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Rand Issues Commentary: Venezuela After Maduro - Q&A With RAND Experts
SANTA MONICA, California, Feb. 4 -- Rand issued the following commentary on Feb. 3, 2026:* * *
Venezuela After Maduro: Q&A with RAND Experts
By Tahina Montoya, Marie Jones and Kelly Piazza
Today marks one month since the dramatic U.S. operation in Venezuela that captured Nicolas Maduro, the country's president, and brought him to New York City to face federal drug trafficking charges.
While many details about the operation are clearer now than they were in the immediate aftermath, it remains uncertain how the sudden change in Venezuela might shape long-term political, economic, and institutional ... Show Full Article SANTA MONICA, California, Feb. 4 -- Rand issued the following commentary on Feb. 3, 2026: * * * Venezuela After Maduro: Q&A with RAND Experts By Tahina Montoya, Marie Jones and Kelly Piazza Today marks one month since the dramatic U.S. operation in Venezuela that captured Nicolas Maduro, the country's president, and brought him to New York City to face federal drug trafficking charges. While many details about the operation are clearer now than they were in the immediate aftermath, it remains uncertain how the sudden change in Venezuela might shape long-term political, economic, and institutionaldynamics--both within the country and across the region.
To better understand this uncertainty and identify trends to watch moving forward, we asked three RAND experts to discuss why Venezuela remains critical for Latin America, how regional players are responding to change in Caracas, the nature of the U.S.-Venezuela relationship, and more.
Q: Why is Venezuela's political trajectory so consequential for Latin America?
TAHINA MONTOYA: Because the crisis extends beyond Venezuela's borders. Prolonged authoritarian rule has imposed severe costs on Venezuelans, including rising living expenses and widespread human rights abuses, while also driving large-scale migration and enabling criminal and armed actors. At the same time, Venezuela has become a case study for how the United States, hemispheric partners, and adversaries respond, with critical implications for regional norms, security cooperation, and broader hemispheric security.
MARIE JONES: Venezuela has become Latin America's most closely watched case of democratic erosion followed by uncertain political reconfiguration. Its trajectory matters not only because of its size, resources, and population, but because it shapes regional expectations about whether deeply captured states can recover democratic governance. Venezuela's experience influences norms around executive power, electoral integrity, and the role of security forces in politics. Materially, its instability has driven the largest displacement crisis in the region's modern history, straining neighboring governments and regional institutions.
KELLY PIAZZA: Venezuela's fate reverberates across the region. Once one of Latin America's most prosperous democracies, its turn toward authoritarianism and economic collapse has impacted neighboring states through mass migration, humanitarian challenges, and shifts in regional alliances--developments that have strained social systems and reshaped domestic politics across the region. Additionally, Venezuela has long functioned as a key supporter and partner of other authoritarian regimes in the region, most notably Cuba. Its ongoing political turmoil and economic deterioration directly influence the stability and resources of its allies, while also serving as a cautionary tale of how comparable regimes might experience strain or unravel under similar conditions. More broadly, Venezuela's experience informs broader regional debates about governance, democracy, nationalization, and relations within the hemisphere.
What are the most plausible scenarios for Venezuela over the next one to three years?
MONTOYA: Whatever comes next for Venezuela will require a deliberate, phased strategy and sustained cooperation to avoid further instability and enable lasting change. While a political transition remains possible, recent rhetoric from interim President Delcy Rodriguez suggests that this path remains fragile. Any credible way forward must incorporate the voices of Venezuelans most affected by the crisis. Their perspectives are essential to restoring governance, addressing security challenges, and achieving durable outcomes.
JONES: Several scenarios appear plausible in the near term. One is a form of managed authoritarian continuity, in which political power is redistributed within existing elite networks without meaningful democratization. Another is a partial political opening--such as limited electoral reforms or negotiated power-sharing--that stops short of full democratic transition. A more ambitious scenario would involve a negotiated political reconfiguration leading to competitive elections and institutional rebuilding.
PIAZZA: Recent events illustrate that "regime decapitation does not equal regime change." Although Nicolas Maduro has been replaced by Delcy Rodriguez, most of the ruling structure remains intact. As a result, little has shifted on the ground. The same security forces patrol the streets, fear continues to silence dissent, and state media spouts its familiar propaganda.
Although Venezuela could eventually progress toward a democratic transition--whether organically or through a negotiated arrangement in which Chavista leaders agree to elections under domestic and international pressure--the most plausible near-term scenario remains the persistence of a deeply entrenched authoritarian system marked by ongoing instability.
How have countries around Latin America responded over the last month? How do you see them adjusting to shifts in Venezuela moving forward?
MONTOYA: Latin American governments have fallen into four categories as Venezuela's crisis has unfolded. The first group is made up of states that support Maduro's removal as a blow to authoritarianism and criminal networks (e.g., Argentina). The second group condemns the move as a violation of sovereignty and international law (e.g., Colombia). A third group remains cautious, prioritizing stability, border security, and spillover risk (e.g., Panama). And a fourth group reflects mixed or internally divided positions (e.g., Chile). These divergent responses are likely to persist, making credible solutions for Venezuela critical as developments could either mitigate or aggravate hemispheric instability.
What about Cuba? Does Maduro's ouster bring the island's regime and fragile economy closer to collapse, as many observers have speculated?
JONES: Any sustained disruption to Cuba's economic and energy lifeline from Venezuela increases pressure on an already fragile Cuban economy. However, collapse is not inevitable. Havana has shown resilience before, notably during the "Special Period" following the collapse of the Soviet Union, by adapting to external shocks through rationing, diversification of partners, and internal controls. The more immediate effect is heightened economic stress and political risk, rather than sudden regime failure. Much depends on how Venezuela's energy and foreign policy orientations evolve.
PIAZZA: Allies and partners have undeniably been pivotal in sustaining Cuba's regime. The reduction in Venezuela's oil supplies has placed significant pressure on Havana, worsening power outages, living conditions, and adding to strain, more broadly. The regime's endurance partially hinges on how other nations react to U.S. efforts to isolate and pressure Cuba. Nevertheless, there are strong reasons to believe it will persist as it has for decades: The government remains effectively "coup-proofed," without a unified or institutionalized opposition, and benefits from both robust mechanisms of repression and a capable intelligence network.
MONTOYA: Cuba has long relied on Venezuelan energy and economic support. With that support now sharply reduced, shortages in basic needs are likely to drive internal instability. Given that Cuba is just 90 miles from the United States, instability on the island carries direct security implications, especially as the ongoing crisis in Haiti is already destabilizing the Caribbean.
How could different political outcomes in Venezuela affect regional migration patterns?
MONTOYA: Different political outcomes in Venezuela will shape migration in ways that directly affect security and stability across the hemisphere. A poorly planned or executed transition is likely to sustain displacement, increasing pressure on neighboring countries. By contrast, a coherent, gradual transition could restore confidence and reduce outward migration, particularly if basic needs and security concerns are addressed. For this reason, incorporating the perspectives of Venezuelans most affected by the crisis is essential to easing migration pressures and preventing further instability.
JONES: If Venezuela experiences even modest stabilization through improved governance, economic management, or security, then outward migration could slow. Large-scale return migration is unlikely in the near term. Conversely, prolonged uncertainty or institutional breakdown would likely sustain or renew migration flows, particularly toward Colombia, Brazil, Peru, and the Caribbean. Over time, the challenge for the region is shifting from emergency response to long-term integration (PDF); millions of Venezuelans have already established durable economic and social ties outside their country.
PIAZZA: If Venezuela's dictatorship further consolidates or the country descends into deeper chaos, migration would likely intensify as people flee deteriorating conditions, with fewer targeting the United States than in the past because of the current restrictive U.S. immigration climate. Conversely, a democratic transition marked by greater stability and economic recovery would likely slow outward migration and encourage more Venezuelans to remain or even return home. (Roughly 8 million have left in recent years.)
U.S. leaders have said that Venezuela's vast oil reserves were a key driver behind last month's operation. What might need to happen on the ground in Venezuela to move the needle for U.S. energy security?
JONES: Venezuela's oil potential is constrained less by geology than by governance. Meaningful contributions to global or U.S. energy markets would require political stability, clear legal frameworks, professional management of the oil sector, and substantial reinvestment in infrastructure. Production capacity deteriorated under Maduro and cannot be restored quickly. Even under favorable conditions, recovery would likely take several years and depend on market access, technical expertise, and confidence that the rules governing contracts and revenues will remain stable.
The U.S.-Venezuela relationship is critical to shaping the post-Maduro transition. What exactly is the nature of this relationship now? Or is it still coming into focus?
MONTOYA: The U.S.-Venezuela relationship is still delicately evolving. While U.S. actions have shaped the immediate post-Maduro environment and early rhetoric was inconsistent, the United States has clarified that its role is intended to be temporary and focused on stabilization rather than long-term governance. How the relationship evolves will depend on the consistency of U.S. policy, the direction of Venezuela's political transition, the role of regional partners, and the will of the Venezuelan people, with direct implications for regional and hemispheric security.
PIAZZA: The U.S.-Venezuela relationship is evolving. The Rodriguez administration appears intent on balancing its hold in Venezuela while attempting to meet the demands of the Trump administration.
This tension is particularly evident in the issue of prisoner releases. While many political prisoners have been freed, they are under strict conditions of silence, even as many others remain or are newly imprisoned.
In recent days, these strains seem to have intensified. Early signs of cooperation between the Rodriguez and Trump administrations are giving way to growing friction. Should Venezuela's interim leadership deviate from U.S. expectations, the possibility of new military action against the country cannot be ruled out.
What indicators should policymakers watch to assess Venezuela's trajectory moving forward?
MONTOYA: Policymakers should look beyond rhetoric and focus on actions. Internally, this means watching whether the interim government can stabilize the country, take credible steps toward inclusive governance, improve cost-of-living conditions, and demonstrate a real commitment to human rights. Migration trends--whether Venezuelans continue to leave or feel confident enough to return--will be an important indicator of progress or continued distress. Externally, who Venezuela partners with, and how, will shape its strategic direction and influence broader regional stability.
JONES: Key indicators include changes in the independence and behavior of electoral and judicial institutions, shifts in elite alliances with security forces, and decisions about economic governance and public finance. Trends in civic space, media freedom, and repression are also critical. On the economic side, transparency in the oil sector and social service delivery will matter. These indicators should provide a clearer picture over time of whether Venezuela is moving toward stabilization, stagnation, or renewed crisis.
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More About This Commentary
Tahina Montoya is a defense and policy researcher at RAND and a professor of policy analysis at the RAND School of Public Policy.
Marie Jones is a senior international and defense researcher at RAND and co-director of the RAND Forecasting Initiative.
Kelly Piazza is a political scientist at RAND.
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Original text here: https://www.rand.org/pubs/commentary/2026/02/venezuela-after-maduro-qa-with-rand-experts.html
[Category: ThinkTank]
Jamestown Foundation Issues Commentary: Kremlin's Russian Nationalism Alienating Non-Russians at Home and Abroad
WASHINGTON, Feb. 4 -- The Jamestown Foundation issued the following commentary on Feb. 3, 2026, in its Eurasia Daily Monitor:* * *
Kremlin's Russian Nationalism Alienating Non-Russians at Home and Abroad
By Paul Goble
Executive Summary:
* Russian President Vladimir Putin's increasing appeals to Russian ethno-nationalism--which he has employed to sustain support as Moscow enters the fifth year of its war against Ukraine--are alienating non-Russians domestically and across the former Soviet space.
* Putin's repression has decreased the visibility of non-Russian alienation within Russia, but ... Show Full Article WASHINGTON, Feb. 4 -- The Jamestown Foundation issued the following commentary on Feb. 3, 2026, in its Eurasia Daily Monitor: * * * Kremlin's Russian Nationalism Alienating Non-Russians at Home and Abroad By Paul Goble Executive Summary: * Russian President Vladimir Putin's increasing appeals to Russian ethno-nationalism--which he has employed to sustain support as Moscow enters the fifth year of its war against Ukraine--are alienating non-Russians domestically and across the former Soviet space. * Putin's repression has decreased the visibility of non-Russian alienation within Russia, buthas not reduced it. Internationally, his war against Ukraine and bullying of other former Soviet republics have intensified anti-Moscow sentiments and led other countries in the region to distance themselves from Russia.
* There are some signs that Putin is learning that appealing only to the largest nationality within an empire has limited utility, but his moves away from this strategy have so far been ineffective.
Russian President Vladimir Putin has adopted ever more intense imperial Russian ethno-nationalism as his war against Ukraine grinds on. This trend is alienating non-Russians both within their own country and across the former Soviet space (Window on Eurasia, June 12, 2022, December 3, 2023; see EDM, June 24, 2025). The Kremlin's repressive actions at home have obscured but not reduced this trend. Putin's continuing aggression against Ukraine and bullying of other former Soviet republics that he believes are part of Moscow's sphere of influence have intensified anti-Moscow feelings and led almost all the countries in the region to distance themselves from Russia (Window on Eurasia, March 17, 2022; see EDM, June 5, 2025; Idel.Realii, December 22, 2025). The situation has become so serious that there are some signs Putin--having begun to learn that relying on a core nationality alone is typically counterproductive--is backing away from some, but far from all, of his nationalist and imperialist positions (see EDM, June 5, 2025; Window on Eurasia, January 30, 2023, July 8, 26, 2025). His moves in that direction appear to be ringing hollow with his intended audiences and may leave him and his regime in an even worse position. This may especially be the case if non-Russians within Russia and the non-Russian countries conclude that he has been weakened and thus is in retreat (Natsional'nyi Aktsent, December 25, 2025, January 29).
Putin invaded Ukraine because of an imperialist vision of a restored Great Russia. Until recently, he tried to reduce the element of ideology as far as Russians are concerned, lest he trigger the rise of a nationalist movement inside his country that he could not control (see EDM, March 22, 2022). Instead, he has sought to recruit soldiers by paying them rather than inspiring them with his vision (see EDM, June 27, July 29, August 7, October 24, 2024, May 14, November 5, 2025). As the war has ground on, however, his regime has introduced ever more ideological elements. The Kremlin is facing more difficulties in filling the ever-depleting ranks of its military and a rise in xenophobia among Russians toward migrant workers (see EDM, May 9, 15, 2024, November 18, 2025). Putin also fears that Ukraine's resistance is inspiring non-Russians within the Russian Federation and thus threatening his rule (Window on Eurasia, September 26, November 9, 2022, July 19, 2023). Non-Russians within the Russian Federation have certainly been affected by the war because Putin has recruited them disproportionately and deployed them in more dangerous positions (see EDM, April 4, 9, 16, 30, 2024, June 20, September 23, 2025). Kyiv's efforts to help non-Russians and what is happening in Ukraine have also changed the way many of them think (Window on Eurasia, August 12, 2022; see EDM, January 25, February 1, April 25, August 8, 2024, October 16, 2025). Putin's response has been repression, with most of the leaders of non-Russian nationalist groups now in jail or having emigrated, a situation that has obscured the power of such feelings but hardly reduced them.
If Moscow is holding its own in the non-Russian republics within the Russian Federation--at least as far as public demonstrations are concerned--it has been suffering repeated defeats in the independent countries that emerged in 1991. The list of their moves to distance themselves from Moscow since Putin launched his full-scale invasion of Ukraine is large and growing. For example, almost all independent countries that emerged following the collapse of the Soviet Union in 1991, other than Russia, have fully accepted the West's sanctions regime. Most have denounced the Kremlin's plan to change borders, two have left Kremlin-organized post-Soviet regional organizations, and hostility toward Russia and even the use of Russian has increased (see EDM, May 12, 2022, August 5, July 22, October 31, 2024). These changes reflect the views of post-Soviet peoples and their governments. Moscow has been worried because its loss of influence in these countries will reduce Russia's role in the world. The Kremlin has responded with ever more imperialistic bombast that frightens many far from Russian borders, but has a different effect on those next door.
Two new articles, one from Kazakhstan and another from the Russian Federation, call attention to this trend. The first article mentions developments in non-Russian countries, and the second article discusses developments inside of Russia. In the first, Serik Maleyev, the editor of Kazakhstan's Altyn-Orda portal, is explicit. He says that to compensate at home for its failure to achieve victory in Ukraine, Moscow propagandists, such as Aleksandr Dugin, have adopted increasing imperialist rhetoric about countries in the region. Maleyev argues that this effort is backfiring and is convincing these countries that the only way they can have a secure future is for Russia to suffer a crushing defeat and disintegrate further (Altyn-Orda, January 24; Region.Expert, January 30).
Dugin, the chief megaphone for this rhetoric, Maleyev continues, is not just some odious eccentric. Rather, his words about the former Soviet republics not having the right to exist except as Russian client states are "the concentrated expression of imperial revanchism, which long ago became part of the Russian propaganda mainstream." The Kazakhstan analyst adds that "the louder these imperial fantasies are sounded, the more obvious their compensatory character is." Additionally, residents of neighboring countries will see this language "not as an argument in favor of coming together but rather as a direct warning" and as a reason "to see Russia's total defeat not as something radical but sensible," particularly at a time when Russia is in what is so obviously a "weakened" condition (Altyn-Orda, January 24).
In the second article, the well-connected and influential Nezygar Russian Telegram channel argues that Moscow's increasingly Russian nationalist messaging is alienating non-Russians. It adds that "separatist sentiments in Russian regions have become a source of serious concern for the Kremlin and the security forces." "Internal sociological surveys" conducted for the Putin regime show these sentiments have not disappeared in their hidden form but instead have intensified (Telegram/@russicaRU January 20). Minval, an Azerbaijani outlet that has been tracing the decline of Russian influence among non-Russians both within the Russian Federation and across the former Soviet space, highlighted Nezygar's arguments (Minval, December 22, 2025, January 21, 30).
According to Nezygar, "closed studies record increases in alarming sentiments in the non-Russian republics." Residents there increasingly interpret war deaths "not as abstract losses but as threats to the very existence of their peoples." These perceptions are "fueled by alternative narratives" which "continue to circulate despite censorship." This does not mean, it says, that Russia is about to see "a repetition of 'the parade of sovereignties' of the 1990s." Moscow still has too tight control in regional capitals for that. Rather, Russia will see a period in which "regional elites will increasingly use the theme of autonomy as a bargaining tool." It continues, saying that "as socio-economic problems [of the country] intensify," demands for increased regional powers will grow--both from local elites and from the population. In the non-Russian republics, this demand is extremely likely to take the form of separatist sentiments." The channel concludes that a major reason for this is Moscow's "ideological shift toward Russian national patriotism" (Telegram/@russicaRU January 20).
The notion of a civic Russian identity "has been effectively replaced" over the last few years, the Telegram channel continues, by a more ethnic-Russian-centered nationalism that non-Russians are expected to accept. Nezygar argues:
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For national minorities, this rhetoric appears exclusionary and reinforces a sense of alienation. No attempt is being made to strike a balance between ethnic diversity and the dominant national narrative, which, in the medium term, only increases the risk of destabilization.
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That means the growth of separatism is "the most likely scenario" (Telegram/@russicaRU January 20).
Whether Putin will pull back from imperialist Russian nationalism and thus save Moscow's position and perhaps his own remains to be seen. The threats to him and Moscow both inside and beyond Russia's borders, however, are growing, and the time for him to do so may be running out.
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Paul Goble is a longtime specialist on ethnic and religious questions in Eurasia.
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Original text here: https://jamestown.org/kremlins-russian-nationalism-alienating-non-russians-at-home-and-abroad/
[Category: ThinkTank]
Ifo Institute: Business Climate in German Automotive Industry Improves Slightly
MUNICH, Germany, Feb. 4 -- ifo Institute issued the following news release:* * *
Business Climate in German Automotive Industry Improves Slightly
The business climate in Germany's automotive industry improved slightly in January to -19.6 points, up from -19.8 points* in December. While companies assessed their current business situation as worse, they are less pessimistic about the coming months. "Demand from the eurozone continues to act as a supporting force for the German automotive industry," says ifo industry expert Anita Wolfl.
Companies expect considerably better business abroad: Export ... Show Full Article MUNICH, Germany, Feb. 4 -- ifo Institute issued the following news release: * * * Business Climate in German Automotive Industry Improves Slightly The business climate in Germany's automotive industry improved slightly in January to -19.6 points, up from -19.8 points* in December. While companies assessed their current business situation as worse, they are less pessimistic about the coming months. "Demand from the eurozone continues to act as a supporting force for the German automotive industry," says ifo industry expert Anita Wolfl. Companies expect considerably better business abroad: Exportexpectations rose to +8.7 points, up from -8.0 points* in December. "Judging by the official data on incoming orders, intra-European trade is playing the driving role here," says Wolfl. On the foreign markets within the EU, companies in the German automotive industry also assess their competitive position as significantly better, with the balance rising from 1.5 points* in October to +15.4 points in January. By contrast, they assessed their competitive position on markets outside Europe as much worse once again: The balance fell to -31.3 points, down from -17.4 points in October. "The German automotive industry has lost competitiveness in markets outside the EU since 2024, as calculations based on official trade data show. This is especially the case with regard to China, but is also increasingly evident with regard to the US," says Wolfl.
*Seasonally adjusted
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More Information
Survey (https://www.ifo.de/en/facts/2026-02-04/business-climate-german-automotive-industry-improves-slightly)
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Original text here: https://www.ifo.de/en/press-release/2026-02-04/business-climate-german-automotive-industry-improves-slightly
[Category: ThinkTank]
Hudson Institute Posts Commentary to Arab News: Arctic Remains a Zone of Sustained Competition
WASHINGTON, Feb. 4 -- Hudson Institute, a research organization that says it promotes leadership for a secure, free and prosperous future, posted the following commentary on Feb. 2, 2026, to Arab News:* * *
The Arctic Remains a Zone of Sustained Competition
By Luke Coffey
US President Donald Trump's recent statements about the need to acquire Greenland caused considerable division within the transatlantic community. Fortunately, these tensions appear to have been resolved for now. One positive consequence of the Greenland debate, however, has been to elevate the strategic importance of the ... Show Full Article WASHINGTON, Feb. 4 -- Hudson Institute, a research organization that says it promotes leadership for a secure, free and prosperous future, posted the following commentary on Feb. 2, 2026, to Arab News: * * * The Arctic Remains a Zone of Sustained Competition By Luke Coffey US President Donald Trump's recent statements about the need to acquire Greenland caused considerable division within the transatlantic community. Fortunately, these tensions appear to have been resolved for now. One positive consequence of the Greenland debate, however, has been to elevate the strategic importance of theArctic region on the international agenda.
The Arctic region is home to some of the harshest terrain and environmental conditions on Earth. There are eight countries that can call themselves Arctic states: the US, Canada, Denmark via Greenland, Iceland, Norway, Sweden, Finland, and Russia. Many more countries are now seeking to expand their influence in the region.
The region is important for scientific, environmental, trade, transit, and energy reasons. Tourism has also been growing, boosting local economic activity. The region is widely believed to contain vast amounts of untapped oil and gas reserves, along with significant quantities of rare earth minerals. The challenge lies in finding ways to access and extract these resources that are both economically viable and environmentally responsible. This is made even more difficult by the lack of infrastructure and limited logistical connectivity.
The Arctic Council, an intergovernmental body led by the eight Arctic states, was established to promote cooperation on issues such as search and rescue coordination, environmental protection, and scientific research. However, the council has all but stopped functioning since Russia's invasion of Ukraine in 2022, severely limiting one of the few institutional mechanisms for Arctic-wide cooperation.
For the US, it is clear that the Trump administration views the Arctic primarily through the lens of great power competition. The US became an Arctic state in the 1860s with the purchase of Alaska from Russia. What was widely seen at the time as a mistake has since proven to be one of the most strategic decisions made in the post-Civil War era. Despite the rhetoric from multiple Washington administrations, however, relatively little emphasis has been placed on improving American capabilities or presence in the Arctic. For example, the US Coast Guard currently operates only one heavy icebreaker there.
So far in his first year in office, Trump has placed renewed focus on the region, including moving forward with a significant purchase of new icebreakers in cooperation with Finland. Even during the first Trump administration, the US role in the Arctic was framed largely in the context of great-power competition, particularly in relation to China. There is little reason to assume the second Trump administration will approach the region any differently.
Russia is the world's largest Arctic state, with roughly half the world's Arctic coastline located within the Russian Federation. For Moscow, the Arctic has long been a source of national pride and identity, dating back to the era of Peter the Great. After many Arctic bases and military facilities were shuttered at the end of the Cold War, President Vladimir Putin has invested heavily in reopening, modernizing, and expanding these installations. In recent years, Russia has also fielded specialized military units designed to operate in extreme Arctic conditions.
Moscow also views the Northern Sea Route, the shipping corridor between Europe and Asia that runs along its Arctic coastline, as both geopolitically and economically significant. Russia has invested substantially in infrastructure along this route in an effort to attract more commercial shipping between European and Asian markets. However, many of Russia's ambitious cargo-volume targets have not been met, and it remains unclear whether the route will become as commercially viable as Russian officials hope.
For China, the Arctic represents yet another region where Beijing seeks to expand its global influence. Although China is not an Arctic country, it has declared itself a "near-Arctic state," despite being roughly 1,200 km from the Arctic Circle at its closest point. Beijing has leveraged international institutions such as the Arctic Council to expand its presence in the region and has taken advantage of Russia's growing isolation from the West to deepen Arctic cooperation with Moscow, often in ways that disproportionately benefit China.
China has tried to pursue investments in key Arctic infrastructure projects, including some located in NATO members, and maintains a small, but strategically significant, scientific outpost in Norway's Svalbard archipelago. While China has not conducted overt military activity above the Arctic Circle, it has sent numerous scientific missions, research vessels, and icebreakers to the region -- assets that could serve dual civilian and military purposes. In the years ahead, China can be expected to seek an even greater role in the Arctic.
Meanwhile, it has not always been clear to Europeans, beyond those countries that are Arctic states, what role the rest of the Continent should play in the region. While the EU as an institution holds policy competencies over many issues that directly affect the Arctic, member states that are Arctic countries have largely kept decision-making at the national level. In fact, the EU has attempted multiple times to join the Arctic Council as an observer, only to be blocked.
In the wake of Trump's rhetoric over Greenland, however, Europe has begun to step up its engagement in the Arctic, a development that will be welcomed in Washington. From a security perspective, the accession of Finland and Sweden into NATO means that seven of the eight Arctic states now fall under the same security umbrella. For the first time, NATO itself has adopted a more direct and active role in the region.
Still, the future of Arctic cooperation hinges on the growing competition and divisions among the great powers. With relations between the West and China increasingly uncertain, and with the Arctic Council sharply reducing its activities due to the breakdown in relations between Russia and the other Arctic states, it is clear that the region will remain a zone of sustained competition. What must be avoided at all costs is allowing the Arctic to become the next theater of global conflict.
Read in Arab News (https://www.arabnews.com/node/2631298/amp).
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Luke Coffey is a senior fellow at Hudson Institute. His work at Hudson analyzes national security and foreign policy, with a focus on Europe, Eurasia, NATO, and transatlantic relations.
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Original text here: https://www.hudson.org/foreign-policy/arctic-remains-zone-sustained-competition-luke-coffey
[Category: ThinkTank]
CSIS Posts Commentary: Frontline - Technology Is a Modern Warfighting Domain
WASHINGTON, Feb. 4 -- The Center for Strategic and International Studies posted the following commentary on Feb. 2, 2026:* * *
The New Frontline: Technology Is a Modern Warfighting Domain
By Katrina Schweiker
The history of war is inextricably linked to science and technology, from the Stone Age to spears and crossbows through guns and tanks to space, nuclear, stealth, and cyber. Control of science and technology through national investments and the American creative drive for innovation has fueled U.S. hegemony for the past 80 years. China's increasing research and development investments ... Show Full Article WASHINGTON, Feb. 4 -- The Center for Strategic and International Studies posted the following commentary on Feb. 2, 2026: * * * The New Frontline: Technology Is a Modern Warfighting Domain By Katrina Schweiker The history of war is inextricably linked to science and technology, from the Stone Age to spears and crossbows through guns and tanks to space, nuclear, stealth, and cyber. Control of science and technology through national investments and the American creative drive for innovation has fueled U.S. hegemony for the past 80 years. China's increasing research and development investmentssince 2000 demonstrate the recognition of science and technology as a "key battleground" of modern war, essential for national power and power projection. Modern war requires the United States to establish science and technology as a warfighting domain or risk ceding key terrain in the next conflict.
The technology domain (Figure 1) shares some characteristics with other warfighting domains. Like cyberspace, technology is a man-made, global domain requiring continual human engagement. Similarly, just as the land domain presents maneuver forces with terrain that varies in operational importance over time, the technology domain presents scientists, engineers, acquirers, and warfighters with different opportunities that vary in operational and strategic importance over time. Activities in the technology domain are essential for freedom of action in air, space, and cyberspace and for enabling Joint All-Domain Operations. Like air superiority, technological superiority is constrained in time and space, requiring a maneuver approach to position technical forces in key physical and technological terrain to generate advantage across all warfighting domains and time.
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Figure 1: Schematic Illustration of a Portion of the Technology Domain
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Technology Maneuver
Technology maneuver treats individual emerging technologies like contested terrain, requiring speed to seize initiative, deception to misdirect adversaries, and constant repositioning to maintain advantage. As a framework, it provides a mechanism to mobilize all national resources with a shared understanding of both warfighting and homeland defense requirements. To successfully adapt technology at combat-relevant speeds, military technical forces that are embedded with operational units must maintain continuous connection with the nation's academic and industrial bases.
Maneuvering through the technology domain is the art of modern conflict, demonstrated by the war in Ukraine. As with other forms of maneuver warfare, time is a critical factor in technology maneuver. Time pressure requires the Ukrainian military to execute nondoctrinal solutions to build new warfighting capabilities. Frontline units have integrated research and development shops that adapt commercial technology to unit-specific tactical tasks and challenges, compressing innovation and adaptation cycles to weeks, days, and even hours. Tactical innovation did not replace the work of institutions, laboratories, or centralized procurement. Rather, small unmanned aerial systems (sUAS) and electronic warfare-enabled counter-UAS capabilities were of immediate importance at the tactical and operational levels, creating combat advantage to buy time for the strategically important, long-term investments in the production capacity for first-person view (FPV) drones, cruise missiles, and sUAS to occur.
Maneuver warfare is defined by actions and counteractions. In the war in Ukraine, Russia has executed several counteractions in the technology domain to which the Ukrainian military has then had to respond. In response to the rapid fielding of commercial drones by the Ukranian military, Russia deployed high-power, large-scale jammers, which then required Ukraine to innovate counter-counter-measures. The rapid industrial scaling to mass production of low-cost Shahed drones and development of fiber optic drones are other examples of technology maneuver that significantly affected all warfighting domains.
Technology maneuver lessons are not new. In World War I, Major General George Squier, commander of the Signal Corps and radio scientist, recognized that signal troops did not have the expertise required to run communications hubs. He recruited telephone operators from the United States who were technical experts in their craft, enabling faster dissemination of orders to Allies and freeing Signal Corps members to execute their mission closer to the front. Employing technical expertise for faster command and control was a huge success and marked a critical turning point for the Allies.
During World War II, Lieutenant Colonel Jimmy Doolittle, an innovative aviator and one of the first recipients of an aeronautical engineering doctorate from MIT, was tasked to plan an air raid on Japan. He used his technical and operational expertise to design the plans to modify the fuel tanks of the B-25 and build innovative training and tactics so modified planes could take off from a carrier.
In each of the examples described above, leaders relearned old lessons in the crucible of combat, as the realities of war necessitated tight coupling with technical and operational forces. How might the United States set conditions now to prepare all forces and the nation so that it does not have to rediscover these principles when the next conflict starts? Technology maneuver prepares U.S. technical forces (e.g., scientists, coders, and engineers) as combatants in an essential aspect of warfighting--technological adaptation.
A successful maneuver approach needs a military prepared to outlearn the adversary by employing combined arms teams connected to existing acquisition reform levers. Recent guidance to unify defense technology innovation efforts under a single chief technology officer is a step in the right direction. The undersecretary of war for research and engineering, who will serve as the department's chief technology officer, recently released a new list of critical technology areas. The list provides some focus by consolidating the previous administration's fourteen critical technology areas to six. However, the services often duplicate investments without always having a clear purpose for doing so. One way to deconflict research investments and maximize gains is for the undersecretary of war for research and engineering to appoint a lead service for each critical technology area, optimizing investments and decisionmaking authority. The lead service for each critical technology area should then design technology development campaigns that include identification of key technology terrain, associated military objectives, and mechanisms to achieve unity of effort across the development ecosystem of academia, industry, and federal research and development organizations.
Recently, acquisition was codified as a warfighting function, following Secretary of Defense Pete Hegseth's unveiling of the Warfighting Acquisition System. The acquisition system has traditionally focused on the strategic level of war, generating deterrence through the development and procurement of large, complex, advanced weapons systems (Figure 2). The recent guidance memorandum on transforming the defense innovation ecosystem is the first step in realizing a future where technology development is fluid, with iteration cycles closer to combat than bureaucracy. It directed moving the current ecosystem away from alignment to technology maturity, instead aligning to the three pillars the innovation ecosystem delivers: technology innovation, product innovation, and operational capability innovation.
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Figure 2: Technology and Capability Development Across Three Levels of War
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Recommendations for Implementing Acquisition as a Warfighting Function
Practical implementation of acquisition as a warfighting function requires recognizing technology as a key warfighting domain, operationalizing the lessons from history, and enabling technology maneuver as the doctrinal framework across all levels of war.
Tactical Warfighting in the Technology Domain
The new integrated innovation ecosystem designates the Defense Innovation Unit and Strategic Capabilities Office as field activities, along with the Defense Advanced Research Projects Agency, the Chief Digital and Artificial Intelligence Office, the Test Resource Management Center, and the Office of Strategic Capital. However, this construct does not sufficiently resource the tactical level of war in the technology domain. The services should establish technology reconnaissance detachments to pair technical forces with operational units. Technology maneuver elements at the tactical level must have clearly defined tactics, techniques, and procedures to enable frontline technology adaptation. The employment of technology combined arms teams should be institutionalized by continuing the integration of technical and operational forces in combatant commands and major exercises. The new integrated ecosystem and other defense experimentation units should link to operational units through these teams to demonstrate feasible entry points for new technologies.
The Air Force requires technology to access its primary warfighting domains and should therefore lead the way for the department by improving the integration of technical and operational forces across all levels of war. Technical officers and Futures Airmen should develop tactical adaptation experience early, empowered by the principle of decentralized initiatives to solve technological challenges at the point of need. A Technology Integrator Course should be established to produce Technology Integration Officers, who will serve as the Air Force's tactical experts in the technology domain and will be empowered as both frontline problem solvers and instructors in the art of technology maneuver.
Operational Warfighting in the Technology Domain
Critically, responsibility for executing the operational level of war in the technology domain must be defined. The technology centers in each service--the Air Force Research Laboratory, Office of Naval Research, or Army Research Laboratory--are best postured to serve as technology operations centers. Living at the nexus of past, present, and future, with relationships across academia, industry, and government, they are best postured to quarterback the information flow between tactical innovation and strategic procurement, consolidating gains at scale across the Joint Force.
Federal technology centers must continue to unapologetically imagine new futures and execute the discovery and technology development work required to bring them to fruition. Federal research and development de-risks future technology and product innovation through constant interactions across discovery, development, delivery, and adaptation. Improving feedback loops between the tactical and strategic levels of war is required to maneuver at speed.
Strategic Warfighting in the Technology Domain
Technologists across the nation--in academia, industry, and federal research centers--must incorporate modularity, adaptability, and learning fast by failing faster into their ethos.
Acquirers should fully integrate technical forces into systems integration and development programs to mitigate technical risk and deliver new capabilities at the speed required by tactical-level warfighters.
Conclusion
The United States excels at maneuver warfare because it is most closely aligned with the American military ethos, which has always prioritized initiative, adaptability, and innovation. It is time to bring this concept into the digital age by establishing technology as a warfighting domain and adopting a maneuver approach to win against the United States' adversaries. The United States' historic ability to mobilize national treasure and talent across academia, government, and industry toward a war-winning technological vision is its asymmetric advantage. The United States has ceded key technological terrain, but a maneuver approach can help take it back.
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Col. Katrina Schweiker is an active duty Air Force Officer. She is a 2025 military fellow with the Defense and Security Department at the Center for Strategic and International Studies in Washington, D.C.
The author would like to thank the Department of the Air Force Pathfinder program and members of Project Doolittle for their active support and engagement in the development of this concept and their thoughtful review of this article.
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Original text here: https://www.csis.org/analysis/new-frontline-technology-modern-warfighting-domain
[Category: ThinkTank]
CSIS Issues Commentary: Three Truths About the End of New START and What It Means for Strategic Competition
WASHINGTON, Feb. 4 -- The Center for Strategic and International Studies issued the following commentary on Feb. 2, 2026:* * *
Three Truths About the End of New START and What It Means for Strategic Competition
By Heather Williams
The 2010 New Strategic Arms Reduction Treaty (New START), the last remaining bilateral nuclear arms control agreement between the United States and Russia, expires February 5. Russian President Vladimir Putin has repeated an offer to informally continue to observe the treaty limits for an additional year. Barring a last-minute reprieve from President Donald Trump, ... Show Full Article WASHINGTON, Feb. 4 -- The Center for Strategic and International Studies issued the following commentary on Feb. 2, 2026: * * * Three Truths About the End of New START and What It Means for Strategic Competition By Heather Williams The 2010 New Strategic Arms Reduction Treaty (New START), the last remaining bilateral nuclear arms control agreement between the United States and Russia, expires February 5. Russian President Vladimir Putin has repeated an offer to informally continue to observe the treaty limits for an additional year. Barring a last-minute reprieve from President Donald Trump,the end of New START will be the end of an era for nuclear arms control.
Here's what the end of New START does and does not mean for strategic competition: The end of New START does not augur the start of an arms race. The end of New START does not mean the United States will automatically and massively build up its nuclear arsenal. And the end of New START does not equal the end of arms control; rather, this may be the beginning of a new era of arms control. Arms control must adapt to the moment. And this moment calls for diversifying and expanding the U.S. nuclear arsenal, paired with a new approach to arms control.
This Is Not an Arms Race--And If It Is, America Is Losing
The end of New START has prompted fears of a new arms race. Senator Ed Markey warned, "If the U.S. exceeds New START limits by uploading warheads, Russia will do the same, and China will use it as another excuse to build up their nuclear arsenal." The United States has shown exceptional restraint over the past decade in not expanding its arsenal and remaining committed to a modernization program since 2012. In a 2024 interview, the head of the New START delegation, Rose Gottemoeller, explained ongoing U.S. nuclear modernization as, "it's not about a buildup or a nuclear arms race--the modernization that we are undertaking. But it is about a replacement of obsolescent systems that are no longer safe to operate." But without the constraints of New START, these fears of an arms race have become more acute if the United States decides to build up, and Russia or China responds.
Arms racing is an action-reaction cycle, typically defined by an automaticity whereby one party builds up in direct response to an adversary's actions. During the Cold War, Hedley Bull described arms races as sustaining or exacerbating conflicts, as well as expressing them; however, "the idea that arms races obey a logic of their own and can only result in war, is false; and perhaps also dangerous." Some of the historic concerns about arms racing are that it can increase risks of misperception and accident, along with the financial costs. In the mid-1980s, for example, the Soviet Union was spending 15-17 percent of its GDP on defense. Whether or not we are in an arms race and whether or not arms races are "good" or "bad" remain hotly debated topics. Some experts argue that the arms race is already underway and point to Russian and Chinese nuclear buildups.
New data from both the Council on Strategic Risks and Federation of American Scientists provide insights about the quantitative and qualitative expansion of Russian and Chinese arsenals and can provide some insights into whether or not this is an arms race moment. Since New START was concluded in 2010, Russia has expanded its number of nuclear-capable systems by 22 percent on average, to include a 20 percent increase in the number of nuclear-armed submarines and submarine-launched ballistic missiles (SLBMs). China has engaged in an even more rapid buildup, such as by increasing the number of intermediate-range ballistic missiles by 635 percent and adding new types of strategic and nonstrategic delivery vehicles.
Conversely, as shown in Figure 1, the United States has not expanded anywhere near the scale of Russia and China since New START was concluded in 2010. Instead, U.S. nuclear capabilities have either stayed constant or gone down.
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Figure 1: Types of Systems Active
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This asymmetry can be seen across the board in nuclear platforms. There has been a 33 percent decrease in nonstrategic nuclear weapons platforms.
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Figure 2: NSNW Types Active
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Russia has increased its SLBMs by over 20 percent, while the United States decreased by 17 percent decrease in SLBMs since New START was finalized.
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Figure 3: SLBMs
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One of the most striking changes has been the 88 percent increase in China's intercontinental ballistic missile (ICBM) force, while the United States ICBM force actually decreased by 11 percent under New START.
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Figure 4: ICBMs
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What these figures show is that Russia and China have been significantly expanding their strategic arsenals despite restraint on the part of the United States. If this is a nuclear arms race, the United States is losing; and if it is not yet an arms race but turns into one, the United States is starting from behind.
The United States Does Not Need to Massively Build Up--It Needs to Diversify and Expand
Arms control is a product of its time. The New START agreement was concluded in 2010, following the 2009 U.S.-Russia "reset," President Obama's 2009 Prague speech calling for the "peace and security of a world without nuclear weapons," and an ambitious action plan for the 190 states in the Nuclear Non-Proliferation Treaty (NPT), to include additional arms control and risk reduction measures. At the time, a bilateral, verifiable arms control agreement was in the interests of both the United States and Russia. New START limits the United States and Russia to 1,550 deployed warheads on 700 deployed ICBMs, SLBMs, and heavy bombers. The treaty's verification measures include on-site inspections, data and telemetric information exchanges, and a semiannual Bilateral Consultative Commission.
Historically, arms control has been a tool for managing strategic competition, and it is essentially a bargain between the parties involved that, though they may continue to compete and seek strategic advantage, they will limit themselves in this specific, discrete domain. Bilateral strategic arms control is neither a political nor a legal requirement for the United States. As described by former Department of State official Tom Countryman, "Arms control agreements are not a concession made by the United States, nor a favor done for another nation; they are an essential component of, and contributor to, our national security." Arms control comes with strategic benefits of transparency and predictability into adversary arsenals, especially through on-site inspections, and also contributes to obligations under the 1968 NPT.
Since 2010, Russia has violated, suspended, or withdrawn from numerous important arms control agreements. A 2014 Department of State compliance report raised concerns about Russia's compliance with the 1987 Intermediate-Range Nuclear Forces (INF) Treaty. In 2022, Russia suspended inspection activities under New START, and in 2023, it suspended participation in New START and withdrew ratification of the Comprehensive Test Ban Treaty. Putin's offer to continue to observe New START limits did not include an offer to return to inspections or other transparency measures associated with the treaty. Despite its abysmal record with arms control and recent buildup in nonstrategic nuclear weapons, Russia faces practical challenges that mean it is unlikely to massively expand its strategic delivery vehicles.
What these trends all point toward is an increasing reliance on nuclear weapons by the United States' adversaries, particularly for regional ambitions to intimidate U.S. allies and partners and try to drive a wedge between them and Washington. In congressional testimony in March 2022, then-Commander of U.S. Strategic Command Charles Richard pointed to this specific concern: "It is not all strategic. There is a significant class of theater threats that we are going to have to rethink, potentially, how we deter that." Richard's successor, General Anthony Cotton emphasized that in Russia's case, nonstrategic weapons are not included under New START limits. Facing growing competition from nuclear-armed adversaries, the 2026 National Defense Strategy reasserts that the United States will "modernize and adapt our nuclear forces accordingly with focused attention on deterrence and escalation management amid the changing global nuclear landscape."
Until today, New START has restrained the United States' ability to adapt its strategic forces, but even with the treaty's end, the United States does not need a massive nuclear buildup. In his testimony, Richard said, "We do not necessarily have to match weapon for weapon.... But it is clear what we have today is the absolute minimum, and we are going to have to ask ourselves what additional capability, capacity, and posture we need to do, based on where the threat is going." What the United States needs now is a nuclear force posture that is more diverse and flexible to deter an increasing range of threats across multiple theaters, which may require expanding the U.S. nuclear arsenal, albeit "not radically, not monumentally."
With the end of New START, the United States can consider at least four options for how it might change its nuclear force posture to align with Richard's recommendations and develop a nuclear force that is more flexible. The first option would be to upload warheads to existing ICBM and SLBM platforms, which could "roughly double" the number of deployed warheads from New START numbers, according to former Deputy Assistant Secretary of Defense Kingston Reif. In the Project Atom 2025 study, Matthew Costlow makes the case for the second option: the United States should expand its procurement of systems that are "resilient, survivable, and forward-deployed (or deployable) in theater," such as a new stand-off weapon or dual-capable intermediate-range systems. A third option would be expanding existing plans for nuclear modernization, such as additional B-21s or Columbia-class submarines. A final option, of course, is to make no changes to plans for U.S. nuclear force posture and instead invest in conventional capabilities, although this would come with a significant risk of undermining assurance and allied proliferation.
How the United States Can Lead a New Era of Arms Control
This is not the end of arms control. In an interview for the CSIS Project on Nuclear Issues arms control oral history project, Gottemoeller pointed to this as a moment of opportunity for arms control: "It's very important the next treaty must be very much a Donald J. Trump treaty and Vladimir V. Putin treaty. It has to step into this new era that we are experiencing now with Trump in the lead." Bull described arms control as "spasmodic." It happens in waves, as evidenced throughout the history of the Cold War. Although this moment might signal a downturn in arms control as we know it, President Trump has repeatedly expressed an interest in a "denuclearization" agreement with Russia and China, which suggests a window of opportunity for new approaches to arms control.
What is to be done in this new era of arms control? As it considers how to respond to the pressures of the security environment and Russian and Chinese nuclear buildups, the Trump administration can pursue three simultaneous arms control priorities, some of them ambitious. First, Trump himself should play a role in leading future arms control initiatives. This could include a head-of-state-level trilateral meeting with Presidents Vladimir Putin and Xi Jinping, committing to a series of measures reducing the risks of nuclear use, such as hotlines, keeping a human in the loop in nuclear decisionmaking, and recommitting to the NPT. China has historically avoided any dialogue that hints at "arms control," but a head-of-state-level dialogue may tempt Xi. Trump's interest in new multilateral institutions, such as the Board of Peace, could be well-suited to nuclear diplomacy, such as establishing a Nuclear Risk Reduction Summit.
Second, while leaving the door open for dialogue with Moscow and Beijing, the Trump administration should also work with the international community to hold Russia and China accountable for their risky nuclear activities. Russia and China have expanded their nuclear arsenals with impunity. Both are suspected of conducting low-yield nuclear tests in violation of a testing moratorium. And Russia has consistently relied on nuclear threats throughout the war in Ukraine, with no accountability on the international stage. Key actors that claim to champion nuclear disarmament have refused to call out Russian behavior in the United Nations. South Africa, for example, abstained from four key resolutions on Ukraine, including one on the safety of the Zaporizhzhia Nuclear Power Plant.
Reducing the risks of nuclear weapons use is not only the responsibility of the United States, but of all nuclear possessors, and it is the responsibility of the wider international community to hold bad actors responsible. Until now, Russia and China have gotten a free pass. The United States can contribute to this accountability effort by sharing more data about Russian and Chinese nuclear buildups and behavior, combating disinformation about the U.S. nuclear posture, and actively participating in international forums such as the NPT.
And finally, the future of arms control requires the people and knowledge to seize opportunities when they arise. This new era of arms control requires new thinking, new ideas, and the creativity that the next generation of arms control leaders can bring. At the same time, the lessons learned from treaties like New START, particularly tacit knowledge, should not be lost. To be sure, the end of New START is a moment for reflection on all the treaty achieved and how the strategic landscape has changed since 2010; but it should also be a cue for new thinking on arms control and how it can work in tandem with deterrence in this era of strategic competition.
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Heather Williams is the director of the Project on Nuclear Issues and a senior fellow in the Defense and Security Department at the Center for Strategic and International Studies in Washington, D.C.
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Original text here: https://www.csis.org/analysis/three-truths-about-end-new-start-and-what-it-means-strategic-competition
[Category: ThinkTank]
American Action Forum Issues Commentary: HHS-OIG's Direct-To-Consumer Drug Sales Bulletin: A Preemptive Maneuver
WASHINGTON, Feb. 4 -- The American Action Forum issued the following commentary on Feb. 2, 2026:* * *
HHS-OIG's Direct-To-Consumer Drug Sales Bulletin: A Preemptive Maneuver
By Michael Baker
Executive Summary
* The Department of Health and Human Services' Office of the Inspector General released a Special Advisory Bulletin that attempts to clarify the criteria for direct-to-consumer (DTC) platforms to avoid violation of the federal anti-kickback statute.
* The issuance of this bulletin is notable because of the impending launch of TrumpRx, the Trump Administration's heavily pushed DTC ... Show Full Article WASHINGTON, Feb. 4 -- The American Action Forum issued the following commentary on Feb. 2, 2026: * * * HHS-OIG's Direct-To-Consumer Drug Sales Bulletin: A Preemptive Maneuver By Michael Baker Executive Summary * The Department of Health and Human Services' Office of the Inspector General released a Special Advisory Bulletin that attempts to clarify the criteria for direct-to-consumer (DTC) platforms to avoid violation of the federal anti-kickback statute. * The issuance of this bulletin is notable because of the impending launch of TrumpRx, the Trump Administration's heavily pushed DTCplatform, as well as the proliferation of company-specific DTC offerings.
* While neither a formal legal opinion nor an identification of wrongdoing, the bulletin clearly notes the risks associated with pushing DTC sales as an alternative to high prescription drug prices, furthering fragmentation in the U.S. health care system.
Introduction
Last week, the Department of Health and Human Services (HHS) and the HHS Office of the Inspector General (OIG) released a Special Advisory Bulletin describing the guardrails for when a pharmaceutical manufacturer's direct-to-consumer (DTC) sale of a prescription drug to a cash-paying patient - who may also be enrolled in Medicare, Medicaid, or another federal health care program - is "low risk" under the federal anti-kickback statute (AKS). It also calls for a Request for Information to inform any potential future rulemaking that may be needed to support continued adherence to fraud and abuse laws as they relate to DTC channels.
The guidance is meant to give manufacturers clearer compliance terrain to offer lower cash prices directly to patients, including federal program enrollees - particularly as the administration prepares to launch its much-touted TrumpRx DTC platform - without turning those discounts into unlawful "remuneration" intended to induce federally reimbursable business. In addition to the TrumpRx platform, a multitude of individual companies have launched their own DTC platforms (some independently and some under duress) that they are now advertising. This bulletin is less a speculative thought experiment than a waypoint in an already moving market.
The bulletin lands at a moment when the policy conversation on drug affordability is increasingly colliding with the mechanics of the U.S. pharmacy supply chain: List prices, rebates, patient cost-sharing, and the role of intermediaries all create incentives for patients to seek "outside the benefit" pathways when the benefit design (or point-of-sale price) feels unaffordable. While neither a formal legal opinion nor an identification of wrongdoing, the bulletin clearly notes the risks associated with pushing DTC sales as an alternative to high prescription drug prices and furthering fragmentation in the U.S. health care system.
What OIG Is Attempting to Clarify
Read plainly, the bulletin attempts to delineate one specific slice of the DTC universe: the sales transaction between a manufacturer and a cash-paying patient who happens to be a federal health care program enrollee. OIG repeatedly emphasizes that this is not a new safe harbor and not a blanket blessing; the anti-kickback statute is a criminal, intent-based law, and legality still turns on a case-by-case assessment of all relevant facts and circumstances.
Within that narrow transaction, OIG signals low AKS risk if (among other features) the DTC program is structured so that:
* No federal program is billed for the drug; patients are paying cash outside Medicare Part D / Medicaid;
* The discount is not a "hook" to induce purchase of other federally reimbursable products/services, and the DTC price is not conditioned on future purchases;
* The patient has a valid prescription from an independent third-party prescriber;
* The program excludes controlled substances; and
* The price is offered for at least one full plan year (a stability/anti-bait-and-switch concept).
OIG also flags two main anti-kickback concerns with manufacturer DTC sales to federal health care program enrollees. First, a manufacturer could use a discounted drug offer as a marketing incentive to steer the enrollee toward the manufacturer's other drugs, items, or services that may later be paid for by Medicare, Medicaid, or another federal program. Second, a manufacturer could use DTC pricing to start a patient on its drug with the expectation that the patient's federal coverage will eventually be billed for ongoing therapy once the drug becomes affordable under the benefit - an approach often described as "seeding."
Patient Costs, Access, and Quality Considerations
The clearest near-term promise of manufacturer DTC pricing is simple: For patients who face high cost-sharing at the pharmacy counter, a lower cash price can mean the difference between starting therapy and walking away. That's not a marginal issue. Abandonment is often driven by "first-fill sticker shock," especially for therapies with coinsurance tied to a high list price or for beneficiaries early in the year who are still working through deductibles. A well-designed DTC option can function as an immediate pressure valve - increasing access to medications and reducing out-of-pocket costs in the moment when patients are most likely to drop off.
But the same feature that makes DTC attractive - the fact that it is a cash purchase outside the insurance benefit - creates a second-order set of consequences that are less intuitive for patients. OIG's bulletin is explicit that when a federal health care program enrollee buys through a DTC arrangement structured so that no insurer is billed, that purchase generally does not count toward key benefit calculations. For Medicare Part D beneficiaries, for example, paying cash through DTC does not count toward "true out-of-pocket" or total Part D spending for program purposes. That matters because many beneficiaries rely on the mechanics of the benefit to reduce cost exposure over the course of a year. In practical terms, some patients may save money now but delay reaching the phases of coverage where cost sharing would otherwise drop. Others may end up toggling between channels - using DTC when the benefit is least favorable and returning to Part D when it becomes more protective - creating unpredictability in what the "best" option is at any given time.
That channel-switching risk feeds directly into access and quality. On one hand, DTC can expand access by offering an alternative route for patients who struggle with local pharmacy availability, face recurring inventory disruptions, or need more hands-on support navigating a specialty product. A manufacturer-directed fulfillment model can, at least in theory, reduce some friction: fewer handoffs, more standardized patient support, and clearer pricing at the point of sale.
On the other hand, moving purchases "off benefit" can widen informational blind spots. Claims data is not just a payment artifact; it is a core input for medication therapy management, drug utilization review, adherence interventions, and basic safety edits that rely on a complete record of what a patient is taking. OIG acknowledges this implicitly by stating it would be "prudent" for manufacturers to implement mechanisms to communicate DTC purchases to the beneficiary's plan to support utilization review and medication therapy management. Without that connectivity, DTC growth could mean more fragmented medication lists, more duplicative therapy, and more opportunities for contraindicated combinations - problems that disproportionately affect medically complex patients who are also the most likely to be enrolled in Medicare or Medicaid.
The upshot is that the "lower cash price" story is real, but incomplete. The policy question isn't just whether DTC can deliver point-of-sale affordability; it's whether the system can reconcile DTC's affordability benefits with the benefit-design mechanics and care-management infrastructure that federal programs use to protect patients over time. In the best-case scenario, DTC functions as a targeted alternative for patients who genuinely benefit from it, paired with data-sharing that preserves safety and coordination. Conversely, DTC may become a channel that helps some patients in the short run but increases confusion, weakens continuity of care, and complicates the patient's long-run affordability calculus - especially for those who need coverage to work predictably across the year.
Federal Program Costs: "Not Billed" Doesn't Mean "No Fiscal Impact"
OIG suggests it is not concerned about increased federal costs for the drugs purchased through these particular DTC programs when the guardrails are met, largely because the programs are structured so federal payers are not billed. In a narrow accounting sense, that's true: If a Medicare beneficiary (or Medicaid enrollee) pays cash through a manufacturer DTC channel and the transaction is structured so the federal program is not billed, then that particular fill does not generate a federal outlay. That is a meaningful distinction, and it helps explain why OIG is comfortable characterizing the simplest DTC-to-cash model as comparatively "low risk" under the anti-kickback statute.
But the real-world budget question is rarely confined to whether the program paid for a specific transaction; it's whether the arrangement changes behavior in ways that shift utilization, timing, and downstream spending. The guidance itself implicitly acknowledges that point by spotlighting the "seeding" risk - using a short-term, attractive cash price to initiate therapy with an expectation that coverage will eventually be tapped. Even if a DTC purchase is "off benefit" today, it can still act as a catalyst for a longer course of therapy that later migrates onto Medicare Part D or Medicaid once the patient is clinically stable, once the manufacturer adjusts pricing, once a plan's utilization management conditions change, or once a patient's financial capacity to stay cash-pay collapses. In that world, the DTC program doesn't eliminate public spending but it can re-sequence it.
There's also a quieter spillover channel: Even though the bulletin is framed as guidance for manufacturers, its real-world effect depends at least as much on beneficiary behavior as on corporate compliance. The "low-risk" model assumes that enrollees will knowingly choose a cash-pay DTC pathway, understand that it sits outside their plan benefit, and stick with it long enough for the manufacturer's pricing and process safeguards (such as year-long price stability) to matter. In practice, beneficiaries will be the ones deciding whether to bypass Part D or Medicaid billing, whether to toggle between channels when costs shift, and whether to disclose DTC fills to their plan or clinicians - choices that determine both program integrity risk and downstream costs. In that sense, the bulletin regulates manufacturers on paper, but it operationalizes through patient incentives and decision-making.
What happens when a discounted cash pathway begins to compete with the benefit pathway at the point of patient choice? If patients increasingly fill outside their coverage, the program loses claims visibility that underpins routine cost controls - utilization review, medication therapy management, adherence interventions, and even basic safety edits. That isn't just a clinical governance problem, it's a fiscal one. When plans and states can't "see" a drug until it reappears inside coverage, spending management becomes more reactive, less targeted, and potentially more expensive.
Finally, even if federal payers are not writing checks for DTC fills, they can still end up absorbing system-level costs created by fragmentation: extra administrative touches to reconcile medication histories, more avoidable adverse events tied to incomplete records, and shifting utilization patterns that complicate forecasting and benefit design. The near-term optics of "not billed" may look like savings, but the longer-run fiscal footprint depends on whether DTC becomes a stable alternative channel - or a transitional on-ramp that ultimately feeds back into publicly financed coverage with less transparency and weaker guardrails.
In other words, the guidance may reduce one category of AKS risk while increasing the importance of benefit-integrated guardrails that the bulletin does not (yet) regulate.
Supply Chains: Shifting the Center of Gravity From Pharmacies to Manufacturers
If DTC programs scale beyond the handful that have been announced - or TrumpRx really takes off - the most immediate supply-chain effect is a quiet reallocation of "where the work happens." Volume that would ordinarily flow through retail pharmacies (and, upstream, through the conventional wholesaler-to-pharmacy cadence) could shift toward manufacturer-directed specialty channels, contracted fulfillment partners, and direct-to-patient logistics networks. Even when manufacturers don't literally ship the product themselves, they can become the de facto orchestrator of inventory positioning, cold-chain controls, patient communications, and refill timing. Over time, that changes incentives for pharmacies' stocking behavior and can alter wholesalers' demand forecasting, because the signal traditionally generated by pharmacy purchasing and claims activity becomes less central for certain products and patient cohorts. All these shifts may yet have impacts on the federal health programs the AKS intends to protect.
A more technical concern involves how the "discount" is operationalized in a way that still uses existing dispensing infrastructure. OIG's bulletin notes that some DTC models may rely on a buy-down mechanism - often framed as a coupon or similar instrument - so that the patient receives the lower DTC price at the pharmacy counter even though the transaction remains cash-pay. That sounds simple, but it introduces a separate set of supply-chain and compliance questions about who is paid, when, and for what service. OIG is explicit that the bulletin is not opining on remuneration flowing to pharmacies (or other intermediaries), which effectively means the most operationally important part of scaling these programs - integrating them into real-world dispensing - sits in an area where enforcement sensitivity remains high. The result is that distribution partners may demand tighter contractual protections, audit rights, and claims-like documentation, all of which can increase friction and reduce the "directness" that DTC models promise.
Widespread DTC also creates the risk of operational fragmentation: parallel pathways for access to the same product, each with different pricing logic, fulfillment steps, and patient instructions. A patient might obtain a drug through their plan benefit one month, then through a DTC cash channel the next, depending on deductible status, formulary changes, or short-term affordability shocks. From a supply-chain perspective, that means duplicative enrollment workflows, duplicative customer service and troubleshooting, and a higher likelihood of discontinuities when shipments, authorizations, or refills do not synchronize. Unless manufacturers and plans build durable data-sharing and coordination processes, the system can trade one set of distribution "middlemen" for another kind of complexity - less visible, but still very real in the form of reconciliation work, exception handling, and continuity-of-therapy failures.
Conclusion
The practical bottom line is that this announcement can plausibly reassure some pharmaceutical manufacturers that DTC channels offer lower prices for some patients in the near term. But it also creates a new set of incentives that, without careful integration into benefit design and medication safety workflows, could trade price relief for coverage confusion, weaker care management, and a more bifurcated pharmaceutical distribution system - with federal programs absorbing the downstream complexity even when they aren't paying the initial bill
It's further notable that OIG paired the bulletin with a formal Request for Information asking whether safe harbors or beneficiary-inducement exceptions should be modified for emerging manufacturer DTC models, including those tied to TrumpRx, and explicitly inviting comment on pharmacy and telemedicine arrangements around DTC programs. That sequencing matters: Today's bulletin gives a compliance "green light" for the simplest transaction. Tomorrow's fight - over steering, prescriber alignment, pharmacy compensation, marketing, and platform economics - is where the AKS risk (and the real patient-and-supply-chain consequences) will concentrate.
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Michael Baker is the Director of Health Care Policy at the American Action Forum
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Original text here: https://www.americanactionforum.org/insight/hhs-oigs-direct-to-consumer-drug-sales-bulletin-a-preemptive-maneuver/
[Category: Think Tank]