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The congressional hearing before the Ways and Means Committee two weeks ago, summoning the chief executives of UnitedHea...
02/16/2026

The congressional hearing before the Ways and Means Committee two weeks ago, summoning the chief executives of UnitedHealth, Cigna, Elevance, Humana, Centene, and Molina, followed a pattern familiar to students of legislative oversight.

When public anger reaches sufficient intensity, elected officials subpoena the most recognizable figures in the offending industry.

The spectacle serves a dual function: it satisfies the public demand for accountability while leaving the deeper architecture of the problem untouched.

Consider what congressional scrutiny has not reached. Five individuals serve as the authorized official for ten separate Medicaid billing entities.

Their combined billing on a single service code totals $11.8 billion.

One operates two entities from the same building, four doors apart.

Another controls two entities bearing the same name at the same address, differentiated only by the placement of a comma.

This is not an anomaly at the margins.

This is the structure through which billions in taxpayer-funded Medicaid claims flow without congressional examination, public testimony, or institutional oversight of any kind.

The Big 6 insurers, whatever their failings, operate under layers of regulatory compliance, SEC disclosure requirements, and public accountability.

These five entities operate under none.

The history of financial regulation is consistent on this point: the actors who attract legislative attention are rarely the actors who represent the greatest systemic risk.

The subprime mortgage crisis was not caused solely by the large banks.

It was caused by thousands of unregulated mortgage originators operating beneath the threshold of institutional visibility.

The Medicaid billing apparatus presents an uncomfortable parallel.

Chairman Smith would do well to extend his committeeโ€™s attention to Suite 305 and Suite 309.

๐“๐ก๐ข๐ฌ ๐ข๐ง๐ฏ๐ž๐ฌ๐ญ๐ข๐ ๐š๐ญ๐ข๐จ๐ง ๐›๐ž๐ ๐š๐ง ๐ฐ๐ข๐ญ๐ก ๐š ๐ฌ๐ข๐ง๐ ๐ฅ๐ž ๐›๐ข๐ฅ๐ฅ๐ข๐ง๐  ๐œ๐จ๐๐ž. T1019. Personal care services. Bathing, dressing, and meal prep.$๐Ÿ๐ŸŽ...
02/15/2026

๐“๐ก๐ข๐ฌ ๐ข๐ง๐ฏ๐ž๐ฌ๐ญ๐ข๐ ๐š๐ญ๐ข๐จ๐ง ๐›๐ž๐ ๐š๐ง ๐ฐ๐ข๐ญ๐ก ๐š ๐ฌ๐ข๐ง๐ ๐ฅ๐ž ๐›๐ข๐ฅ๐ฅ๐ข๐ง๐  ๐œ๐จ๐๐ž.
T1019. Personal care services. Bathing, dressing, and meal prep.

$๐Ÿ๐ŸŽ๐ŸŽ+ ๐๐ข๐ฅ๐ฅ๐ข๐จ๐ง ๐ƒ๐จ๐ฅ๐ฅ๐š๐ซ๐ฌ ๐ฅ๐š๐ญ๐ž๐ซ, ๐ญ๐ก๐ž ๐๐š๐ญ๐š ๐ซ๐ž๐ฏ๐ž๐š๐ฅ๐ž๐ ๐Ÿ๐ข๐ง๐๐ข๐ง๐ ๐ฌ ๐ญ๐ก๐š๐ญ ๐ž๐ฑ๐ญ๐ž๐ง๐ ๐Ÿ๐š๐ซ ๐›๐ž๐ฒ๐จ๐ง๐ ๐ฉ๐ž๐ซ๐ฌ๐จ๐ง๐š๐ฅ ๐œ๐š๐ซ๐ž.

If this is what T1019 looks like, what does T1020 look like?
What about home health codes, DME codes, and behavioral health codes?

The same structural incentives exist across the Medicaid billing landscape: low oversight, easy entity creation, geographic clustering, and authorized official networks.

Medicaid is the largest payer in the U.S. healthcare system, covering 90 million people. It is also the least transparent.

The HHS dataset is now public.

How 98 Home Health Agencies Captured Half of Medicaid's $122.7 Billion Personal Care Budget

Who is NOT threatened by the Break Up Big Medicine Act:โ€ขLargest nonprofit hospital system in America. โ€ขEvery state Certi...
02/13/2026

Who is NOT threatened by the Break Up Big Medicine Act:

โ€ขLargest nonprofit hospital system in America. โ€ขEvery state Certificate of Need board.
โ€ขLobbyist who helped write Section 6001.
โ€ขThe American Hospital Association.
โ€ขThe Federation of American Hospitals.
โ€ขThe entire $275 billion annual subsidy apparatus.

Who IS threatened:

โ€ขThe insurer-PBM-physician conglomerates that make good headlines.

One group funds campaigns.
The other gets regulated.

Do you really trust the politicians?

The real reform agenda is five items:โ€ขRepeal the physician-owned hospital banโ€ขEliminate Certificate of Need lawsโ€ขEnforce...
02/12/2026

The real reform agenda is five items:

โ€ขRepeal the physician-owned hospital ban

โ€ขEliminate Certificate of Need laws

โ€ขEnforce site-neutral payments

โ€ขCondition nonprofit tax exemptions on actual community benefit

โ€ขSeparate insurer-PBM-physician conglomerates

This bill does one of five and calls it a revolution.
Do all of it, or admit the rest is theater.

https://open.substack.com/pub/dutchrojas/p/two-senators-want-to-break-up-big?r=3mc0ds&utm_medium=ios&shareImageVariant=poster

02/12/2026

Congress outlawed physician-owned hospitals in 2010.

The American Hospital Association and the Federation of American Hospitals lobbied for it.

CMS data shows 9 of the top 10 hospitals for quality, access, and cost are physician-owned.

Charges are one-third lower than traditional hospitals for the same procedures.

Congress banned the best model and now wonders why healthcare is expensive.

And youโ€™re wondering why your premiums are high? Kennedy and OZ could fix it tomorrowโ€ฆ

Boston.700,000 people.Home to some of the most celebrated academic medical centers on earth.One ambulatory surgery cente...
02/11/2026

Boston.
700,000 people.

Home to some of the most celebrated academic medical centers on earth.

One ambulatory surgery center.

Senator Warrenโ€™s state banned ASCs for 47 years. Then gave health systems veto power over any that tried to open.

Do you know how Massachusetts tried to solve
healthcare?

They send all patients to the highest acuity health systems and bill them for the highest codes and then wonder why premiums are high.

This is the senator who wants credit for fighting the healthcare monopoly.

The Break Up Big Medicine Act borrows from Glass-Steagall, the 1933 Banking Act that separated commercial and investment...
02/11/2026

The Break Up Big Medicine Act borrows from Glass-Steagall, the 1933 Banking Act that separated commercial and investment banking after the Great Depression.

The comparison is apt.
But here is the lesson the sponsors missed.

Glass-Steagall worked for 66 years.
Congress repealed it in 1999 without addressing the incentive structures underneath.

Nine years later, the financial system collapsed.

This bill proposes structural separation without touching the $275 billion annual subsidy apparatus that created the consolidation in the first place.

The 340B program grew 23% in a single year. Medicaid supplemental payments tripled to $90.1 billion.

Site-neutral payment violations cost Medicare $1.6 billion in unnecessary spending.

Structural separation absent incentive reform is a temporary fix.

The US has already ran this experiment.
It ended in 2008.

Massachusetts banned new surgery centers for 47 years. Missouri regulates 14 healthcare services through Certificate of Need. Their bill targets their personal enemies, not those of the United States.

02/11/2026

Rory Sutherland once observed that the opposite of a good idea can also be a good idea. In healthcare, the opposite of conventional wisdom is often closer to the truth.

Conventional wisdom:
Drug prices are high because drugs are expensive to develop.

The reframe:
Drug prices are high because no one has ever built a market in which prices are set through competition.

Every "price" in healthcare is a negotiation, a political outcome, or an administrative fiction.

The pharmaceutical industry does not have a pricing problem.
It has a market design problem.

And market design is a solved problem.
We solved it in 1530.

๐“๐ก๐ž๐ซ๐ž ๐ข๐ฌ ๐š ๐œ๐จ๐ง๐œ๐ž๐ฉ๐ญ ๐ข๐ง ๐ฌ๐ฒ๐ฌ๐ญ๐ž๐ฆ๐ฌ ๐ญ๐ก๐ข๐ง๐ค๐ข๐ง๐  ๐ญ๐ก๐š๐ญ, ๐จ๐ง๐œ๐ž ๐ฅ๐ž๐š๐ซ๐ง๐ž๐, ๐œ๐š๐ง๐ง๐จ๐ญ ๐›๐ž ๐ฎ๐ง๐ฅ๐ž๐š๐ซ๐ง๐ž๐.A second-order solution treats visible sy...
02/10/2026

๐“๐ก๐ž๐ซ๐ž ๐ข๐ฌ ๐š ๐œ๐จ๐ง๐œ๐ž๐ฉ๐ญ ๐ข๐ง ๐ฌ๐ฒ๐ฌ๐ญ๐ž๐ฆ๐ฌ ๐ญ๐ก๐ข๐ง๐ค๐ข๐ง๐  ๐ญ๐ก๐š๐ญ, ๐จ๐ง๐œ๐ž ๐ฅ๐ž๐š๐ซ๐ง๐ž๐, ๐œ๐š๐ง๐ง๐จ๐ญ ๐›๐ž ๐ฎ๐ง๐ฅ๐ž๐š๐ซ๐ง๐ž๐.

A second-order solution treats visible symptoms within an existing system.
A first-order solution changes the structure that produces the symptoms.

Every drug pricing intervention of the last 30 years has been second-order.

PBMs negotiated within the system.
GoodRx arbitraged within the system.
Cost Plus is priced honestly within the system.
TrumpRx negotiated politically within the system.

Not one asked why the system produces wrong prices in the first place.

The answer: healthcare has no market.
No exchange. No mechanism for price discovery.

It is the only major industry in America that skipped the transition from administered pricing to open competition.

The Dutch built the first commodity exchange in 1530.
Agriculture followed in 1848.
Energy in the 1990s.

Healthcare is still waiting.
It does not have to.

There is a pattern hiding in plain sight.

๐€ ๐ง๐ฎ๐ฆ๐›๐ž๐ซ ๐ฐ๐จ๐ซ๐ญ๐ก ๐ฌ๐ข๐ญ๐ญ๐ข๐ง๐  ๐ฐ๐ข๐ญ๐ก: ๐†๐ž๐ง๐ž๐ซ๐ข๐œ ๐๐ซ๐ฎ๐ ๐ฌ ๐š๐œ๐œ๐จ๐ฎ๐ง๐ญ ๐Ÿ๐จ๐ซ ๐Ÿ—๐ŸŽ% ๐จ๐Ÿ ๐ฉ๐ซ๐ž๐ฌ๐œ๐ซ๐ข๐ฉ๐ญ๐ข๐จ๐ง๐ฌ ๐Ÿ๐ข๐ฅ๐ฅ๐ž๐ ๐ข๐ง ๐€๐ฆ๐ž๐ซ๐ข๐œ๐š. ๐“๐ก๐ž๐ฒ ๐š๐œ๐œ๐จ๐ฎ๐ง๐ญ ๐Ÿ๐จ๐ซ ๐Ÿ๐Ÿ% ๐จ๐Ÿ ๐ญ...
02/10/2026

๐€ ๐ง๐ฎ๐ฆ๐›๐ž๐ซ ๐ฐ๐จ๐ซ๐ญ๐ก ๐ฌ๐ข๐ญ๐ญ๐ข๐ง๐  ๐ฐ๐ข๐ญ๐ก: ๐†๐ž๐ง๐ž๐ซ๐ข๐œ ๐๐ซ๐ฎ๐ ๐ฌ ๐š๐œ๐œ๐จ๐ฎ๐ง๐ญ ๐Ÿ๐จ๐ซ ๐Ÿ—๐ŸŽ% ๐จ๐Ÿ ๐ฉ๐ซ๐ž๐ฌ๐œ๐ซ๐ข๐ฉ๐ญ๐ข๐จ๐ง๐ฌ ๐Ÿ๐ข๐ฅ๐ฅ๐ž๐ ๐ข๐ง ๐€๐ฆ๐ž๐ซ๐ข๐œ๐š. ๐“๐ก๐ž๐ฒ ๐š๐œ๐œ๐จ๐ฎ๐ง๐ญ ๐Ÿ๐จ๐ซ ๐Ÿ๐Ÿ% ๐จ๐Ÿ ๐ญ๐จ๐ญ๐š๐ฅ ๐๐ซ๐ฎ๐  ๐ฌ๐ฉ๐ž๐ง๐๐ข๐ง๐ .

Branded drugs account for 10% of prescriptions.
They account for 88% of spending.

Cost Plus covers the 12%.
GoodRx arbitrages both.
PBMs extract from both.
TrumpRx covers 40 drugs.

Not one of these built a market for the 88%.

The structural problem is not price.
It is the absence of price discovery.

Healthcare has charge masters, rebates, clawbacks, DIR fees, and political negotiations.

What it does not have is a place where buyers and sellers meet, and prices form through competition.

That is not a detail.
That is the diagnosis.

Today's article: https://buff.ly/Ru4IEOF

There is a pattern hiding in plain sight.

When physicians leave independent practice for hospital employment, Medicare costs per patient per year increase by $1,3...
02/09/2026

When physicians leave independent practice for hospital employment, Medicare costs per patient per year increase by $1,327.

When they move to models that preserve the practice structure, costs decrease by $963.

Consolidation does not reduce spending.
It increases it.
The data is not ambiguous.

https://dutchrojas.substack.com/p/718-million-thats-how-much-the-middleman

When a practice pays an insurance premium, four things happen.The carrier pays claims.The carrier covers operating costs...
02/09/2026

When a practice pays an insurance premium, four things happen.

The carrier pays claims.
The carrier covers operating costs.
The carrier keeps underwriting profit.
The carrier invests the float.

Warren Buffett built Berkshire Hathaway on that fourth one.
Your premiums built it for him.

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