Released earlier than in years past, the 2026 Centers for Medicare & Medicaid Services (CMS) Medicare Advantage (MA) and Part D Advance Notice contains key updates for MA plans from both a risk adjustment and quality perspective. Here, we offer three important takeaways for MA plans looking to digest these proposed changes and craft impactful comments to submit during the public comment period.
As noted in Figure 1, a significantly larger effective growth rate compared to the 2025 Final Rate Announcement would drive an expected average revenue bump exceeding 4.3% or more than $21 billion. As CMS explains, this effective growth rate is driven by estimated growth in Medicare Fee-For-Service (FFS) per capita costs. The expected average revenue increase also factors in quality bonus payments, risk adjustment model updates, and risk score increases driven by demographics and coding patterns.
Impact |
2026 Advance Notice |
2025 Final Rate Announcement |
---|---|---|
Effective growth rate |
5.93% |
2.44% |
Change in Star Ratings |
-0.69% |
-0.15% |
MA coding pattern adjustment |
0.00% |
0.00% |
Risk model revision and FFS normalization |
-3.01% |
-2.45% |
MA risk score trend |
2.10% |
3.86% |
Expected average change in revenue |
4.33% |
3.70% |
Figure 1. Year-over-year changes in anticipated MA plan payments (Source: CMS fact sheet).
In 2023, CMS announced the phase-in of a new CMS-HCC risk adjustment model to begin in calendar year 2024. Important updates included:
In 2026, CMS proposes to complete the three-year phase-in of the 2024 CMS-HCC risk adjustment model, noting the following:
Plans and providers have implemented the model smoothly and risk adjustment and payment levels have remained stable, and thus CMS is proposing to finish the phase-in as proposed to improve payment accuracy. For 2025, MA offerings for people with Medicare remained stable—including premiums, supplemental benefits, and coverage options. Additionally, MA rebates—used to provide supplemental benefits and premium buy-downs—have stayed stable at more than $2,400 annually per person on average, which indicates that MA payment has remained adequate during the phase-in of these updates. Pausing the risk adjustment model phase-in would result in $3.4 billion in additional payments to MA plans in 2026, which are not necessary to support stability in the program.
CMS anticipates the cumulative impact of changes to the Star Ratings program for calendar year 2026 would be a 0.69% decline in overall quality bonus payments, a steeper decrease from 0.15% decline for calendar year 2025.
In addition to non-substantive measure specification updates, the Advance Notice proposes new measure concepts and methodological changes driven by changes to the HEDIS® program proposed by the National Committee for Quality Assurance (NCQA). This includes potential measures focused on:
For the Health Equity Index (HEI) reward that will be implemented beginning with the 2027 Star Ratings, CMS also seeks feedback on adding geography (e.g., rural or urban) as a social risk factor (SRF).
CMS will accept public comment on the 2026 Advance Notice through February 10, 2025 and publish the final Rate Announcement by April 7.
For a deeper dive into the 2026 Advance Notice, don’t miss Cotiviti’s 30-minute webinar kicking off our Quality Decoded webinar series on Wednesday, February 19 as we:
We’ll also break down other critical HEDIS and Star Ratings updates throughout all of 2025. Sign up for the entire series or any individual webinar that suits your interest. We’ll see you there!
HEDIS® is a registered trademark of the National Committee for Quality Assurance.