After two years of payment cuts to Medicare Advantage, the research and advocacy organization urged the Centers for Medicare & Medicaid Services (CMS) to take actions that would promote stability within the program. The Better Medicare Alliance suggested the Trump Administration hit “pause” to review the Biden administration’s proposed 2026 changes before moving forward to finalize them in April.
Earlier this month, CMS released the 2026 Medicare Advantage and Part D Advance Notice, which proposed annual technical updates to Medicare Advantage and Medicare Part D Prescription Drug Programs to ensure payments to plans are up-to-date and accurate.
Among the proposed changes: CMS expects payments to Medicare Advantage plans to increase by 4.33 percent on average (a $21 billion increase) from 2025 to 2026, the completion of the three-year phase-in of the updated Part C Risk Adjustment Model, and updates to the Part D risk adjustment model, including the continued implementation of the Manufacturer Discount Program and the updated out-of-pocket threshold, the new Medicare Drug Price Negotiation Program, and calibrating the model using more recent data years (2022 diagnoses and 2023 costs).
Better Medicare Alliance said in an announcement that it has urged CMS to implement only provisions required by law. The organization asked CMS to pause and thoroughly evaluate the Biden administration’s proposed policy and technical changes before finalizing policies not required by statute. It emphasized the need for CMS to provide stability in the program and safeguard affordability, access, and quality of care for more than 34 million beneficiaries.
“Millions of Medicare Advantage beneficiaries are already navigating significant changes in Medicare Advantage and Part D, including implementation of the IRA (Inflation Reduction Act), as well as the impact of the last two years of Medicare Advantage rate changes that led to higher costs, reduced benefits, and widespread plan closures in 2025,” said Mary Beth Donahue, president and CEO of Better Medicare Alliance in the announcement. “We encourage CMS to prioritize stability and take the time needed to carefully review these proposals to protect the affordability and access that Medicare Advantage beneficiaries rely on.”
In its comment letter to CMS, the Better Medicare Alliance said it supports the proposal to integrate provider directories with Medicare Plan Finder but recommends that the agency delay implementation to 2027 to allow adequate preparation and to clarify processes for timely updates to maintain accuracy and consistency.
It also called on CMS to preserve supplemental benefit to close care gaps and address health-related and social needs. The Better Medicare Alliance also urged the Trump administration to extend the Value-Based Insurance Design (VBID) program for at least one more year to promote stability and smooth transitions for beneficiaries. Last month, CMS announced plans to terminate the program at the end of 2025 because it is costing billions of dollars to the Medicare Trust Funds.
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The organization also asked CMS to adopt integrated ID cards to streamline access for dual-eligible beneficiaries, individuals who are enrolled in both Medicare and Medicaid. It suggested targeted implementation of integrated Health Risk Assessments focused on Fully Integrated Dual Eligible Special Needs Plans to ensure meaningful impact and reduce administrative burdens.
Better Medicare Alliance also said it supports CMS’ efforts to protect beneficiaries from misleading marketing but urged the agency to consider reasonable review timelines to prevent bottlenecks and ensure timely dissemination of accurate information. It also asked CMS to collaborate with stakeholders to ensure a balanced approach to maintain transparency while reducing unnecessary complexities.
Other industry reaction
Other industry groups have also weighed in on the Advance Notice. AHIP wrote in an article this week that CMS must remember that payments to the Medicare Advantage program was cut in each of the last two years while underlying medical costs have continued to rise substantially. “With seniors' usage of medical services expected to remain high, a third consecutive year of insufficient MA funding would cause additional negative consequences for seniors’ benefits, costs and choices in 2026–while undermining efforts to promote prevention and reduce the incidence and progression of chronic disease,” it wrote.
In a letter to CMS’ Acting Administrator Jeff Wu, the Alliance of Community Health Plans (ACHP) asked the agency eliminate or at least delay the implementation of the Health Equity Index (HEI) and reinstate the Medicare Advance Reward Factor. ACHP said the HEI is poorly designed and doesn’t provide incentives for closing caps in care delivery. In rural areas, health plans are unable to complete for the reward.
“This is anticompetitive, harms vulnerable consumers in underserved areas and is antithetical to quality investment. ACHP-commissioned modeling by Wakely Consulting Group shows that while nearly the entire nation has the requisite number of seniors with defined social risk factors to qualify for the HEI, more than three-quarters are enrolled in health plans that are ineligible for the full reward. This is a clearly broken policy that should be halted,” it wrote.