The Centers for Medicare and Medicaid Services (CMS) recently released the
Contract Year 2027 Medicare Advantage and Part D Proposed Rule (CMS-4212-P), outlining several changes aimed at modernizing the Medicare Advantage (MA) program and fostering marketplace competition. In addition to the Inflation Reduction Act (IRA) mandated Part D changes, key proposals include significant adjustments to Star Ratings measures, recission of certain marketing restrictions, new special enrollment period when a beneficiary’s key provider (s) is no longer in-network, and three Requests for Information (RFIs) including one focused on duals, to assess how C-SNP and I-SNP enrollment trends may affect state integration efforts.
Proposed Star Ratings Changes
CMS plans to shift from process-focused measures to outcome measures that deliver greater beneficiary value. It also proposes removing12 administrative performance measures, noting that these measures have shown consistently high performance. Additionally, CMS proposes adding a new measure for Depression Screening and Follow-Up starting in CY 2027.
Marketing and Agent/Broker Changes
CMS has also proposed removing several marketing-related and agent broker requirements for MA plans, including:
- The 48-hour waiting period between completing a Scope of Appointment (SOA) and holding a personal marketing appointment.
- The 12-hour gap between an educational event and a marketing event at the same location, provided attendees can opt out.
- The explicit prohibition on superlatives such as “best” or “most” in marketing materials, as long as the materials are not misleading.
- The requirement that third party marketing organizations (TPMOs) that do not sell all plans in a service area to read the disclaimer within the first minute of a call instead requiring it be read before discussing benefits; removes state health insurance assistance programs as an information source.
Requests for Information
CMS seeks feedback on modernizing MA risk adjustment and quality bonus payments; improving integration of Medicare-Medicaid benefits for dually eligible SNP enrollees, spurred by the growth in the number of duals in C-SNPs in particular but also in I-SNPs; and advancing well-being through tools and incentives that support emotional health, social connection, preventive care, and nutrition. The rule also contains proposed changes to certain D-SNP policies and well as feedback on additional MA policies such as network adequacy, medical loss ratio, etc.
More information on the rule
is available for AHCA/NCAL members.
Please note a member log-in and password are required to access this resource. The CMS
press release and
fact sheet are also available.
AHCA/NCAL will be submitting comments by the January 26, 2026, deadline. Please reach out to
Nisha Hammel, VP of Reimbursement Policy & Population Health, and Population Health Policy Analyst
Rohini Achal with any questions.