denied a stay. HHS dropped its appeal (January 20, 2026) and said on February 5 that it would scrap the pilot, which the court vacated on February 10, 2026. HRSA reissued a revised pilot on August 3, 2026, and AHA filed a second suit against it on October 9, 2026. Golder previously won AHA v. Becerra (2022, unanimous) and lost both price transparency suits.

Lisa Kidder Hrobsky: SVP, Federal Relations, Advocacy & Political Affairs (2021 to present)

The registered lobbyist. Still on the Q3 2026 LD-2. She directs legislative advocacy, grassroots mobilization, and AHAPAC political engagement. She has had a 17+ year AHA career across two stints. Path: Senate Special Committee on Aging staff, then America's Health Insurance Plans, then AHA, then Idaho Hospital Association (President & CEO), then back to AHA. She has been registered under the Lobbying Disclosure Act since at least 2002. She runs AHA's "grasstops" strategy: hospital CEOs and trustees calling their own delegations, using their weight as major local employers.

Chris DeRienzo, M.D., MPP: SVP & Chief Physician Executive (2022 to present)

The physician shield. A neonatologist who is also President of AHA's research arm, the Health Research & Educational Trust (HRET). He supplies the "physician imprimatur" for AHA's opposition to physician-owned hospitals and site-neutral pay. He has never owned or run an independent practice; his career has been inside hospital systems (WakeMed, Mission Health). As HRET President he oversees the research AHA cites in its lobbying, which closes the loop.

Staff status check: Hughes and Hrobsky are confirmed in role by AHA's Q3 2026 lobbying filing. Hood, Golder, and DeRienzo are listed as current in the November 2026 dossier refresh. We found no announced departures under Walsh.

The Board: Governance as Influence Architecture

AHA's Board of Trustees is made up mostly of CEOs, system presidents, and board chairs of member institutions. Members have direct financial stakes in the policies AHA lobbies for, and there is no published recusal requirement.

2027 Officers

Bill Gassen (2027 Chair). He also chairs AHA's 501(c)(4) lobbying arm, has sat on a federal CMS/HHS advisory committee, and holds an insurer board seat at Oscar Health. Under Gassen, Sanford tried four mergers in six years: the FTC blocked one (75–85% market share), a state AG investigation killed another, and two collapsed. Sanford's own federal lobbying ran $800K in 2025 (LDA). Starting in January, the hospital lobby is chaired by a man advising the government on hospital payment while sitting on an insurer's board.

Marc Boom (2026 Chair, 2027 Immediate Past Chair). He also sits on the board of the Houston Branch of the Federal Reserve Bank of Dallas. Houston Methodist charges facility fees at hospital-based outpatient clinics, which is exactly what site-neutral reform targets. It was out of compliance with price transparency for 18+ months, made $50M in one year from 340B through outpatient acquisitions, and posted 350 pricing line items against a competitor's 5,313. Boom chaired the search that picked Walsh.

Laura Kaiser (2027 Chair-elect). Named Chair-elect Designate on July 12, 2026. She will chair AHA in 2028.

Turnover

• ►Joining January 1, 2027 (three-year terms): Charles Gressle (President, East Florida Division, HCA Healthcare), William Jennings (President, Fairfield Region, Hartford HealthCare), J. Stephen Jones, M.D. (President & CEO, Inova Health), Vicki Lewis (President & CEO, Coffee Regional Medical Center, Douglas, GA), and Michele Baker Richardson (President & CEO, HEA Consultants).
• ►Leaving December 31, 2026: Tina Freese Decker (Corewell Health; 2025 Chair), Kurt Barwis (Bristol Health), and Robert Trestman, M.D. (Carilion Clinic).

Notable: HCA's East Florida division president now gets a seat. That puts the largest investor-owned chain, which also funds the Federation of American Hospitals ($4.99M in federal lobbying in 2025), directly inside AHA's governance as well.

Board Composition Patterns

• ►Large-system CEOs dominate the agenda, the revenue, and the institutional weight.
• ►Small and rural hospital CEOs add geographic and size diversity, and may function as easily managed votes for the large-system agenda. Vicki Lewis (Coffee Regional) joins that bloc in 2027.
• ►Strategic appointments shield exposed institutions. NYU Langone placed its CNO, not its CEO, who was paid $22.8M.
• ►Distressed institutions have held seats. Bristol Health's Barwis joined months after a going-concern audit and was a registered Connecticut lobbyist at the same time. His term ends December 31, 2026.
• ►The Vizient-to-AHA pipeline keeps the board stocked with executives tied to the GPO-hospital complex.
• ►Dual state-federal roles multiply influence (Vissers/Colorado, Hirsch/NJHA HealthPAC, Glasgo/Iowa). The new CEO is the ultimate example: Walsh comes directly from running a state hospital association.

The Conflict of Interest Structure

Trustee Melinda Hancock (Chief Administrative and Financial Officer, Sentara Health) "literally models the P&L impact of these policies at Sentara and then sits on the board that lobbies to shape them." In 2026 those policies include state-directed payment caps, the provider-tax freeze, and the 340B rate cut. No public conflict-of-interest recusal mechanism exists.

The Revolving Door Map

AHA hired two Senate aides, one Republican and one Democrat, and registered them as lobbyists within days of their leaving the Hill in January 2026. Its outside firms run the same play. In 2026 the Nickles Group added a former House Oversight Committee deputy general counsel, and Red+Blue Strategies added a former Senate Veterans' Affairs Committee counsel to the AHA account. Each hire brings knowledge of how Congress and federal agencies work, personal relationships with sitting members and staff, and the ability to work regulatory processes from the inside. The revolving door is not a side effect. It is the staffing model.

Sources: Senate LDA filings (lda.gov); FEC committee C00106146; Healthcare Dive (July 1, 2026); LegiStorm; Federal Register (340B Rebate Model Pilot notice, Aug. 3, 2026); prior research files aha_intel_pollack.md, aha_intel_hughes.md, aha_intel_hood.md, aha_intel_golder.md, aha_intel_hrobsky.md, aha_intel_derienzo.md, aha_intel_boom.md, aha_intel_gassen.md, aha_intel_freesedecker.md, aha_intel_hancock.md, aha_intel_albert.md, aha_intel_barwis.md, aha_intel_fish.md, aha_intel_glasgo.md, aha_intel_vissers.md, aha_intel_hirsch.md, aha_intel_trestman.md. Full URL list in powermap.lobbyingPacRevolvingDoor.changes.md.

AHA's influence operation runs on a steady pipeline between Capitol Hill, state legislatures, federal agencies, and K Street. Under its new CEO, the pipeline now starts in a state house.

The 2026 hires. AHA hired two Senate aides in January 2026, one from a Republican office (Fischer) and one from a Democratic office (Welch), and registered both as AHA lobbyists in its first-quarter filing. Sacasa left Fischer's office on January 5 and Waheeddeen left Welch's on January 16. The bipartisan pairing is deliberate.

The outside bench. AHA keeps five outside firms on retainer: the Nickles Group, Red+Blue Strategies, Bockorny Group, the Smith-Free Group, and Morrison Public Affairs Group. Together they cost $1.05M in Q1–Q3 2026. The Nickles Group, co-founded by the former senator Hughes once served as chief of staff, has billed AHA $90,000 every quarter. In 2026 it added a former House Oversight Committee deputy general counsel to the AHA account. Red+Blue added a former Senate Veterans' Affairs Committee counsel.

The new CEO's door swings at the state level. Walsh wrote Massachusetts health care financing law as a legislator, then spent nine years lobbying that same legislature as head of the state hospital association, and now runs the national one. That is the template AHA chose to replace a 43-year Washington lifer.

Hughes describes the team: "They have all worked largely on Capitol Hill." The revolving door is not a side effect. It is the staffing model. Each hire brings knowledge of how Congress and federal agencies work, personal relationships with sitting members and staff, and the ability to work regulatory processes from the inside.

Staff status: Hughes and Hrobsky are confirmed by the Q3 2026 LD-2. Hood, Golder, and DeRienzo are current per the November 2026 dossier refresh. We found no announced departures under Walsh.

Sources: Senate LDA filings, AHA Q1–Q3 2026 LD-2 lobbyist covered-position disclosures (lda.gov); Healthcare Dive (July 1, 2026); LegiStorm (Sept. 15, 2022); prior research files aha_intel_pollack.md, aha_intel_hughes.md, aha_intel_hood.md, aha_intel_golder.md, aha_intel_hrobsky.md, aha_intel_derienzo.md.

AHA's lobbying operation does not merely protect existing revenue. It underwrites a consolidation strategy that concentrates market power in the systems whose executives sit on its board. The pattern is consistent: acquire competitors, absorb physician practices, use Certificate of Need laws to block new entrants, collect facility fees from converted sites, and run AHA's $25 million-a-year lobbying operation against every form of oversight. In 2027 the board gets a new chair, a new CEO and some new members. It keeps the same playbook.

The 2027 Board: Who Now Holds the Wheel

• ►Chair: Bill Gassen (Sanford Health), a serial acquirer. Chair-elect: Laura Kaiser (SSM Health). Immediate past chair: Marc Boom (Houston Methodist).
• ►President & CEO: Steve Walsh, named June 30, 2026. He ran the Massachusetts Health & Hospital Association and is a former Massachusetts state representative. He succeeds Rick Pollack.
• ►New trustees from Jan. 1, 2027: Charles Gressle (HCA Healthcare, East Florida Division), William Jennings (Hartford HealthCare), J. Stephen Jones, MD (Inova Health), Vicki Lewis (Coffee Regional Medical Center) and Michele Baker Richardson (HEA Consultants).
• ►Leaving Dec. 31, 2026: Tina Freese Decker (Corewell), Kurt Barwis (Bristol Health) and Robert Trestman (Carilion Clinic).

The new class does not dilute the incumbent tilt. It sharpens it:

• ►HCA's seat. HCA is the largest hospital operator in the country. Its CEO was the for-profit witness at the April 28, 2026 Ways and Means hearing, where Rep. Adrian Smith asked why HCA charges commercial insurers more than three times the Medicare rate.
• ►Hartford HealthCare's seat. Hartford is the other half of Connecticut's hospital duopoly, alongside Yale New Haven.

The Merger Scoreboard

Sanford Health (Bill Gassen, 2027 AHA Chair)

The most persistent acquirer on the board. Six deals are on the record:

The FTC found the Mid Dakota deal would create "a near monopoly provider of physician services in the Bismarck-Mandan area," likely leading to "higher reimbursement rates and higher premiums for consumers." After Fairview collapsed, Gassen cited a lack of "support from certain Minnesota stakeholders" and did not address the AG's antitrust concerns. On Jan. 1, 2027 he becomes chair of the organization that sets national hospital policy on competition.

Yale New Haven Health (Pamela Sutton-Wallace, trustee; Acting CEO since June 29, 2026)

Connecticut's dominant system ran a deliberate consolidation strategy until the money ran out.

• ►Lawrence + Memorial: YNHHS absorbed L+M (New London) in 2016, then added Westerly Hospital in Rhode Island.
• ►Prospect Medical: the deal unwound. In September 2025, YNHHS agreed to pay Prospect $45 million to walk away from its $435 million purchase of Waterbury, Manchester Memorial and Rockville General. The bankruptcy court approved the exit in October 2025.
• ►Losses:
  • ►FY2025: a $197 million operating loss (-2.6%) on $7.6 billion in revenue.
  • ►FY2024: a $46.2 million surplus, driven largely by a one-time ~$100 million 340B program remedy settlement.
  • ►S&P moved its outlook to negative. The CFO and general counsel left in October 2025. About 150 Northeast Medical Group layoffs came in March 2025 and about 600 voluntary retirements followed.
• ►Facility fees: health system fees at Connecticut hospitals more than doubled, from about $748 million (FY2017) to $1.6 billion+ (FY2024). The driver is practice acquisitions and the reclassification of physician offices as hospital outpatient departments.

The lesson: scale bought pricing power, not operating discipline. And Hartford HealthCare, the duopoly partner, now gets its own AHA board seat.

Endeavor Health (J.P. Gallagher, trustee)

Gallagher's system has one antitrust run-in after another:

• ►Evanston–Highland Park (2000): in 2007 the FTC ruled the merger anticompetitive. It led to a $55 million class-action settlement for overcharging consumers.
• ►NorthShore–Advocate (2017): blocked. It would have created >50% inpatient share in Chicago's northern suburbs.
• ►NorthShore–Edward-Elmhurst (2022): approved, creating Illinois' third-largest system.

Gallagher led the last two attempts. Evanston Hospital now carries the sixth-largest fair share deficit in the country (-$152 million a year, Lown 2025).

Montefiore Einstein (Philip Ozuah, trustee)

• ►Montefiore grew from 4 hospitals in 2010 to 11 by 2019, plus 250 ambulatory sites, a nursing home and a home care agency. It holds a near-monopoly position in the Bronx.
• ►Nurses call the result a "two-tier health system": capital flowed to Westchester while Bronx emergency departments overflowed.
• ►The bill came due in 2026:
  • ►Strike: a 15,000-nurse NYSNA strike across three systems ran Jan. 12 to Feb. 9, 2026.
  • ►Losses: a $120.9 million operating loss in 2025, then -4.5% in Q1 2026.
  • ►Credit: KBRA cut its outlook.
• ►Ozuah's FY2024 pay was $16.69 million.

Corewell Health (Tina Freese Decker, leaves the board Dec. 31, 2026)

• ►Spectrum + Beaumont (2022) created Michigan's largest system: 21 hospitals and ~$11.5 billion in revenue.
• ►The FTC issued a rare second request for a cross-market deal, then let it close with no conditions. Beaumont's ~$4 billion in reserves came over unrestricted.
• ►Former Beaumont CEO John Fox left with a $10.2 million package.

Freese Decker chaired AHA in 2025 and served as past chair in 2026. Her exit ends Corewell's officer-level run, but Michigan keeps two seats: Trinity's Slubowski and MHA's Brian Peters.

Trinity Health (Michael Slubowski, trustee)

• ►MercyOne: absorbed 16 medical centers and 400+ sites of care in Iowa, adding about $3 billion in revenue.
• ►Reproductive care: when Trinity buys a community's only hospital, the Ethical and Religious Directives eliminate sterilization and contraception services that patients cannot get elsewhere locally.

Intermountain Health (Rob Allen, trustee)

• ►The SCL Health merger (2022) built a 33-hospital system across Utah, Colorado, Montana and Kansas.
• ►Intermountain owns SelectHealth (~1 million members). It is insurer and provider at once, which gives it "significant leverage in contract negotiations with employers and other payers."
• ►Intermountain publicly opposed the 2021 executive order on hospital consolidation, in line with AHA.

Antitrust Enforcement Reaches the Big Systems

Federal enforcers moved against dominant-system contracting in 2026. Neither target sits on the AHA board, but both run on the model the board defends:

• ►February 2026: DOJ and the Ohio attorney general sued OhioHealth over contract terms that blocked insurers from offering tiered and steered plans; a proposed final judgment filed June 16, 2026 voids those terms.

In the House, the Healthy Competition for Better Care Act would ban anti-steering, anti-tiering and all-or-nothing clauses. CBO reportedly scores it at nearly $5 billion in savings.

At the same hearing, Chairman Jason Smith cited about 2,000 hospital mergers and said about 90% of beds now sit inside systems. His verdict on hospital prices: "borderline extortion."

AHA's long-standing line is to criticize "the approach and framework the Federal Trade Commission has employed to review hospital transactions."

Certificate of Need: Incumbent Protection

Certificate of Need (CON) laws require state permission before anyone can build or expand a healthcare facility. Board members' systems use CON as a moat and defend it through the state hospital associations that feed AHA's regional policy boards.

Connecticut (Yale New Haven and, from 2027, Hartford HealthCare)

• ►Proton therapy: a proposed Danbury proton center was denied under CON. Meanwhile YNHHS and Hartford HealthCare won approval for their own joint facility in Wallingford, "effectively blocking a competitor while securing the same service for themselves."
• ►Reform stalled: CON reform "dissolved in the final weeks of the 2024 CT legislative session."
• ►Who wins: State Sen. Ryan Fazio: "The Yale New Havens of the world are going to have the administrative, the legal, the lobbying capacity to manage that."
• ►Both beneficiaries on the board: with Jennings joining, both systems that co-own the proton franchise will sit on the AHA board in 2027.

Virginia (Carilion Clinic; Trestman leaves the board Dec. 31, 2026)

• ►Virginia's Certificate of Public Need (COPN) program protects Carilion's position in Roanoke.
• ►FTC, 2008–09: after Carilion bought two low-cost independent outpatient centers, the FTC forced it to divest them.
• ►DOJ, 1989: an antitrust suit against Carilion failed.
• ►The result: a regional monopoly with documented monopolistic pricing and 33,000 court judgments against patients.

Trestman's exit removes Carilion from the board. The new class adds Northern Virginia's Inova, which operates under the same COPN regime.

Louisiana (Joan Coffman, trustee and RPB 7 Chair)

• ►Louisiana adopted CON in 1991, after the federal mandate was repealed and other states were abandoning theirs.
• ►The Louisiana Hospital Association has historically opposed CON reform. Coffman sits on both the LHA board and the AHA board.

CON changes in the 2025–2026 state sessions could not be verified for this update. See the changes file.

The GPO-to-AHA Pipeline

Vizient, the largest hospital group purchasing organization, works as a feeder for AHA governance:

• ►Joan Coffman: Vizient Southern States Board Chair, then AHA trustee.
• ►Rob Vissers (Boulder Community Health): Vizient board chair, then AHA trustee.
• ►Michelle Hood: AHA EVP/COO and a Vizient New England board member.

GPOs collect administrative fees (typically 1–3% of contract value) from vendors. Member-specific rebate arrangements are "generally not publicly transparent." Coffman's stack shows how the roles reinforce each other: AHA Board, RPB 7 Chair, Vizient Southern States Past Chair, LHA Board and Ochsner Health Network Board. Since January 2026, Ochsner CEO Pete November has also sat on the AHA board.

Vertical Integration: The Full-Stack Hospital

The acquisition-to-facility-fee pipeline:

1. ►Buy an independent practice.
2. ►Reclassify it as a hospital outpatient department.
3. ►Collect a facility fee on top of the professional fee.

Smith's examples from April 28: an ultrasound costs $164 in a physician office and $339 in a hospital outpatient department. A biopsy costs about $150 versus $800.

The House Energy & Commerce memo for the March 18, 2026 hearing, at which Pollack testified, cited GAO data: at least 47% of physicians were employed by or affiliated with hospital systems in 2024, up from under 30% in 2012. That is why AHA fights site-neutral payment. Site-neutral pay would remove the arbitrage that pays for the acquisitions.

The Pricing Power Payoff

• ►Houston Methodist: charges more than 2x peer institutions for comparable services. The Baker Institute found it omitted major insurer prices from its transparency file.
• ►Endeavor (NorthShore): the FTC-condemned Evanston merger produced a $55 million overcharge settlement.
• ►Yale New Haven: Connecticut system fees doubled to $1.6 billion+ as YNHHS consolidated.
• ►Sanford: the FTC said the blocked Mid Dakota deal would mean "higher reimbursement rates and higher premiums."
• ►Carilion: a 2008 Wall Street Journal investigation documented monopoly pricing in Roanoke.

The E&C memo cites research tying horizontal hospital consolidation to higher prices "without a discernible change in quality."

How It All Connects

1. ►Acquire: hospitals, physician practices, ambulatory and outpatient sites.
2. ►Reclassify: convert independent sites to hospital outpatient departments.
3. ►Extract: facility fees, 340B program margins, negotiated-rate leverage.
4. ►Protect: CON to block entrants, AHA to fight site-neutral pay and antitrust.
5. ►Govern: seat system CEOs on the AHA board to set the agenda.
6. ►Repeat: use reserves and market position to fund the next deal.

The 2027 transition proves the point. The chair passes from Houston Methodist to Sanford, the board's most aggressive acquirer, and the new class adds HCA and Hartford HealthCare. Every policy AHA opposes threatens a different spoke of this wheel: site-neutral payment, price transparency, all-or-nothing contracting bans, CON repeal and 340B accountability. The conflicts are not incidental. They are the design.

Sources: https://www.aha.org/press-releases/2026-07-31-aha-names-new-trustees-board ; https://www.chiefhealthcareexecutive.com/view/hospital-ceos-pressed-on-prices-by-congress ; https://waysandmeans.house.gov/?p=20051 ; https://legis1.com/news/hospital-pricing-extortion-ceos-face-fire-over ; https://www.realclearhealth.com/2026/04/27/the_monopoly_tax_on_your_health_insurance_1179221.html ; https://d1dth6e84htgma.cloudfront.net/03_18_2026_HE_Hearing_Memorandum_0a8170f092.pdf ; https://www.fiercehealthcare.com/providers/prospect-medical-holdings-asks-bankruptcy-judge-preserve-yale-new-haven-healths-435m ; https://www.beckershospitalreview.com/finance/connecticut-health-system-without-cfo-posts-197m-operating-loss ; https://hartfordbusiness.com/article/yale-new-haven-health-ceo-oconnor-details-tough-year-restructuring-and-plans-for-recovery/ ; https://www.ynhhs.org/news/yale-new-haven-health-system-announces-leadership-changes ; https://www.beckershospitalreview.com/finance/montefiore-posts-1-4-operating-margin-in-2025/ ; https://projects.propublica.org/nonprofits/organizations/131740114 ; https://www.healthbeat.org/newyork/2026/02/09/nurses-strike-agreement-hospitals ; https://www.beckershospitalreview.com/finance/hospital-community-investment-vs-tax-breaks-9-things-to-know ; https://www.aha.org/node/707122 ; prior research files aha_intel_gassen.md, aha_intel_suttonwallace.md, aha_intel_gallagher.md, aha_intel_ozuah.md, aha_intel_freesedecker.md, aha_intel_slubowski.md, aha_intel_allen.md, aha_intel_boom.md, aha_intel_trestman.md, aha_intel_coffman.md, aha_intel_vissers.md, aha_intel_hood.md

AHA's public story is that nonprofit hospitals are "cornerstones of their communities," returning far more in community benefit than they receive in tax breaks. In January 2026 it repeated the claim in round numbers: $149 billion in community benefit against $13.2 billion in federal tax exemptions in 2022, about $11 for every $1. Independent estimates tell a different story, and so does the record of AHA board members' own institutions. In 2026, so did the chairman of the House tax-writing committee.

Two Ledgers

The gap is definitional. AHA's number counts Medicaid shortfalls, unreimbursed Medicare, research and education. The Congressional Research Service found unreimbursed Medicare alone was about 45% of reported community benefit spending in 2021. It also found that 80% of hospitals spent less on community benefit than their tax breaks were worth.

On April 28, 2026, Ways and Means Chairman Jason Smith used the narrow numbers: about $28 billion in tax breaks against about $16 billion in charity care. He said the difference goes to real estate and stadium naming rights. Before the hearing, he called nonprofit systems "hedge funds with hospital beds."

The Fair Share Scoreboard (Lown Institute, 2025 report, 2020–2022 data)

The Lown Institute's latest fair share report was published in April 2025. It is the most recent edition; Lown has not released one in 2026. The 2025 edition found:

• ►Tax breaks: $26 billion a year.
• ►Community investment: $22.4 billion a year.
• ►Deficit: $11.5 billion a year across the 54% of hospitals that fell short.
• ►Large deficits: 12 hospitals each had a deficit above $100 million.

AHA board members' institutions appear on both sides of the ledger:

Lown's 2025 data shows Houston Methodist's main hospital in surplus. Houston Methodist's weak marks come elsewhere: a D grade for equity on the Lown Hospitals Index, ranking 3,724 of 3,764 hospitals.

AHA's response to the 2025 report came from Rick Pollack. He called such reports "distractions" built on "methodology that directly omits essential information." AHA and the Catholic Health Association released their own community benefit report one week before Lown's.

The Community Benefit Shell Game

• ►Intermountain Health (Allen): claims $1.3 billion in community benefit (2023), mostly Medicaid shortfalls, education, research and "community building." Had it been for-profit, it would have owed an estimated $362 million more in taxes. Narrowly defined charity care is a fraction of the headline.
• ►Methodist Le Bonheur (Ugwueke): claims $293 million in community benefit (2023). Free care to uninsured patients, as a share of revenue and tax-exemption value, has never been transparently broken out.
• ►Allina Health (Shannon): reported $608 million in community benefit (2022), but actual charity care was under 0.5% of expenses (2020), against a ~2% national average.
• ►UnityPoint Health (Glasgo): claims $1.3 billion using the same padded methodology.
• ►The witness table, April 28, 2026: nonprofit systems cited community benefit of $5.2 billion (CommonSpirit) and $2.4 billion (NewYork-Presbyterian) to justify their exemptions.

At the September 16, 2025 Ways and Means Oversight hearing, Subcommittee Chair David Schweikert signaled support for expanded Schedule H disclosure and facility-level reporting. Large systems currently report only at the system level, which hides which hospitals carry the charity load. AHA opposes changing the methodology.

Suing the Poor: The Collections Machine

Methodist Le Bonheur Healthcare (Michael Ugwueke, trustee; re-elected to a full term from 2027)

• ►8,300+ lawsuits against patients (2014–2018), more than all but one creditor in Shelby County.
• ►Wages garnished in 46% of cases, against 36% at Regional One and 20% at Baptist.
• ►It sued its own employees. A housekeeper earning $16,000 a year was sued for $23,000, and the system garnished the wages of 70+ workers.
• ►Patient Carrie Barrett, first sued in 2010, had interest added seven times and her paycheck garnished 15 times. Her debt reached $33,000.
• ►MLH owns its own collection agency.
• ►Of 977,000+ patients with bills at least 30 days past due, only 1% received financial assistance during collections.

AHA re-elected its CEO to a full three-year board term in July 2026.

Carilion Clinic (Robert Trestman, leaves the board Dec. 31, 2026)

• ►33,000 court judgments against patients in Roanoke small claims court (2003–2008), 40% of that court's entire caseload.

Allina Health (Lisa Shannon, trustee)

• ►Canceled appointments for patients with more than $4,500 in debt, including patients with chronic conditions. The New York Times exposed the policy, prompting a Minnesota AG inquiry (2023).

Yale New Haven (Sutton-Wallace, trustee)

• ►A long-running class action over inflated charges, liens and wage garnishment against uninsured patients remains part of the system's record.

Executive Compensation vs. Charity Care

• ►NYU Langone (Albert): former CEO Robert Grossman earned $22.8 million in 2023. Total executive compensation of $41.9 million equaled 39% of the system's $108 million charity care budget.
• ►Sentara Health (Hancock): holds $6 billion in net assets, "partly because it pays no taxes." The Checks and Balances Project filed an IRS complaint alleging Sentara charges uninsured patients more than insured ones.

False Claims Act: The Compliance Record

The Methodist Le Bonheur case settled in January 2024 for $7.25 million with no admission of liability. Methodist said the amount was under 3% of what the government originally sought.

Sanford's case is the starkest. A 111-page complaint alleged executives received "numerous warnings" from physician whistleblowers about a neurosurgeon's kickback and unnecessary-surgery scheme and "repeatedly failed to take corrective measures." Sanford had already paid $625,000 in 2013 over the same surgeon. Its CEO takes the AHA chair on Jan. 1, 2027.

No new 2025–2026 False Claims Act settlements involving board members' systems were found in this update. That covers the incoming trustees' systems (HCA, Hartford, Inova) only as far as the search budget allowed.

Labor: Strikes, Layoffs, and Offshoring

• ►Montefiore (Ozuah): about 15,000 NYSNA nurses at Montefiore, Mount Sinai and NewYork-Presbyterian struck from Jan. 12 to Feb. 9, 2026. It was the largest and longest nurses' strike in New York City history, and Gov. Hochul declared a state of emergency. The settlement added $15,000 to base pay over three years. The three systems spent about $100 million on replacement nurses. In May 2026, Montefiore told 12 utilization-review nurses their jobs would be replaced by AI software.
• ►Yale New Haven (Sutton-Wallace): about 150 Northeast Medical Group layoff notices (March 2025), about 600 voluntary retirements with a net cut of roughly 200 positions (July 2025), and about 38 management roles restructured (October 2025).
• ►Corewell Health (Freese Decker): about 10,000 nurses voted ~90% to authorize a strike over staffing ratios. Corewell eliminated unit-reassignment premium pay and canceled student loan repayment. About 186 billing employees were fired over Zoom and their work outsourced to India.
• ►Allina Health (Shannon): a 41-day nurses' strike (2016), a statewide strike (2022), and in 2025 a strike by 600+ physicians, PAs and NPs, the first physician strike in Minnesota history.
• ►Endeavor Health (Gallagher): a federal FLSA suit alleges unpaid pre-shift work and "deliberate understaffing to cut costs," citing 55 patient falls at three hospitals in 2024.
• ►Bristol Health (Barwis, departing): cut 60 FTE positions while the CEO earned about $800,000, at a system under going-concern audit doubt.

Facility Fees: The Revenue Model AHA Protects

• ►Houston Methodist (Boom): charges facility fees at transplant, wound care, radiation oncology and infusion clinics. One patient was billed $6,151.56 for what was described as a 30-minute conversation with a PA.
• ►NYU Langone (Albert): two bills per visit, one for the physician and one for the "facility." The fees spread with every retail site reclassified as a hospital outpatient department.
• ►Yale New Haven (Sutton-Wallace): Connecticut system fees more than doubled, from about $748 million (FY2017) to $1.6 billion+ (FY2024).
• ►Endeavor (Gallagher): did not respond to NBC Chicago's facility-fee investigation.

Washington's numbers make the stakes plain:

• ►Price gaps: Smith's examples from April 28, 2026: an ultrasound costs $164 in a physician office and $339 in a hospital outpatient department. A biopsy costs about $150 versus $800.
• ►Savings: CBO's site-neutral option is cited at more than $170 billion over 10 years.
• ►Concession: CommonSpirit's CEO conceded under questioning that "there might be opportunities for modifications to the current site-neutral process."

State facility-fee legislation in 2025–2026 could not be verified for this update.

Pressure Points (November 2026)

IRS

• ►The IRS announced 35 tax-exempt hospital examinations in 2024.
• ►In May 2025 it revoked a governmental hospital organization's 501(c)(3) status for failing the Section 501(r) community health needs assessment rules (Letter 202521025).
• ►The 2025–2026 Treasury/IRS Priority Guidance Plan includes Section 4960 excise-tax guidance on executive pay above $1 million. A revised Form 990 with more Schedule H transparency is expected within one to three years.

Congress

• ►January 2025: a Ways and Means menu floated eliminating nonprofit status for hospitals, a ~$260 billion, 10-year revenue raiser. It was left out of the final reconciliation law.
• ►September 16, 2025: the Ways and Means Oversight Subcommittee held a hearing on whether tax-exempt hospitals earn their exemption.
• ►January 28, 2026: Smith and Schweikert opened an organ transplant inquiry into Montefiore, Ozuah's system, and UChicago Medicine. Smith said hospitals that prioritized foreign nationals "should have their tax-exempt status terminated." No resolution had been reported as of November 2026.
• ►March 18, 2026: at an Energy & Commerce Health Subcommittee hearing, Pollack testified for AHA on the "provider landscape."
• ►March 30, 2026: a CRS report laid out minimum charity care requirements, tougher IRS oversight and taxes on hospital assets as options.
• ►April 28, 2026: the full Ways and Means Committee questioned the CEOs of HCA, CommonSpirit, NewYork-Presbyterian and ECU Health.
• ►Pending legislation: H.R. 3019 would tie a charity care floor to the value of each hospital's exemption.

State attorneys general

• ►Minnesota: the Sanford–Fairview review produced a law letting the AG enjoin or unwind healthcare deals.
• ►Ohio: the AG joined DOJ's February 2026 suit against OhioHealth.
• ►Texas: in October 2025, AG Ken Paxton warned Boom about transplant access for unvaccinated patients. Houston Methodist denied having such a policy.

Post-Chevron litigation

• ►Loper Bright (2024) set off what Bloomberg Tax called a barrage: hundreds of hospitals in dozens of suits against Medicare payment rules.
• ►AHA filed an amicus brief in the Medicare DSH case Advocate Christ, claiming HHS's reading cost hospitals more than $1 billion a year. The Supreme Court decided the case in 2025 without relying on Loper Bright.
• ►AHA's own scorecard: it lost twice on price transparency, won unanimously on 340B program reimbursement (2022), and won a preliminary injunction against HHS's 340B rebate pilot.

The Pattern

AHA board members lead institutions that:

1. ►Claim $149 billion in "community benefit" using a definition that counts Medicaid shortfalls and Medicare losses. On narrow measures, the charity care is about $16 billion, against $28 billion or more in tax breaks.
2. ►Include hospitals with some of the country's largest fair share deficits, including Evanston at -$152 million a year.
3. ►Sue thousands of patients, garnish their own employees' wages and cancel appointments over debt.
4. ►Pay CEOs $1.7 million to $16.7 million while posting operating losses and pleading hardship.
5. ►Settle federal fraud cases ranging from $560,000 to $84.5 million. The 2027 chair's system has a Corporate Integrity Agreement on its record.
6. ►Face the largest nurses' strike in New York City history, physician strikes, layoffs and offshoring.
7. ►Charge facility fees that double or quadruple the price of the same service, the practice AHA's lobbying exists to protect.

AHA's response to all of this has not changed under its new chief executive: dispute the methodology and defend the exemption. In 2027 it re-seats the CEO whose system sued 8,300 patients and hands the gavel to the CEO whose system paid $20.25 million to settle kickback allegations.

Sources: https://www.aha.org/news/blog/2026-01-08-hospital-benefits-communities-far-outweigh-tax-exemptions-closer-look-numbers ; https://lownhospitalsindex.org/wp-content/uploads/2025/04/fair-share-2025-national-report-20250409.pdf ; https://lownhospitalsindex.org/?p=15735 ; https://lownhospitalsindex.org/wp-content/uploads/2025/04/Texas_state-report.pdf ; https://lownhospitalsindex.org/wp-content/uploads/2025/04/Michigan_state-report.pdf ; https://www.beckershospitalreview.com/finance/hospital-community-investment-vs-tax-breaks-9-things-to-know ; https://beckershospitalreview.com/rankings-and-ratings/10-hospitals-health-systems-where-charity-care-lags-behind-tax-breaks.html ; https://www.aha.org/press-releases/2025-04-16-aha-statement-lown-institute-fair-share-report ; https://www.everycrsreport.com/reports/IF13192.html ; https://www.pwc.com/us/en/services/tax/library/continued-scrutiny-of-nonprofit-hospital-tax-exempt-status.html ; https://www.hfma.org/accounting-and-financial-reporting/the-hospital-tax-exemption-comes-under-scrutiny-in-congress/ ; https://www.withum.com/?p=132042 ; https://news.bloombergtax.com/daily-tax-report/ways-and-means-chair-hits-hospital-tax-exempt-status-bgov-tax ; https://waysandmeans.house.gov/?p=20051 ; https://legis1.com/news/hospital-pricing-extortion-ceos-face-fire-over ; https://essentialhospitals.org/on-the-hill-dhs-shutdown-ends-health-system-ceos-face-congress/ ; https://www.pulse.bot/healthcare/news/site-neutral-payment-debate-intensifies-in-hospital-affordability-hearing-af161b2a-cd17-48f3-9eca-4fb41624986d/ ; https://d1dth6e84htgma.cloudfront.net/03_18_2026_HE_Hearing_Memorandum_0a8170f092.pdf ; https://ahiporg-production.s3.amazonaws.com/documents/FINAL-03.18.26-AHIP_EC_Hearing_Statement_Examination_of_the_Provider_Landscape.pdf ; https://taxnews.ey.com/news/2025-1237-irs-revokes-tax-exempt-status-of-government-hospital-organization-that-failed-to-meet-the-community-health-needs-assessment-requirements-of-irc-section-501r ; https://www.justice.gov/usao-mdtn/pr/memphis-based-methodist-le-bonheur-healthcare-and-methodist-healthcare-memphis ; https://www.localmemphis.com/article/news/health/methodist-le-bonheur-healthcare-settlement-federal-lawsuit-partnership-west-clinic-memphis/522-40096c1c-873b-4a0c-9cf4-c58432505ae9 ; https://www.justice.gov/usao-ct/pr/hospital-owner-and-hospitalist-group-agree-pay-560k-settle-false-claims-act-allegations ; https://oig.hhs.gov/fraud/enforcement/sanford-health-entities-to-pay-2025-million-to-settle-false-claims-act-allegations-regarding-kickbacks-and-unnecessary-spinal-surgeries ; https://news.bloombergtax.com/social-justice/medicare-faces-barrage-of-hospital-pay-cases-after-chevrons-end ; https://www.yalejreg.com/wp-content/uploads/Gluck-et-al.-Bulletin.-Healthcare-Law-in-the-First-Year-After-Loper-Bright.pdf ; https://www.realclearhealth.com/2026/04/27/the_monopoly_tax_on_your_health_insurance_1179221.html ; https://www.aha.org/press-releases/2026-07-31-aha-names-new-trustees-board ; https://projects.propublica.org/nonprofits/organizations/131740114 ; https://www.healthbeat.org/newyork/2026/02/09/nurses-strike-agreement-hospitals ; https://waysandmeans.house.gov/2026/01/28/smith-schweikert-investigate-allegations-of-foreign-nationals-jumping-u-s-organ-transplant-line/ ; https://www.beckershospitalreview.com/finance/montefiore-posts-1-4-operating-margin-in-2025/ ; https://www.wshu.org/connecticut-news/2025-03-24/ct-ynhh-layoffs-northeast-medical-group ; https://siviq.co/nonprofits/people/pamela-sutton-wallace ; prior research files aha_intel_boom.md, aha_intel_albert.md, aha_intel_gallagher.md, aha_intel_slubowski.md, aha_intel_allen.md, aha_intel_ugwueke.md, aha_intel_shannon.md, aha_intel_hancock.md, aha_intel_freesedecker.md, aha_intel_trestman.md, aha_intel_gassen.md, aha_intel_glasgo.md, aha_intel_barwis.md

AHA's $25 million-a-year lobbying machine is backed by member-system spending, PAC money to both parties and a 2.8-million-person grassroots network. With it, AHA has delayed site-neutral payment, which CBO estimates would save more than $170 billion over 10 years. It sued twice to stop hospital price transparency and lost both times. It defends the 340B program as a profit center: $50 million in a single year at one board member's system. It has kept the ban on physician-owned competitors in place for 15 years, and it fights antitrust scrutiny while its board members' systems buy their way to market dominance. All of this rests on a tax exemption worth an estimated $28 billion a year, against roughly $16 billion in actual charity care.

The machine is now under its heaviest fire in a generation:

• ►Congress: Ways and Means Chairman Jason Smith called hospital prices "borderline extortion." His committee floated ending nonprofit status for hospitals (about $260 billion over 10 years) and, on April 28, 2026, put health system CEOs under oath.
• ►Antitrust: DOJ and Ohio forced OhioHealth to drop contract terms that blocked insurers from steering patients to cheaper care (proposed final judgment, June 2026).
• ►The IRS: it has started revoking exemptions under Section 501(r).

AHA's answer for 2027 is a new CEO, Steve Walsh, a former state lobbyist and legislator, and a board chaired by Sanford's Bill Gassen, the board's most aggressive acquirer. Whatever the new faces say, the agenda is the old one. Protect the exemption, the facility fees and the consolidation that pays for both.

Sources: https://ahiporg-production.s3.amazonaws.com/documents/FINAL-03.18.26-AHIP_EC_Hearing_Statement_Examination_of_the_Provider_Landscape.pdf ; https://waysandmeans.house.gov/?p=20051 ; https://www.hfma.org/accounting-and-financial-reporting/the-hospital-tax-exemption-comes-under-scrutiny-in-congress/ ; https://www.realclearhealth.com/2026/04/27/the_monopoly_tax_on_your_health_insurance_1179221.html ; https://taxnews.ey.com/news/2025-1237-irs-revokes-tax-exempt-status-of-government-hospital-organization-that-failed-to-meet-the-community-health-needs-assessment-requirements-of-irc-section-501r ; https://www.aha.org/press-releases/2026-07-31-aha-names-new-trustees-board ; prior research files aha_intel_hughes.md, aha_intel_hrobsky.md, aha_intel_golder.md, aha_intel_pollack.md, aha_intel_boom.md, aha_intel_gassen.md