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CBO鈥檚 New Baseline Signals Shifting Cost and Risk Dynamics in Medicaid and Medicare

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On February 11, 2026, the Congressional Budget Office (CBO) released  report. The publication, which represents the first time CBO has released Medicare and Medicaid spending baseline projections since , reflects the impact of the 2025 Budget Reconciliation Act (P.L. 119-21, OBBBA), recent changes to Medicare reimbursement for skin substitute products, and the latest Medicare Part D and Medicare Advantage bids.

CBO鈥檚 baseline serves many functions, including serving as the official 鈥渟corekeeping鈥 benchmark used for cost estimates of proposed legislation under consideration in Congress.

Changes to CBO鈥檚 Medicaid Baseline

CBO decreased its projections of 2026鈥2035  by approximately $514 million from its January 2025 baseline update. The main driver of that reduction is the impact of the Medicaid provisions in the 2025 Budget Reconciliation Act, which CBO expects will reduce total Medicaid enrollment by 13.1 million people in 2035. The drop in Medicaid spending from the OBBBA-related enrollment reductions was partially offset by technical changes CBO made to the Medicaid baseline.

Medicaid costs per enrollee grew by 16 percent in 2025, which was more than CBO had anticipated. The agency attributes the cost per enrollee growth to a reported decrease in the average health status of Medicaid enrollees following the end of the COVID-era continuous eligibility policy.

CBO anticipates that payment rates for Medicaid managed care plans will begin to rise in 2026 because of this decrease in the average health status of enrollees, and the agency has updated the Medicaid baseline accordingly (see Figure 1).

Source: 量子资源网 analysis of CBO鈥檚  and F reports.

Changes to CBO鈥檚 Medicare Baseline

Compared with its January 2025 baseline, CBO increased its projections of  by about $1 trillion (roughly $942 billion, by 量子资源网 (量子资源网) calculations). The main driver of that increase came from CBO鈥檚 updates to its Medicare Part D spending projections, which were increased to reflect higher than expected 2026 bids from private insurance plans that administer the Part D benefit. According to their 2026 bids, Part D plans anticipate a 35 percent increase in their annual per enrollee costs in 2026鈥攁 trend that CBO was not expecting and . Part D spending per beneficiary in 2035 is now projected to exceed $4,000, up from less than $3,000 in the January 2025 baseline (See Figure 2).

The agency鈥檚 Medicare Part A fee-for-service (FFS) spending projection increase was the result of larger than expected increases in 2025 enrollment and per enrollee spending. Those trends were also seen in Medicare Part B FFS but were partially offset by the Centers for Medicare & Medicaid Services鈥檚 (CMS) recent reimbursement changes to skin substitute products. Overall, CBO estimates that the skin substitute reform issued in CMS鈥檚  and  final rules will save $245 billion over the 2026鈥2035 period, including the effects on the Medicare Advantage (MA) program (see Figure 3).

Finally, CBO reduced its spending projections for MA compared to the January 2025 baseline. This change was made to reflect lower-than-expected Medicare Advantage enrollment in 2025, although the spending implications of lower enrollment were partially offset by higher-than-expected bids in 2026 by providers of MA plans (see Figure 4).

Source: 量子资源网 analysis of CBO鈥檚  and  reports.
Source: 量子资源网 analysis of CBO鈥檚  and  reports.
Source: 量子资源网 analysis of CBO鈥檚  and  reports

Contact an 量子资源网 Expert Today

Interested in understanding how CBO鈥檚 latest baseline update affects the federal budgetary implications of certain Medicare or Medicaid policy topics or proposals? Contact our experts, Mark Desmaris and Rachel Matthews, to learn more about 量子资源网鈥檚 鈥淐BO-style鈥 federal budgetary scoring work, which relies on The Moran Company鈥檚 long-standing methodology. [1]

Beyond federal budget scoring, 量子资源网 is working with states, health plans, and providers to assess how changes in enrollee health status are affecting utilization, costs, and payment rates鈥攁nd what those trends may mean for Medicaid and MA organizations and providers. Our teams support states in evaluating managed care rate setting and program design, help Medicaid and MA plans anticipate risk and bid implications, and assist providers in understanding how changes in patient acuity could affect care delivery, contracting, and financial performance.

[1]Specifically, we apply our understanding of CBO precedents to predict how CBO will likely evaluate the budgetary impact of the legislation in question. We use our best judgment to adopt the assumptions CBO would tend to use, with the understanding that any variance in the assumptions CBO ultimately adopts could cause our estimate to differ from theirs.

Tending the Embers: Staying Ready for Medicare Advantage RADV Audits

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The Centers for Medicare & Medicaid Services (CMS)鈥痠ssued a memo January 27, 2026, with updates on the agency鈥檚 approach to checking whether Medicare Advantage (MA) plans are being paid correctly. These reviews are conducted through which help CMS confirm that the diagnoses MA plans report are supported by medical records. 

The January 2026 memo signals that CMS intends to honor its commitment to strengthen oversight of MA payments, including accelerating and expanding the use of RADV audits and using AI (artificial intelligence) to streamline human coding reviews. MA organizations must now prepare to respond to the RADV audit notice within the required five-month window, while balancing their other risk-adjustment programs. 

In this article, we explain the rapidly evolving landscape affecting RADV audits. Wakely, an 量子资源网 company, addresses what these changes mean for MA organizations and key considerations to ensure they are prepared for the upcoming enhancements to federal program integrity initiatives. 

Overview of CMS鈥 RADV Refresh 

CMS  a major shift in May 2025: All MA plans will undergo RADV audits鈥攏ot just a small sample as before. These audits look for cases in which diagnosis information submitted by a plan does not match the documentation in the patient鈥檚 medical record. When this happens, CMS may decide the plan was overpaid and require repayment. Historically, CMS audits have identified widespread diagnosis-code documentation errors, resulting in significant revenue recoupment from MA plans. 

The 2025 announcement creates a framework for additional risk for MA plans, which could shift to risk-bearing provider groups. As we explained in an , key components of that announcement include: 

  • All MA plans will be audited starting听with听Payment Year听(PY)听2018.听
  • CMS committed to accelerating audits by听adding more staff and using听new听technology.听
  • CMS听planned to听use 鈥渆xtrapolation鈥濃攎eaning听if errors were found in a small sample of records, the error rate could be applied to the full population, which could lead to much larger repayment amounts.听
  • CMS also planned to听eliminate听the fee-for-service听(FFS)听adjuster鈥攁听policy that previously helped reduce the amount a plan would have to repay. This听proposal听would increase financial risk for plans.听

Both the use of extrapolation and the removal of the FFS adjuster were later challenged in court. 

Legal Challenge 

In September 2023, Humana  CMS in federal court, arguing that the 2023 RADV final rule, which allowed extrapolation and removed the FFS adjuster, was put into place without following proper federal rulemaking procedures. On September 25, 2025, the court agreed with Humana and vacated certain parts of this final rule, meaning certain parts of the rule are no longer in effect. 

CMS appealed the ruling on November 1, 2025, which has created uncertainty about how RADV audits will work in future years. 

Navigating the Legal and Regulatory Changes in Early 2026 

The court did not say that extrapolation or elimination of the FFS adjuster is illegal鈥攐nly that CMS did not follow the required process for changing the rules. Hence, the 2023 RADV final rule cannot take effect unless CMS wins its appeal or reissues the policy using the proper steps. 

In its January 2026 Health Plan Management System (HPMS) memo, CMS stated that it will comply with the order while it is in effect. 

The pending litigation does not diminish CMS鈥檚 broader commitment to increased audit activity and heightened scrutiny of MA risk-adjustment practices. 

Effect of the Ruling. During RADV audits, CMS selects a sample of enrollees and requests corresponding medical records from the MA plan. These records are reviewed to confirm that the documented diagnoses meet CMS requirements. If unsupported diagnoses are found, CMS may recalculate payments and recover overpayments from the health plan. This audit process maintains program integrity and ensures accurate payments. 

Plans that submit incomplete records could owe significant repayments to CMS. 

CMS鈥檚 January 2026 memo clarifies how the agency plans to roll out additional RADV audits starting with PY 2020. CMS also addresses the agency鈥檚 plans to:  

  • Reduce burden on plans and providers,听for example by extending the submission window听听
  • Balance the volume of medical record submissions needing review听by using smaller sample sizes听where appropriate听
  • Use AI听to further accelerate the review process听

Preparing for What鈥檚 Next 

Given CMS鈥檚 stated direction and the still unsettled litigation environment, MA plans should remain vigilant and audit ready.

Key steps include: 

  • Prioritizing听timely听and complete chart submission processes听
  • Strengthening internal criteria to听identify听and听prioritize听charts most likely to support diagnoses听
  • Improving documentation and coding accuracy through provider engagement听
  • Conducting proactive self鈥慳udits to听identify听potential vulnerabilities听
  • Partnering with expert RADV consultants to navigate audit strategy, documentation, and submission readiness听

Connect with Us 

Wakely assists plans with their RADV initiatives and development of robust RADV playbooks. For more information about Wakely鈥檚 RADV playbooks, contact . 

Congress Advances FY 2026 HHS Appropriations Bill with Health Extenders and PBM Reforms

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On February 3, 2026, Congress finalized federal funding for fiscal year (FY) 2026, with the House passing the Consolidated Appropriations Act (CAA), 2026, with a vote of 217-214, following Senate approval last week. The president signed the CAA () shortly thereafter. The law provides full-year appropriations for the Departments of Health and Human Services (HHS), Housing and Urban Development, Labor, and several other departments. 

This year鈥檚 HHS funding bill is notable not only for what it includes, but also for what it omits. It restores or maintains funding for key public health and research agencies previously proposed for elimination in the president鈥檚 FY 2026 , extends several healthcare programs, and contains a significant package of pharmacy benefit manager (PBM) reforms. All of this activity comes as the Administration  new grant programs and policy efforts related to its signature priorities. 

In this article, we review the major funding and policies approved in the HHS spending bill. We also address key considerations for healthcare organizations as they anticipate downstream funding and policy developments and develop advocacy initiatives for federal FY 2027 bills. 

HHS Funding Levels and Direction 

The bill provides $116.8 billion for HHS, an increase of $210 million over FY 2025, and rejects large-scale structural reorganizations proposed in the president鈥檚 FY 2026 budget. This provision preserves funding for the Agency for Healthcare Research and Quality (AHRQ), Centers for Disease Control and Prevention (CDC), Health Resources & Services Administration (HRSA), and the Substance Abuse and Mental Health Services Administration (SAMHSA) 

Table 1. HHS Agency Funding Highlights, FY 2026 

Agency  FY 2026 Funding  (+/-) Compared with FY 2025 
Administration for Strategic Preparedness and Response (ASPR) $3.7 billion +$58 million  
CDC $9.2 billion level funding 
Centers for Medicare & Medicaid Services (CMS), administrative expenses only  $3.7 billion level funding  
 HRSA $8.9 billion +$415 million  
National Institutes of Health (NIH) $48.7 billion  +$929 million  
SAMHSA $7.4 billion  +$65 million  

The bill also extends mandatory funding for community health centers, special diabetes programs, the National Health Service Corps, and Teaching Health Center Graduate Medical Education. 

PBM Reforms in the Package 

In one closely watched area of federal policymaking, the FY 2026 package includes a substantial set of PBM-related reforms that largely mirror the bipartisan package negotiated but not enacted in December 2024. These reforms have implications across Medicare Part D, commercial insurance, and employer-sponsored plans. 

The legislation contains the following PBM reforms: 

  • Prohibits PBMs from deriving听remuneration听linked to drug prices for听Medicare-covered Part D drugs听
  • Restricts spread pricing in Medicaid,听eliminating听a major driver of PBM revenue听
  • Requires contractual transparency, mandating that PBMs clearly define pricing terms in agreements with Part D plan sponsors听
  • Adds new PBM reporting obligations, including drug price reporting and rebate disclosures听
  • Requires 100听percent听passthrough of rebates in ERISA-regulated plans for new, renewed, or extended contracts beginning听30 months听after enactment听
  • Expands audit rights for plan sponsors听
  • Codifies the 鈥渁ny willing pharmacy鈥 requirement for Medicare plan sponsors听

These provisions position 2026 as a consequential year for PBM regulation, increasing transparency, strengthening plan leverage, and heightening HHS oversight. 

Healthcare Extenders and Program Reauthorizations 

The bill includes a broad set of Medicaid, Medicare, and public health program extenders, affecting providers, patients, states, and managed care plans. 

Medicaid 

  • Postpones reductions听in the听Disproportionate Share Hospital (DSH)听allotments听until FY 2028听
  • Changes听the听DSH cap calculation听to听broaden which patient costs count toward Medicaid shortfall听
  • Requires states to听develop and implement a process to听allow certain out-of-state pediatric providers to deliver services without听additional听screening for three years听
  • Removes age limits on Medicaid鈥檚 Ticket to Work program, allowing adults older than age听65 to听participate听and requires state compliance by January 1, 2028听
  • Establishes new maternity care reporting requirements听for rural hospitals, with dedicated federal funding听for hospitals听and states to听comply with听the reporting听

Medicare 

Congress extends several key programs and payment provisions, including: 

  • Telehealth flexibilities through December 31, 2027听
  • Incentive payments for participation in eligible alternative payment models through payment year 2028 (for performance year 2026) and applies an adjustment amount of 3.1 percent for 2028听
  • Acute Hospital Care at Home waivers through 2030听
  • Low-volume and Medicare-dependent hospital payment adjustments听
  • The听1.0 work geographic practice cost index floor used in the calculation of payments under the Medicare physician fee schedule through December 31, 2026听
  • Add-on payments for ambulance services听
  • Continuation of Part D coverage for certain antivirals and modifications to hospice payment caps听

Behavioral Health Policy 

The appropriations bill听was听finalized听as the听administration听听new funding and policy initiatives听to听support behavioral health, crisis services, workforce expansion, and youth mental health鈥攅fforts mirrored in SAMHSA鈥檚 increased appropriations.听

SAMHSA鈥檚 $7.4 billion budget includes: 

  • $1.6 billion听for State Opioid Response grants听
  • $1.01 billion听for the Mental Health Block Grant听
  • $535 million for the 988 Suicide and Crisis Lifeline听

Considerations for Stakeholders 

Federal funding and policy developments affect state budget dynamics as many states are now releasing 2026鈥2027 budget proposals as well as the operational and growth plans of healthcare organizations and partners. 

A few key takeaways from the FY 2026 funding bill include: 

  • Federal appropriations signal听congressional and听administration priorities and have听downstream听impact on upcoming rounds of grant cycles, including听SAMSHA and HRSA听awards.听
  • The approved funding and certain policy extensions provide operational stability and reduce near-term fiscal pressure, such as the further delay of Medicaid DSH cuts. The extra time will allow healthcare entities to prepare for future reductions and plan for financial sustainability.听
  • Agency and program funding emphasize oversight, program integrity, and听compliance. In addition,听fraud and program integrity听priorities are听woven into听certain听new听policies听and program听extensions,听including听PBM reforms, flexibility for pediatric care across state borders,听and rural maternity cost reporting requirements,听among others.听

Connect with Us 

If you would like deeper analysis or state and stakeholder-specific effects, 量子资源网鈥檚 policy experts are available to assist. 

2026 Marketplace Open Enrollment: Where the Numbers Currently Stand

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On January 28, 2026, the Centers for Medicaid & Medicare Services (CMS) posted a detailing 2026 Open Enrollment (OE) results. Although this report is neither a complete nor final picture of 2026 Marketplace enrollment activity, it is likely to be the last OE data CMS publishes for some time. A comparison of 2026 and 2025 Open Enrollment results can be found in Table 1.

Table 1. Comparison of 2026 and 2025 Open Enrollment

20262025Net Change
Total22,973,21924,166,491(1,193,272)
New Consumers3,382,1893,938,907(556,718)
Returning Consumers19,591,03020,227,584(636,554)

A summary of our analysis on these 2026 OE results and how they compare with 2025 data can be found below. This analysis builds on the findings in Wakely鈥檚 from January 2026.

  • Overall, topline plan selections are down from last year. Total enrollment decreased by 5%, with new enrollment down 14% and renewals down 3%.
  • State-based marketplace (SBM) enrollment declined modestly, but the data are as of January 10, and many SBMs are continuing to enroll people through the end of January.
    • New Mexico plan selections increased by 14% over last year, the largest increase of any state, driven by state-funded subsidies mirroring the expired enhanced premium tax credits (ePTCs).
    • Georgia plan selections decreased by 14%, the largest SBM year-over-year decline.
  • The federally facilitated marketplace (FFM) experienced an overall decrease of 5%. FFM data are as of January 15 and therefore measures plan selections after the OE period has ended. Within the FFM, state-by-state results varied significantly.
    • Texas led all FFM states with a 5% increase, whereas Ohio and North Carolina experienced 20% and 22% decreases in enrollment, respectively.
    • Some of this variation is surprising and not readily explainable from the available data and will be a focus of future 量子资源网 and Wakely analyses.
  • The data include neither effectuated enrollment nor paid enrollment鈥攄ata which will be key to fully understanding 2026 enrollment trends and the impact of changing federal policies, including the ePTC expiration and changing eligibility standards introduced in 2026 as the result of P.L. 119-21 (OBBBA).
    • from SBMs suggest significantly higher rates of cancellations and disenrollments than in previous years.
    • SBMs are also sharing that they expect high rates of affordability-driven voluntary and non-payment terminations throughout the first half of 2026.
    • Monitoring paid enrollments, attrition, and grace period dynamics, including retro-terminations, will be key to understanding market dynamics and 2027 pricing.

量子资源网 and Wakley experts have considerable experience working with states, insurers, and federal policymakers with jurisdiction over the Marketplace. We work with these entities to inform, analyze, and influence federal policies and conduct impact analyses on pricing, enrollment, administration, and operations. 量子资源网 also provides strategic and project management support for the implementation of finalized policies.

Please contact Taylor Gehrke at [email protected], Michael Cohen at [email protected], or Zachary Sherman at [email protected] with questions, follow-up, or if you would like expert assistance exploring any of the issues discussed in this post.

Related Resources:

CMS ACCESS Model: A New On-Ramp to Outcomes-Based, Tech-Enabled Care in Traditional Medicare

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The Centers for Medicare & Medicaid Services (CMS) Innovation Center recently published applications for its new  (Advancing Chronic Care with Effective, Scalable Solutions), a 10-year voluntary initiative beginning July 2026. The model is designed to advance outcomes-based, technology-enabled care delivery in Original Medicare and aligns with the Innovation Center鈥檚 priorities of strengthening prevention, empowering beneficiaries, and promoting performance-based competition. ACCESS is particularly suited to organizations with mature clinical operations and data infrastructure, offering a new pathway for tech-supported services. 

This article summarizes the model鈥檚 design, highlights key considerations for prospective applicants, and addresses common questions our Medicare and technology experts fielded during a recent Health Management Associates (量子资源网)/Leavitt Partners webinar

What the ACCESS Model Is Testing 

ACCESS evaluates whether Outcome-Aligned Payments (OAPs)鈥攔ecurring payments contingent on measurable clinical improvement鈥攃an reduce spending while maintaining or improving quality for beneficiaries with chronic conditions. The model tests whether incentivizing technology supported care can produce reliable clinical outcomes while complementing traditional care delivery. 

Who may participate? Organizations must be Medicare Part B鈥揺nrolled providers or suppliers (excluding DMEPOS [Durable Medical Equipment, Prosthetics, Orthotics, and Supplies] and labs). Participants may enroll beneficiaries directly, operate across multiple clinical tracks, and manage all qualifying conditions within each selected track. Beneficiary participation is voluntary, and individuals may switch ACCESS participants every 90 days. 

Clinical tracks. At launch, the four clinical tracks reflect high-prevalence chronic conditions with established care pathways and strong evidence for technology-supported interventions: 

  • Early Cardio-Kidney-Metabolic (eCKM)听
  • Cardio-Kidney-Metabolic (CKM)听
  • Musculoskeletal (MSK)听
  • Behavioral Health (BH)听

Payment. OAPs vary by track and performance period. CMS pays a portion prospectively each quarter and withholds 50 percent pending reconciliation based on: 

  • Clinical outcomes attainment: The percentage of aligned beneficiaries who complete the 12鈥憁onth performance period and achieve track鈥憇pecific clinical targets relative to their baseline.听
  • Substitute鈥憇pend test: Ensures beneficiaries do not receive duplicative听fee-for-service (FFS)听services for conditions managed under ACCESS.听

Technology and data exchange. ACCESS takes a tech-forward approach. Key expectations include use of Fast Healthcare Interoperability Resources (FHIR庐) based Application Programming Interfaces (APIs)鈥痜or eligibility, consent, claims sharing, and care coordination鈥攑art of the broader federal push to modernize the health data ecosystem. CMS also plans to publish a public directory that lists participants, tracks, cost-sharing policies, and risk-adjusted outcomes to enable consumer and clinician choice. 

Regulatory coordination. To complement ACCESS and expand the pipeline of technology-supported interventions, the US Food and Drug Administration鈥檚 (FDA)  (Technology-Enabled Meaningful Patient Outcomes)  allows selected US-based digital health device manufacturers to participate while generating real-world evidence. Up to 40 device manufacturers may participate across clinical areas. 

This coordinated CMSFDA effort is intended to reduce barriers to innovation and accelerate access to safe, effective digital tools that can support chronic disease management. 

Key Considerations for Applicants 

Program integrity and fraud/abuse. CMS has emphasized program integrity across Medicare and Medicaid, and ACCESS reflects that emphasis. Applicants and their parent organizations should expect rigorous screening. Participants must also operationalize controls to pass the substitute spend test and maintain auditable evidence of outcomes and beneficiary consent. 

Overlap with Accountable Care Organizations (ACOs) and other models. Patients may participate in ACCESS and be aligned with an ACO simultaneously; however, 鈥減articipant overlap鈥 raises important operational and financial issues. ACCESS includes an FFS exclusion policy that prohibits participants or affiliated entities from billing Medicare FFS for any services delivered to the same beneficiaries for the duration of their ACCESS episode. As a result, traditional providers, ACO-aligned clinicians, and integrated delivery systems must assess whether they can segment patient populations or if partnering is more feasible. 

Eligibility and clinical scope. ACCESS is focused on relatively stable, chronically ill beneficiaries and excludes those with more acute/severe conditions. Participants must accept responsibility for all qualifying conditions a beneficiary has within a track. 

翱耻迟肠辞尘别蝉听辫别谤蹿辞谤尘补苍肠别.听The听ACCESS Model places substantial听emphasis on clinical听performance听and care coordination. Participants听are paid in full only if enough patients hit outcomes targets.听Early cohorts will听likely skew听toward organizations with mature clinical protocols, robust engagement models, and demonstrated outcomes.听Applicants should听be听financially听prepared听to听tolerate withholds, beneficiary switching, and听follow-on听period payment reductions after year one.听

Digital infrastructure and interoperability. ACCESS presumes API-driven data exchange, including consent capture, eligibility checks, claims/clinical data integration, and bidirectional information sharing with the patient鈥檚 broader care team. Applicants should ensure they have a FHIR API server and meet the requirements described in the CMS .

Go-to-market and referral strategy. Beneficiary alignment is voluntary and will be facilitated by CMS鈥檚 planned public directory with risk-adjusted outcomes. Access participants will benefit from strong referral relationships鈥攅specially with ACOs and primary care providers鈥攂oth to enroll eligible beneficiaries and to minimize substitute services. A field strategy grounded in evidence, patient engagement, and interoperability with local providers is critical to success. 

Connect with Us 

 for the first ACCESS Model performance period are due April 1, 2026, with model launch in July 2026; applications submitted later would start January 1, 2027. Because ACCESS is a rolling, decade-long model, some organizations may choose to stage entry. 

ACCESS is the most explicit Innovation Center opportunity to date on outcomes-based, tech-enabled chronic care in Traditional Medicare. It offers digital health and advanced care organizations a direct line to FFS beneficiaries with payment tied to results, not activities. Success will favor teams that combine clinical excellence, consumer-grade engagement, and API-level interoperability, as well as manage program integrity, ACO overlap, and beneficiary churn. 

For questions or support assessing readiness, developing an application, or operationalizing the model, contact Amy Bassano, , or Kate de Lisle

CMS Releases 2027 Advance Notice with Medicare Advantage and Part D Rates

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The Centers for Medicare & Medicaid Services (CMS) released the  on January 26, 2026. The Advance Notice begins CMS鈥檚 annual rate-setting cycle and describes proposed updates to Medicare Advantage (MA) growth rates, benchmark rebasing, risk adjustment, Star Ratings, and Part D payment parameters. CMS previously released a鈥痠n November 2025 that included policy changes to the Star Ratings system and enrollment policies for MA and Part D starting in contract year 2027. (Read the 量子资源网 (量子资源网) summary here.) 

Comments on听the Advance Notice are due February 25, 2026, and听CMS will publish the final CY 2027 rate announcement no later than April 6, 2026.听听

This article provides an early look at the proposed methodological updates and draft capitation rates. Wakely, an 量子资源网 Company, will publish a detailed analysis of the Advance Notice in early February. 

Payment Impact on Medicare Advantage Organizations 

CMS estimates a national per capita MA growth rate of 5.10 percent from 2026 to 2027, with fee-for-service (FFS) non-end-stage renal disease (non-ESRD) growth of 5.10 percent and FFS dialysis end-stage renal disease (ESRD) growth of 6.17 percent. 

The听5.10听percent growth rate reflects projected increases in per听capita听FFS听Medicare spending for beneficiaries who are听aged/have听disabilities听and serves as the primary driver of 2027 benchmark updates, interacting with rebasing and risk adjustment changes to听determine听final capitation payments.听The growth rate听reflects听updates听to听how CMS pays for skin substitutes听in the 2026 Medicare Physician听Fee听Schedule. These updates resulted in significantly lower projected costs听and materially reduced听the growth听rate.听

These preliminary estimates inform the development of MA benchmarks and may change in the final rate announcement.听

Table 1. Estimated Impact of Proposed Payment Changes on Medicare Advantage Plan Payments, CY 2027 

听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 听 Year-to-Year Percentage Change
Impact  CY 2027 Advance Notice  
Effective Growth Rate4.97%
Rebasing/Re-pricingTBD
Change in Star Ratings-0.03%
MA Coding Pattern Adjustment0%
Risk Model Revision and Normalization-3.32%
Sources of Diagnoses-1.53%
Expected Average Change0.09%
SourceCenters for Medicare & Medicaid Services. 2027 Medicare Advantage and Part D Advance Notice. January 26, 2026. Available at: https://www.cms.gov/newsroom/fact-sheets/2027-medicare-advantage-part-d-advance-notice. 

Medicare Advantage Benchmarks, Rebasing, and Risk Adjustment 

The Advance Notice describes CMS鈥檚 approach and changes that will affect payment to plans, including: 

  • Excluding from the risk adjustment process diagnoses submitted from chart reviews with unlinked claim records. In the Fact Sheet, CMS estimates this change will reduce Part C payments by 1.53 percent.听
  • Rebasing听county听FFS听rates for 2027 using 2020鈥2024 claims data, continuing听CMS鈥檚听practice of updating benchmarks annually to reflect the most current FFS experience. The Advance Notice also reiterates the statutory framework for calculating benchmarks, including applicable and specified amounts, benchmark caps, and quality bonus payments.听
  • Updating听the CMS Hierarchical Condition Category (CMS-HCC) and Prescription Drug Hierarchical Condition Category (RxHCC) risk adjustment models and associated normalization factors for CY 2027 and听continuing听to apply the statutory MA coding pattern difference adjustment to account for systematic differences in diagnosis coding between MA and FFS.听

Quality Bonus Payments, Star Ratings, and Part D Updates 

CMS states that contracts with 4 or more Stars receive a 5 percentage-point quality bonus, while new and low-enrollment contracts receive a 3.5percentage-point bonus. The Advance Notice also includes updates related to Part C and Part D Star Ratings measures and methodological refinements. 

For Part D, CMS outlines proposed updates to the defined standard benefit parameters for CY 2027, as well as changes to Part D risk adjustment, normalization, premium stabilization, reinsurance, and risk-sharing, with additional policy context provided in the Contract Year 2027 Medicare Advantage and Part D proposed rule. 

Connect with Us 

The CY 2027 Advance Notice provides early signals on benchmark growth, rebasing, and payment methodology changes that will shape MA and Part D payments听in听2027. Stakeholders should begin evaluating the potential implications for bid development, benefit design, and financial performance as CMS moves toward听finalizing听rates in April.听

量子资源网 supports Medicare Advantage and Part D stakeholders with payment impact modeling, scenario analysis, and strategic advisory services related to benchmark rebasing, risk adjustment, Star Ratings, and Part D payment policy to help organizations prepare for the CY 2027 rate announcement. 

For details about the finalized payment and policy rules,听contact our featured experts,鈥 and听.听

Preparing for Change: A Look at Proposed State Fiscal 2027 Budgets

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As of January 1, 2026, nine governors had released proposed budgets for state fiscal year (SFY) 2027. With the phase down of federal funding and substantial policy changes approved in the 2025 budget reconciliation act (P.L. 119-21, OBBBA), these proposals offer insights into how governors plan to manage mounting fiscal pressures, navigate new federal mandates, and position their programs for long-term sustainability. 

Today, 量子资源网 Information Services (量子资源网IS) published its first preliminary review of proposed SFY 2027 budget proposals. The initial installment includes budgets from Alaska, Colorado, Florida, Mississippi, New Mexico, South Dakota, Utah, Virginia, and Wyoming, with the latter two proposals covering the fiscal 2026鈥28 biennium. 

量子资源网IS will release periodic updates as additional governors publish their budget proposals鈥攖he same rolling approach we used in 2025 (here and here). Because 15 states enacted 2025鈥27 biennial budgets last year, 量子资源网IS also might review substantial mid-biennium health-related adjustments or supplemental funding. 

The remainder of this article provides a snapshot of several notable themes and emerging trends detailed in the full report. 

Implementation of New Federal Requirements 

State leaders are preparing budgets for SFY 2027 at a time of heightened fiscal stress and structural uncertainty. Entering 2026, governors are facing reductions in federal funding, particularly in Medicaid and Supplemental Nutrition Assistance Program (SNAP) funding. In addition, they are preparing for new federal requirements that will begin to take effect later this year, including narrower flexibilities for financing and Medicaid community engagement policies and more frequent eligibility redeterminations. 

Against this backdrop, governors are using FY 2027 budget proposals to comply with OBBBA鈥檚 mandates and to stabilize their safety net programs and realign state operations around stricter fiscal realities. 

Medicaid Work Requirements. Virginia鈥檚 proposed budget includes funding to implement federal Medicaid community engagement requirements, including a recommendation to add nine new authorized positions in SFY 2027 and 12 more in fiscal year 2028 to meet workload demands. In addition, South Dakota鈥檚 governor proposed amending the state鈥檚 2026 budget to secure funding to implement these requirements. 

Eligibility and Redetermination. Several governors are proposing investments to support heightened eligibility checks across Medicaid, SNAP, and Temporary Assistance for Needy Families (TANF). For example, Colorado Gov. Jared Polis鈥檚 budget proposes $19.1 million to improve the state鈥檚 eligibility system for programs such as Medicaid, SNAP, and TANF. Utah鈥檚 proposed budget includes a recommended allocation of nearly $16.5 million to the Department of Workforce Services for 鈥淗.R. 1 Medicaid Eligibility Administration,鈥 and nearly $10 million for the 鈥淗.R. 1 SNAP Administrative Services.鈥 

SNAP ChangesStates are backfilling lost federal funding and investing in error reduction and system modernization. New Mexico Gov. Michelle Lujan Grisham鈥檚 proposed budget, for example, includes $37 million to replace the decrease in federal funding for SNAP administration ($4 million of which will support 150 new full-time positions), as well as $8.9 million for systems improvements to reduce payment errors in SNAP. South Dakota Gov. Larry Rhoden鈥檚 proposed budget includes $5.5 million to offset a reduction in SNAP federal funding. 

Strategic Cost Containment 

Considering OBBBA implementation and the effects that it will have on their budgets, our first review of governors鈥 budget proposals signals that states are taking an aggressive posture toward limiting expenditure growth in 2026 and 2027. Initial proposals include targeted reductions, tighter utilization management, and restrictions on benefits. 

Since the 2025 legislative session, Colorado has taken multiple steps to prepare for declining federal revenue. For example, Governor Polis鈥檚 proposed budget accounts for multiple actions approved through an amended executive order that would reduce spending to brace for OBBBA鈥檚 impacts. Examples include: 

  • Reducing provider rates to 85 percent of the Medicare reimbursement rate听
  • Establishing limits on Community First Choice services听
  • Adjusting听the听home health nursing and therapy services payment听methodology听
  • Introducing cost controls for Medicaid benefit categories that have shown disproportionate growth听
  • Implementing听a听$3,000 annual cap on adult Medicaid dental benefits听and a听$750 annual cap on dental benefits for individuals in the Cover All Coloradans program听
  • Changing听the听Cover All Coloradans behavioral health program from managed care to fee for service听
  • Reviewing provider fees听in anticipation of听possible State听Directed Payment approval from the Centers for Medicare & Medicaid Services (CMS)听

Former Virginia Gov. Glenn Youngkin鈥檚 budget鈥攏ow inherited by Abilgail Spanberger following her inauguration January 17, 2026鈥攊ncludes multiple cost-containment proposals, such as: 

  • Anticipated adjustments to capitation rates after a review of Medicaid managed care organizations听
  • A $2,000 annual limit on adult dental services Medicaid coverage听
  • Elimination of听both听automatic rate increases for psychiatric residential treatment facilities and qualifying听addiction听and recovery treatment services providers听and听automatic biennial inflation increases for听medical听assistance听providers听
  • Restrictions on听emergency听maternity services to Medicaid听enrollees听who听are ineligible听for Medicaid听because听of their citizenship status听
  • Standardized听hourly limits across home and community-based听services听waivers听
  • Actions听related to听鈥渆nsuring appropriate utilization鈥 of services,听such as听applied听behavioral听analysis and crisis services听

States are expected to include additional cost-containment tools throughout 2026 and beyond as OBBBA鈥檚 fiscal effects become clearer over the coming months and years. 

What to Watch 

The budget proposals indicate the resources that executive agencies need and preview governors鈥 policy agendas for the year ahead. Stakeholders should track program reductions and rate changes, eligibility system investments, and shifts in care models. 

In addition, some of the announced budget proposals consider federal awards to states under the Rural Health Transformation Program (RHTP). For example, the Alaska Department of Health budget request addresses the state鈥檚 RHTP implementation plans, and Wyoming鈥檚 budget proposal outlines RHTP priorities. Many states are preparing RFP processes to operationalize their RHTP strategies and make progress on the goals of their initiatives. 

Connect with Us 

As federal funding uncertainties continue, states and other stakeholders will need to adapt their delivery systems, administrative structures, and financing models throughout OBBBA鈥檚 multiyear rollout. 量子资源网 offers expertise, analytics, and strategic advisory services needed to navigate this evolving landscape. For details contact Andrea Maresca and Kathleen Nolan

The full state of the states and governor budget report is available to 量子资源网IS subscribers. In addition, 量子资源网IS maintains a  that incorporates details of each initiative and the first year award.  

Outlook 2026: Rural Health Transformation Program

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As we kick off the new year,听量子资源网听(量子资源网)听is launching a new series of brief,听insightful听interviews听with our policy experts听on issues听that will define听2026鈥攚hat鈥檚 changing, why it matters, and how federal, state, and industry decisions will shape what happens next.听Building on听our earlier analysis of听the Rural Health Transformation Program听((RHTP),听here听and听here), this week, we听start听with a听pointed听look at听the Centers for Medicare & Medicaid听Services鈥檚听(CMS)听first year of RHTP awards.听

Rural Health, Ready or Not: CMS Wants Results in 2026

An interview with Kathleen Nolan, Senior Advisor, 量子资源网, and , Principal, Leavitt Partners, an 量子资源网 Company. 

Q: What do the new Rural Health Transformation Program awards tell us about US Department of Health and Human Services (HHS) and CMS priorities heading into 2026? 

Kathleen Nolan: One of the clearest signals is that CMS expects visible progress in 2026. This is not a program that gives states months of planning runway. The application made it clear that CMS wants states to start doing the activities they proposed right away鈥攏ot just planning or propping up existing systems. CMS wants to see meaningful movement on implementation in 2026, especially in the areas of workforce, infrastructure, technology modernization, and care delivery redesign. 

Sara Singleton: Exactly, and CMS is using this investment to reinforce some of the administration鈥檚 broader policy goals. Many state proposals leaned heavily into chronic disease prevention, chronic care management, and expanding supports that promote healthier lifestyles. That alignment isn鈥檛 accidental. The Administration is looking for real traction on these priorities, and RHTP gives states both the resources and the accountability framework to make progress. So, the message from CMS is clear: Move quickly, implement strategically, and show early gains in the areas that matter for long-term population health. 

Q: Was anything in the awards themselves surprising? 

Singleton: There was a lot of speculation about how wide the spread in funding levels might be, particularly for states鈥 discretionary initiatives. But the distribution was relatively tight; 32 states fell in the 鈥渁verage鈥 range of $190鈥$230 million, with only four states above $230 million and 13 below $190 million. That suggests CMS isn鈥檛 signaling dramatic differences in expected performance or ambition. 

Nolan: It reinforces that CMS is looking for consistent, measurable progress from every state. States that struggle to implement their plans could see less funding in about years. 

Q: What should states keep top of mind heading into year one? 

Nolan: Accountability. CMS has made it clear they will adjust budgets in later years if states don鈥檛 meet expectations on reporting and evaluation. That also means states need to know where the dollars are going and what they are getting for the investment. Year one performance really matters. 

Singleton: And it鈥檚 not just CMS. Congress and the Office of Inspector General for HHS will also be watching how states use these funds. 

Q: What rural health policy developments are you watching in early 2026? 

Nolan: Decisions about the leadership for these initiatives and state legislatures. Federal investment can only go so far. States will need strong leaders and supportive policies to accelerate and sustain RHTP efforts in year one. What legislatures choose to prioritize will shape the impact of RHTP far beyond year one. 

Executive Branch Actions Target Drug Affordability in New Pricing Models

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The federal drug pricing landscape continues to undergo significant transformation as executive branch agencies advance an ambitious suite of regulatory and model testing initiatives intended to lower the costs associated with the Medicare and Medicaid programs. In response to ongoing concerns about rising out-of-pocket costs, increasing pressure to align US prices with those paid internationally, and the continued implementation of the Inflation Reduction Act (IRA), federal agencies are reshaping how prescription drugs are priced, reimbursed, and negotiated in federally financed programs. 

The current policy environment reflects a growing emphasis on benchmarking drug prices to those in peer nations, referred to as 鈥渕ost favored nation鈥 (MFN) benchmarks, and accelerating actions that require or encourage manufacturers to offer lower net prices. 量子资源网 (量子资源网), is tracking these developments in the public payer space, replicating Centers for Medicare & Medicaid Services (CMS) payment methodologies, and modeling alternative policies to assist life science companies, payers, and other stakeholders. 

In this article, we review the administration鈥檚 recent efforts to reduce Medicare and Medicaid spending on drugs and biologics, including confidential manufacturer negotiations and three new models that together could reshape pricing dynamics across federal programs. 

Executive Branch Negotiations Seek to Drive Access to MFN Discounts 

In 2025, the administration issued an  directing federal agencies to pursue strategies to establish MFN pricing, linking US prices for certain drugs to the lowest (or second lowest) adjusted net prices among a targeted set of peer countries. Following the order, federal officials sent  to 17 major pharmaceutical and biotechnology manufacturers, urging them to negotiate agreements that would voluntarily align prices with MFN-based benchmarks. 

To date, 14 manufacturers have signed , though full details remain confidential. These agreements are understood to accomplish the following: 

  • Provide听state听Medicaid听programs with听access to听MFNbased听discounts听
  • Require that new drugs be launched in the United听States听at听MFNaligned听prices听
  • Offer certain drugs at discounted听directtoconsumer听prices through a forthcoming 鈥淭rumpRx鈥 program, expected to launch later this year听

Reports suggest that manufacturers entering these MFN-related arrangements may receive exemptions from several federal actions, including the Center for Medicare and Medicaid Innovation (Innovation Center) demonstration models described below and certain tariff-related policies. 

MFNLinked Models Designed to Lower Drug Costs Across Medicare and Medicaid 

Along with the negotiation efforts, the CMS Innovation Center has proposed three models that would test MFNbased pricing through structured rebate mechanisms. Each model targets different segments of the market while testing how international benchmarks could be integrated into federal drug payment policy. 

New Models Test Alternatives to Inflation Rebates 

Announced in December 2025, the  and the  are designed to test alternative approaches to the Inflation Reduction Act鈥檚 (IRA)  policies. CMS plans to test the models鈥 potential for market driven price reductions if manufacturers choose to lower list prices instead of paying MFN-based rebates. 

Key features of the GLOBE Model are as follows: 

  • Applies听to听25 percent of听Medicare听fee-for-service听(FFS)听beneficiaries听using certain听Part B drugs听
  • Beginning in October 2026,听becomes听mandatory听for select drugs and targets听highspending,听physicianadministered听Part B categories, excluding products already subject to IRA听negotiations, generics, biosimilars, and certain听lowspend听products听
  • No changes to听physician and hospital听reimbursement,听although beneficiaries听expected to听see reduced cost sharing听

The GUARD Model will similarly test whether applying MFN-based rebates to Medicare Part D drugs will lower Medicare costs. Key aspects of this model include: 

  • Fiveyear听model听that would start听January 1, 2027听
  • Target听therapeutic categories with more than $69 million in annual Part D spending听
  • No impact on听plan bids and beneficiary cost sharing听

These models rely on pricing data from 19 countries. Manufacturers that voluntarily submit net price information would trigger quarterly benchmark updates; otherwise, CMS will use a fixed list price based benchmark for the entire pilot period. 

CMS is seeking  on whether additional categories, for example cell and gene therapies, should be excluded from GLOBE. GUARD is also open for  through February 23, 2026. 

GENErating cost Reductions fOr US Medicaid (GENEROUS) Model 

The , expected to begin in 2026, creates a voluntary pathway for state Medicaid programs and manufacturers to enter supplemental rebate agreements tied to MFNaligned prices. MFN pricing under this model is based on the second lowest net price in G7 countries plus Denmark and Switzerland. GENEROUS is also expected to align with pricing commitments negotiated through the administration鈥檚 manufacturer agreements. 

Key Considerations and Potential Impacts 

The combined effect of federal negotiations and Innovation Center models could be substantial, though outcomes will depend on manufacturer participation, benchmark stability, and operational feasibility. Key considerations include: 

  • State听Medicaid savings, especially听the extent to which听MFN鈥憀inked rebates exceed existing supplemental rebates听
  • Reduced Medicare beneficiary cost sharing for Part B included in GLOBE听
  • Shifts in manufacturer pricing strategies, including potential changes to US launch prices听
  • Interactions with the IRA, particularly Part D redesign and Part B inflation penalties听

Connect with Us 

量子资源网 experts continue to track the federal drug pricing landscape closely as comments, operational details, and implementation timelines evolve across these initiatives. Our team replicates CMS payment methodologies and models alternative policies using the most current Medicare FFS and Medicare Advantage (100%) claims data. 

For more information听and听questions about the policies described听in this article, please contact听our experts below.

Webinar Replay – The ACCESS Model: Essentials for Applicants

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This webinar was held on January 22, 2026.

CMS鈥檚 new ACCESS model represents one of the most ambitious federal efforts to modernize chronic care through technology-supported services. This national, voluntary, decade-long model creates a new payment pathway for digital health tools, continuous monitoring, behavioral support, and other tech-enabled interventions that complement traditional care. With beneficiaries able to enroll directly and clinicians eligible for co-management payments, ACCESS introduces a fundamentally different approach to chronic condition management across Medicare.

During this webinar, 量子资源网 and Leavitt Partners experts broke down what is known today, what to expect in the forthcoming Request for Applications, and what organizations can do to prepare. We walked through the model鈥檚 four clinical tracks, outcomes-aligned payments, beneficiary engagement expectations, the TEMPO pilot鈥檚 implications for digital device manufacturers, and how it relates to the CMS Health Tech Ecosystem initiative.

Learning Objectives:

  • Understand the ACCESS model鈥檚 goals, structure, and clinical tracks.
  • Recognize participant and beneficiary requirements, payment approaches, and data expectations.
  • Better understand how the ACCESS and ELEVATE models relate to the CMS-aligned network commitments
  • Identify key steps to prepare for the upcoming RFA and assess organizational readiness.

CMS Innovation Center鈥檚 ACCESS Model: What Medicare Organizations Need to Know

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On December 1, 2025, the Centers for Medicare & Medicaid Services (CMS) Innovation Center announced its latest model鈥 (Advancing Chronic Care with Effective, Scalable Solutions). A national, voluntary 10-year model designed to test outcomes-focused payment for technology-enabled care used in managing chronic conditions common among Original Medicare (fee-for-service) beneficiaries, ACCESS addresses the long-standing gap between Medicare鈥檚 payment system and technology鈥檚 capacity to improve healthcare delivery. 

The digital health technology and provider communities have expressed considerable interest in ACCESS. The US Department of Health and Human Services (HHS) and CMS highlighted the model at the December 4, 2025, Modernizing America鈥檚 Care for the Better event (recording here), noting over 250 organizations have already expressed interest in the model. Nonetheless, many details need clarification before the program launches.  

量子资源网 (量子资源网) has reviewed the ACCESS model and is engaging with those agencies and organizations working on design and implementation. In this article, we share early insights and considerations for Medicare organizations and technology manufacturers interested in participating, as well as potential implications for the broader market. 

Model Overview 

ACCESS aligns with the administration鈥檚 strategic priorities for the Innovation Center, including: 

  • Incentivize greater use of听technology听in听chronic听disease prevention and management听
  • Increase access to听tech-enabled care听by overcoming听payment听barriers, while ensuring care is clinician-guided, coordinated, and accountable听
  • Expand听clinicians鈥櫶齛bility to offer innovative care through听a听straightforward payment pathway听
  • Promote competition by publishing risk-adjusted performance results听
  • Reduce overall Medicare costs听

Core Requirements for ACCESS Participants 

Participants in the model (ACCESS care organizations) must be Medicare Part B participating providers or suppliers, exclusive of durable medical equipment, prosthetics, orthotics, and laboratory suppliers. Notably, these organizations must designate a Medicare-enrolled medical director to oversee care quality and compliance. These organizations will collaborate with primary care providers and other referring clinicians to offer tech-enabled services that complement traditional care, including: 

  • Telehealth software听
  • Wearable devices for continuous monitoring (e.g., sleep, heart rate, movement, glucose, etc.)听
  • Apps听to听track and coach lifestyle changes听

Care may be delivered in person, virtually, asynchronously, or through other clinically appropriate tech-enabled methods. 

While CMS has yet to release full details on covered digital health solutions, ACCESS care organizations are expected to offer integrated, technology-supported care, which may include: 

  • Clinician consultations听
  • Lifestyle and behavioral support (e.g., nutrition, exercise, smoking cessation)听
  • Therapy and counseling听
  • Patient education听
  • Care coordination听
  • Medication management听
  • Ordering and interpreting diagnostic tests and imaging听
  • Use or听monitoring听of Food and Drug Administration听(FDA)-authorized devices听

ACCESS is intended to be a supplemental approach to traditional care. Primary care physicians and specialists will be able to refer patients to ACCESS organizations and will receive regular electronic updates on patient progress. 

New Options for Beneficiaries 

Unlike most other Innovation Center models, beneficiaries will be able to voluntarily sign up directly with an ACCESS organization or receive a referral from a physician. CMS will maintain a public directory of ACCESS participants, including the conditions they treat and their risk-adjusted outcomes, to help providers and beneficiaries make informed choices based on their needs. 

 Chronic Condition Focused Clinical Tracks 

ACCESS will launch with four clinical tracks, grouping related conditions with similar care approaches. Although CMS may add additional tracks and conditions in the future, the first four tracks address common chronic conditions among Medicare beneficiaries (affecting over two-thirds of Medicare beneficiaries). 

  1. Early Cardio-Kidney-Metabolic (eCKM):听Hypertension, dyslipidemia, obesity, prediabetes
    Outcome measures:听Control听of听or improvement in听blood pressure听(BP), lipids, weight, HbA1c听
  2. Cardio-Kidney-Metabolic (CKM):听Diabetes,听chronic kidney disease听(CKD),听atherosclerotic听cardiovascular听disease听(ASCVD)听
  3. Outcome measures:听Control or improvement in BP, lipids, weight, HbA1c; CKD/diabetes require eGFR听(estimated听glomerular听filtration听rate)听and UACR听(urine听albumin-to-creatinine听ratio)听data submission听
  4. Musculoskeletal (MSK):听Chronic pain
    Outcome measures:听Improvement in pain intensity, interference, function (via validated听patient-reported听outcome听measures听[PROMs])听
  5. Behavioral Health:听Depression and/or anxiety
    Outcome measures:听Improvement in symptoms (Patient Health Questionnaire-9听[PHQ-9],听Generalized听Anxiety听Disorder-7听[GAD-7]);听submission of听World Health Organization Disability Assessment Schedule 2.0听(WHODAS 2.0)听for overall function听

Participant organizations must manage all qualifying conditions within their chosen track. 

Payments 

CMS will release more details in the forthcoming request for applications (RFA). The model will use two payment approaches: 

  • Outcomes-Aligned Payments (OAPs):听Paid to ACCESS organizations听that听achieve听desired clinical outcomes, support technology-enabled interventions,听and net savings for Medicare. OAPs are expected to be听recurring听(likely听monthly) payments
  • Co-management听Payments:听Referring clinicians will receive approximately $30 per service, plus a one-time $10 bonus, for onboarding beneficiaries

To promote access in underserved areas, CMS will apply a fixed adjustment to OAPs for rural patients in qualifying tracks. 

FDA鈥檚 Complementary TEMPO Pilot 

罢丑别&苍产蝉辫;贵顿础鈥檚&苍产蝉辫; (TEMPO) pilot will work collaboratively with the ACCESS model. Manufacturers of digital health devices that have yet to receive FDA authorization can apply to TEMPO for enforcement discretion, allowing their devices to be used by ACCESS participants for covered care. The FDA is seeking statements of interest for participation in the TEMPO pilot beginning in January 2026. The agency plans to select up to 10 manufacturers in each of four specific clinical use areas to participate in the pilot. 

Next Steps 

Interested applicants should begin exploring participation as a Medicare Part B-enrolled provider if they have yet to enroll. Other key considerations for Medicare organizations include: 

  • 听a nonbinding letter of interest to听the Innovation Center听
  • Evaluate readiness to deliver technology-enabled, outcomes-focused care听
  • Assess capacity to manage qualifying conditions across clinical tracks听
  • Plan for data collection, reporting, and performance measurement听
  • Consider partnerships with technology vendors and referring clinicians听
  • Monitor regulatory developments and payment听methodology听updates听

How 量子资源网 Can Help 

量子资源网听can help organizations听navigate the application process, develop implementation strategies, and position your organization for success in the evolving Medicare landscape.听If your organization is considering听participation in ACCESS or wants to understand how this model could听affect听your market,听contact听our experts below.

CMS鈥檚 2027 Medicare Advantage Proposed Rule Focuses on Outcomes and Competition

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On November 28, 2025, the Centers for Medicare & Medicaid Services (CMS)  the . Each annual rulemaking cycle offers CMS an opportunity to recalibrate program priorities.  

This proposed rule offers a road map for CMS鈥檚 vision for Medicare Advantage (MA) and Part D. Signaling how CMS leadership intends to shape the MA and Part D programs beyond 2027鈥攑rioritizing outcomes, streamlining operations, and inviting dialogue on modernization鈥攖he proposed rule reflects a strategic imprint on the program鈥檚 trajectory. The deadline to submit comments is January 26, 2026

Given CMS鈥檚 goal of modernizing MA and Part D, plans, providers, and advocates should engage early to inform final policies. 量子资源网 (量子资源网) policy and actuarial experts, including Wakely and Leavitt Partners (both 量子资源网 companies), are analyzing and modeling the effect of the proposed changes. This article highlights some of the major policy updates that require near-term planning by states, Medicare Advantage plans, providers who serve MA beneficiaries, and their partners. 

Key Themes in the Proposed Rule 

Requests for Information 

CMS includes three significant requests for information (RFIs) and highlights additional opportunities to provide input on approaches to reduce administrative burden throughout the program. CMS鈥檚 modernization RFI focuses on financing and other strategies to support beneficiaries with plan selection. In addition, CMS seeks input on emerging trends in MA special needs plans (SNPs), citing concerns about rapid growth and potential program integrity issues. Consistent with the departmentwide priorities, the RFI also delves into potential strategies for plans to address nutrition and wellness benefits for MA enrollees. 

Figure 1. RFIs Signaling New Policy Directions 

Star Ratings Overhaul: Refocusing on Outcomes and Experience

CMS proposes significant changes to the Star Ratings system, which influences plan bonuses and consumer choice. The changes increase the focus on clinical care, outcomes, and patient experience of care measures where performance is not topped out and align with universal foundation of measures. 

  • Health Equity Index Rollback: Rather than implement the previously planned Excellent Health Outcomes for All reward (formerly Health Equity Index) for 2027, the agency will continue using the historical reward factor that incentivizes consistently high performance across all measures. 
  • Measure Streamlining: Twelve process-heavy or administrative measures will be removed. 
  • Behavioral Health: A new measure for depression screening and follow-up will be introduced for the 2027 measurement year, with integration into Star Ratings by 2029.  

Why It Matters: Removing these measures continues the shift away from administrative compliance, easing burden while strengthening quality incentives. 

Medicare and Medicaid Dual Eligible SNPs and Integration 

CMS is proposing several changes to improve how Medicare Advantage plans serve people who qualify for both Medicare and Medicaid (dual-eligible beneficiaries): 

  • Starting in calendar year (CY) 2027, CMS proposes to allow D-SNPs and I-SNPs two opportunities to change to their model of care (MOC)鈥攖he framework for how they coordinate care. These windows would be January 1 through March 31 and October 1 through December 31. 
  • When beneficiaries are automatically moved (i.e., passively enrolled) from one integrated D-SNP to another, CMS will no longer require the new plan鈥檚 provider network to closely match the old plan鈥檚 network. Instead, the new plan must ensure that all incoming members receive uninterrupted care for at least 120 days (up from 90 days), helping prevent gaps in treatment. 
  • In states where dually eligible individuals are explicitly carved out from or not required to enroll in Medicaid managed care, CMS proposes to let highly integrated dual eligible special needs plan (HIDE SNP) continue to enroll full-benefit, dual-eligible (FBDE) individuals in the same service area, even if those individuals are in Medicaid fee-for-service. This change is intended to maintain coverage and simplify enrollment for these beneficiaries. 

Why It Matters: While the proposed changes revise broader policies, the updates could have significant effects on D-SNP and MA integration. These changes also could shape states鈥 decisions regarding their integration policies. Plans should continue to monitor these developments. 

Other Notable Changes  

CMS proposes a new special enrollment period (SEP) for beneficiaries when their providers leave a plan鈥檚 network, eliminating the requirement that CMS deem the change 鈥渟ignificant.鈥 The intent of this change is to preserve continuity of care and ease the burden of beneficiaries switching plans. In addition, CMS plans to codify SEP policies for greater consistency. 

The proposed rule also calls for the following: 

  • Codifying multiyear changes stemming from the Inflation Reduction Act, including elimination of the coverage gap phase 
  • Lowering annual out-of-pocket thresholds and removal of cost sharing in catastrophic coverage 
  • Transitioning to the Manufacturer Discount Program and updating true out-of-pocket (TrOOP) calculations 
  • Clarifying specialty-tier drugs and subsidy structures 

As a result, plans will have updated financial responsibilities. 

Connect With Us 

As CMS sets a new course for Medicare Advantage and Part D, organizations face both opportunities and challenges in adapting to these changes. 量子资源网 brings deep expertise in Medicare policy, actuarial modeling, and operational strategy. Our team鈥攊ncluding experts from Wakely and Leavitt Partners鈥攃an help plans, providers, and stakeholders interpret the proposed rule, assess its impact, and develop actionable strategies for compliance and competitive positioning. 

Whether you need data-driven analysis, scenario modeling, or hands-on support preparing for implementation, 量子资源网 is ready to partner with you to navigate the evolving Medicare landscape and achieve your goals.听Contact听our experts below to discuss your questions and how 量子资源网 can help.

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