On January 15, 2026, President Trump released a high-level proposal for what he’s calling the “Great Healthcare Plan.” While the proposal outlines several policy goals, it currently lacks the operational and legislative details required for implementation.
As with all proposed federal healthcare changes, 90 Degree Benefits is closely monitoring Trump’s Great Healthcare Plan to understand how it could impact employers across the U.S., particularly those sponsoring self-funded and level-funded health plans.
Below is a practical breakdown of the proposal’s key components and what employers and brokers should be watching.
Key Components Relevant to Self-Funded Health Plans
Most Favored Nation (MFN) Drug Pricing and Expanded OTC Access
The proposal builds on Most Favored Nation (MFN) drug pricing concepts previously explored by the Trump Administration, aiming to reduce prescription drug costs by tying prices to international benchmarks.
It also expands over-the-counter (OTC) access for certain medications. In theory, this could help lower plan costs by:
- Reducing the need for physician visits solely to obtain prescriptions
- Decreasing the volume of drugs processed through the prescription benefit
However, there may be tradeoffs. OTC medications are typically paid for directly by employees and may not be tracked or reimbursed through the health plan, potentially shifting more out-of-pocket costs to members and reducing employer visibility into utilization patterns.
Insurance Premium Reductions and Increased Price Transparency
The proposal emphasizes price transparency, calling for clearer cost reporting from insurers and healthcare providers.
For self-funded employers, transparency is already a core value and a key reason many partner with a third-party administrator like 90 Degree Benefits. Additional transparency requirements could further support:
- More accurate benchmarking
- Better provider comparisons
- Stronger leverage in contract negotiations
Greater access to actionable cost data strengthens employers’ ability to manage healthcare spend without sacrificing quality of care.
Federal Funds Directed to Individuals, Not Insurers
Another component of the proposal would redirect certain federal healthcare funds directly to individuals, potentially through health savings accounts (HSAs) or similar consumer-directed mechanisms.
This aspect primarily affects the individual insurance marketplace, not ERISA-governed group health plans. However, broader shifts in how individuals access and fund coverage could indirectly influence:
- Plan design strategies
- Employer contribution approaches
- Market dynamics between self-funded and fully insured options
- Overall insurance pricing trends
Potential Positive Implications for Employers
If enacted as written, elements of the proposal could present opportunities for self-funded employers:
- Reduced Prescription Drug Spend
- Pricing reforms may help lower overall pharmacy costs for self-funded plans.
- Greater Cost Transparency
- Enhanced reporting requirements could make it easier to evaluate provider performance and negotiate more effectively.
- Expanded Plan Design Flexibility
- Increased emphasis on HSAs and consumer-directed benefits may support broader adoption of high-deductible or value-based plan designs.
What Employers Should Watch Next
At this stage, the proposal remains conceptual and would require Congressional action to move forward. As with any federal healthcare initiative, the final version, if enacted, could look significantly different from the initial outline.
The legislative process will determine:
- Whether the proposal advances
- Which components are modified or removed
- How and when any changes would take effect
Our Commitment to Brokers and Employers
90 Degree Benefits will continue monitoring state and federal healthcare regulatory developments and translating them into clear, actionable guidance. Our goal is to help brokers and employers:
- Stay compliant
- Anticipate regulatory shifts
- Design smarter healthcare plans that balance quality care with meaningful cost control
If you have questions about how potential regulatory changes could impact your plan strategy, our team is here to help.
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FAQs: Trump’s Healthcare Proposal and Self-Funded Health Plans
Does Trump’s healthcare proposal affect self-funded employer health plans?
The proposal does not directly change self-funded health plan rules today, but several elements, such as prescription drug pricing reforms and expanded price transparency, could indirectly impact plan costs, negotiations, and long-term strategy for employers.
Will this proposal change ERISA requirements for employer plans?
No. The proposal does not currently amend ERISA. However, market-wide pricing and transparency changes could influence how ERISA plans are designed and managed if the proposal advances.
How could the proposal impact prescription drug costs for employers?
If enacted, Most Favored Nation drug pricing could help lower pharmacy spend for self-funded plans. Expanded over-the-counter access may also reduce prescription claims, though it could shift some costs directly to employees.
Does expanded price transparency benefit self-funded employers?
Yes. Greater transparency from providers and insurers could improve cost benchmarking, strengthen negotiations, and give employers better insight into healthcare spending without reducing care quality.
Should employers make plan changes now?
No immediate action is required. The proposal is still conceptual and would require Congressional approval. Employers should monitor developments and consult with their broker or TPA before making any plan design changes.
How is 90 Degree Benefits helping employers navigate potential changes?
90 Degree Benefits monitors federal and state healthcare policy and translates regulatory developments into practical guidance, helping employers and brokers stay compliant and plan strategically.