By Laura Hanen, Senior Policy Advisor, Venable LLP
AAPP had a busy year advocating on behalf of the membership with Congress and the Administration amidst a rapidly changing federal landscape. Throughout the year, AAPP worked to advance the policy priorities outlined in the 2025 Health Policy Agenda. As the new year begins, we look back on the advocacy activities AAPP was engaged in last year with the expectation that 2026 will be full of activity once again. Highlights include:
AAPP Response to Changing Federal Landscape
The year 2025 brought the arrival of a second Trump Administration. A cornerstone of its health policy agenda is the Make America Healthy Again (MAHA) initiatives led by HHS Secretary, Robert F. Kennedy, Jr. With the intent to focus on addressing chronic disease and increasing access to nutritious food, MAHA activities unfortunately have called into question the safety and efficacy of vaccines, the over prescribing of mental health medications, and linking Tylenol use in pregnancy to autism.
Simultaneously, there have been significant and concerning staff and program cuts at SAMHSA, CDC and NIH. There has also been a shift in appointed agency leaders who don’t necessarily have a background in health care or public health but do share loyalty to the goals of the Administration. Funding and grant reviews must now reflect the Administration’s policy priorities. For example, see SAMHSA’s strategic priorities here that will no longer support harm reduction nor “misguided policies, investments in unsupported clinical interventions, and any unlawful focus on specific populations.” Further, the HHS Secretary is seeking to subsume SAMHSA and parts of CDC and HHS into a new agency – the Administration for a Healthy America - in the new year.
In response, AAPP created the Rapid Action Task Force (RATF) to develop timely policy statements and issue briefs to lay out the evidence-base and make policy recommendations. This included AAPP issuing a statement on the Make America Healthy Again Commission. In 2025, the RATF drafted 37 Board-approved policy statements and seven policy briefs on harm reduction, antidepressants for youth, antipsychotics, mood stabilizers, SSRIs, stimulants for ADHD, SUD medication treatment. The work of the RATF, as a subcommittee of the Government Affairs Committee, will continue in 2026.
AAPP By the Numbers
- 39 Hill visits by AAPP’s Board, Government Affairs Committee, and SUD Committee
- 16 comment letters to the Administration
- 14 pieces of legislation actively supported by AAPP
- 21 pieces of legislation or policy changes supported in coalition through 24 sign-on letters
- 11 sign-on letters in support of federal funding/report language
- 37 policy statements drafted by the Rapid Action Task Force
- 7 policy briefs drafted
- 12 advocacy fact sheets for use with policy makers
Pharmacist Scope of Practice
AAPP continued to support legislative efforts to open the door to payment to pharmacists for patient care services. This included collaborating with national pharmacy organizations on two work streams. The first is the Equitable Community Access to Pharmacy Services (H.R. 3164/S. 2426) that would allow pharmacists to provide patient care and receive reimbursement for evaluation and management of patients for testing and treatment of COVID-19, influenza, RSV, or strep throat. Support for the bills has remained steady in the 119th Congress with 69 cosponsors in the House and 27 cosponsors in the Senate. The House bill has been championed by leaders on the House Ways and Means Committee who seek to pass it in committee but continue to navigate opposition by physicians on the committee.
The second work stream is an on-going collaboration with the Hematology/Oncology Pharmacy Association, American College of Clinical Pharmacy, and Society of Infectious Diseases Pharmacists on a strategy to pursue legislation to establish a CMMI demo to pay for clinical pharmacist services as part of a care team. The legislation is being shopped around to potential bill sponsors.
AAPP also responded to a Request For Information on pharmacists providing chronic care to seniors and in underserved and rural areas from the Senate sponsors of the Support the Pharmacy and Medically Underserved Areas Enhancement Act (S. 2800). This was an opportunity to emphasize the necessity for Medicare to pay for the important work of psychiatric pharmacists to expand access to MH and SUD services, including comprehensive medication management.
SUPPORT Act Passage
AAPP weighed-in with Congress to adopt the SUPPORT for Patients and Communities Reauthorization Act (P.L. 119-44) that was signed by the President on December 1. Many of the provisions in the original 2018 law had expired in September of 2023. The new law reauthorizes and updates a number of federal substance use-related programs through FY2030. Highlights include:
- Reauthorizing grants to recruit and educate students to pursue careers in mental and behavioral health.
- Reauthorizing a loan repayment program for SUD treatment providers in high-need areas.
- Reauthorizing CDC grants for evidence-based prevention activities, data collection, and prescription drug monitoring programs.
- Requiring state Medicaid plans to cover MOUD for opioid use disorder.
- Making permanent the state option to waive the Medicaid IMD Exclusion for individuals receiving SUD treatment, allowing Medicaid coverage in certain residential treatment settings that were previously restricted.
- Expanding requirements for HHS to gather state-by-state data on SUD and mental health service provision under Medicaid and CHIP.
- Directing HHS and FDA to re-evaluate scheduling of buprenorphine-naloxone combo products, such as Suboxone and Subutex and, if appropriate, request that the attorney general initiate rulemaking proceedings to revise the schedules accordingly.
- Clarifying that pharmacies can deliver Schedule III, IV, or V drugs to a healthcare provider for medication addiction treatment if the drug has been properly reviewed for potential risks and a provider sufficiently monitors the patient after they receive it.
- Expanding the list of organizations through which prescribers of controlled substances can receive eight hours of required training to include training provided by the American Pharmacists Association and the Accreditation Council on Pharmacy Education.
Maintaining Telehealth and Teleprescribing Flexibilities
AAPP urged Congress to take action to ensure that the Medicare telehealth flexibilities granted during the COVID-19 public health emergency (PHE) didn’t expire on September 30, 2025. Unfortunately, the flexibilities did expire during the government shutdown but have been extended through January 30, 2026. In lieu of permanency, AAPP is also urging Congress to pass a two-year extension to provide stability and to delink the flexibilities from the annual appropriations process.
AAPP also advocated for the continuation of the flexibilities for the teleprescribing of controlled substances instituted during the PHE by the DEA that expire on December 31, 2025. The DEA has yet to issue a new proposed rule to establish a special registration process per the Ryan Haight Act of 2008 or finalize policies for when the practitioner and the patient have not had a prior in-person medical evaluation. A fourth extension of the flexibilities through the end of 2026 was published in the Federal Register on December 31.
ACA Enhanced Premium Tax Credits
AAPP advocated for the extension of the Affordable Care Act (ACA) enhanced premium subsidies (EPTCs) which are set to expire at the end of the year impacting the more than 20 million Americans who rely on the subsidies to afford coverage. The expiration of the EPTCs is projected to raise health premiums by 26% on average and out-of-pocket costs are expected to more than double. Low-income enrollees and those who live in states that have not expanded Medicaid are expected to see the most significant premium increases.
In December, the Senate rejected two competing bills that would have extended the EPTCs. While there is a bipartisan group of Senators continuing to negotiate, a health package to include an extension of the EPTCs will not be released until after Congress returns in January. The House will also vote on extending the ACA EPTCs per a bipartisan discharge petition. It remains to be seen if a consensus can be reached in both chambers.
Looking to 2026
Congress is starting the year with nine must-pass annual spending bills with a deadline of January 30 when the Continuing Resolution to keep the government funded ends. With 2026 being an election year, Congress and the Administration will be seeking to adopt policies to address affordability across health care, housing, food, and more. There will also likely be an effort to pass a health care package to address, among other issues, Pharmacy Benefit Managers and the telehealth flexibilities.
AAPP will also be watching and weighing in on the following: the future of SAMHSA, funding cuts to mental health and SUD programs, implementation of Medicaid work requirements and the impact on people with mental and SUD disorders, and MAHA activities including actions to limit access or undermine mental health medications. While Congress will slow down in late summer through the fall to campaign, we expect the Trump Administration to keep up its breakneck speed in issuing Executive Orders, regulations, and guidance impacting health throughout the year.