On November 25, 2025, CMS issued a proposed rule that updates the Medicare Advantage (MA) and Part D prescription drug programs for contract year (CY) 2027. The rule proposes changes to:
- MA Star Ratings
- Special enrollment periods (SEPs)
- Non-allowable supplemental benefits for chronically ill beneficiaries
- Reduction of plans’ administrative burden
- Codification of provisions of the Inflation Reduction Act of 2022 (IRA)
The most significant proposed change for plans and providers is to Star Ratings. If finalized, the changes will increase payments to plans by $13.2 billion over 10 years and could limit the effectiveness of the provider complaint process CMS revised in 2024.
The proposed rule is extensive and addresses many aspects of the MA program. Below is a summary of select proposed provisions that will impact health plans and providers.
Medicare Advantage & Part D Star Ratings
CMS administers a five-star rating system for MA (Part C) and Part D plans to provide beneficiaries with comparative quality information and determine bonus payments and rebates. CMS continues to refine the Star Ratings system in alignment with its national quality strategy and proposes several changes in the CY 2027 rule.
Measure Removals
CMS proposes to streamline the Part C and Part D Star Ratings program by removing 12 measures (see Table 1, pg. 244 of the display version) beginning with the CY 2029 Star Ratings year. Of these 12 measures, seven are focused on operational and administrative performance, three are process measures, and two are patient experience measures.
CMS contends these measures often show consistently high performance with little variation across contracts, making them less meaningful for beneficiaries when comparing plans. By eliminating measures that are “topped out” or sensitive to small changes, the agency aims to reduce administrative burden and increase the relative weight of outcome-focused measures. The changes are intended to shift attention toward clinical care, outcomes, and patient experience measures where improvement is still needed. Although removing these measures may initially lower overall ratings, CMS expects offsets from retaining the historical reward factor and eliminating the Health Equity Index reward.
Measure Addition
CMS proposes adding the Depression Screening and Follow-Up (DSF) measure. It will begin reporting the DSF measure on the display page for the 2026 Star Ratings, which will impact CY 2029 Star Ratings.
Special Enrollment Periods
CMS proposes two changes to special enrollment periods (SEPs) intended to streamline enrollment in a new plan when justified.
- Provider Leaving Plan Network: CMS proposes replacing the current SEP for Significant Change in Provider Network with a broader SEP for Provider Terminations. If finalized, this would allow affected enrollees to switch plans without requiring CMS or the MA plan to first determine whether the change is “significant.” Under this proposal, any enrollee who has recently received care from a terminated provider would automatically qualify, and SEP information would be included directly in provider termination notices rather than through separate communications.
- Prior Approval for SEPs: CMS proposes codifying its policy that certain SEPs require prior approval from CMS before an election request can be processed. SEPs affected by this proposal include those for contract violations, CMS sanctions, loss of creditable coverage, and other exceptional circumstances. If finalized, eligibility for these SEPs would be confirmed either through a CMS-operated mechanism, such as 1-800-MEDICARE or the Online Enrollment Center, or via an official CMS notice.
Non-Allowable Special Supplemental Benefits for Chronically Ill Enrollees
CMS proposes to clarify that cannabis products that are illegal under federal or state law, including those restricted by the Federal Food, Drug, and Cosmetic Act, cannot be offered as Special Supplemental Benefits for the Chronically Ill (SSBCI). Under the proposal, MA plans would be permitted to offer certain food ingredients derived from hemp seeds as SSBCI if they meet the Food and Drug Administration’s “generally recognized as safe” standard and demonstrate health benefits.
Reducing Administrative Burden for MA Plans
CMS proposes changes to remove requirements that are duplicative or are no longer applicable. This includes proposals related to:
- Exempting Account-Based Medical Plans From Entities Required to Make Disclosures of Creditable Coverage: If finalized, this change would codify that account-based plans, such as health reimbursement arrangements (HRAs) and individual coverage health reimbursement arrangements (ICHRAs), are exempted from group health plans that are required to make creditable coverage disclosures.
- Deregulating Section 422.102(e) Pathway for Certain Dual Eligible Special Needs Plans (D-SNPs) to Offer Supplemental Benefits: Section 422.102(e) currently allows certain D-SNPs to offer additional supplemental benefits. CMS notes very few plans have used this pathway, and the same benefits can already be provided under existing rules. Therefore, CMS proposes eliminating §422.102(e) to streamline the bid submission process, as the agency contends there are other pathways available to offer meals, assistive devices, and other supplemental benefits.
- Rescinding the Mid-Year Supplemental Benefits Notice: CMS proposes to rescind the midyear notice requirement related to supplemental benefits, concluding that it does not improve communication with beneficiaries and is an unnecessary administrative burden. The agency contends that existing outreach and care coordination efforts already ensure enrollees are aware of and use supplemental benefits effectively.
- Revising the Ensuring Equitable Access to Medicare Advantage (MA) Services Requirement: CMS proposes to revert §422.112(a)(8) to its original heading and text, “Cultural considerations,” which requires MA plans to provide services in a culturally competent manner to all enrollees. The agency contends the 2023 revisions added unnecessary complexity without changing the underlying requirements.
- Rescinding the Annual Health Equity Analysis of Utilization Management Policies and Procedures: CMS proposes to rescind the requirements that MA utilization management committees include a member with expertise in health equity, conduct an annual health equity analysis of prior authorization, and publicly post that analysis. The agency contends these provisions create unnecessary regulatory burden, do not significantly improve health equity, and are inconsistent with recent executive orders.
- Rescinding the Quality Improvement Program Health Disparities Requirement: CMS proposes eliminating the requirement that MA plans include activities to reduce health disparities in their quality improvement (QI) programs. The proposed rule notes this provision no longer aligns with current executive orders prioritizing deregulation, and the agency contends removing it will reduce administrative burden while preserving core QI requirements.
- Deregulating the Special Rule for Non-Compliant D-SNPs: The Balanced Budget Act of 2018 authorized the Secretary of Health and Human Services to impose an enrollment sanction on an MA plan offering a D-SNP that has failed to meet at least one of the new integration standards in plan years 2021 through 2025. CMS proposes to remove this provision, given that the statutory authority for the enrollment sanction expires at the end of plan year 2025.
Codifying Inflation Reduction Act Provisions
CMS proposes changes that would codify reforms from the IRA. These changes are significant and include eliminating the coverage gap, lowering out-of-pocket thresholds, removing catastrophic phase cost sharing, and implementing the Manufacturer Discount Program.
How Forvis Mazars Can Help
Forvis Mazars helps MA plans and other payors achieve regulatory excellence to strategically navigate the evolving policy environment. If you have questions about the CY 2027 MA proposed rule and how it may affect your organization, please reach out to our professionals.