Premier Responds to Medicare Advantage and Part D Proposed Rule for Contract Year 2026
Today, Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its Contract Year 2026 Medicare Advantage (MA) and Part D proposed rule. Premier is particularly interested in advancing policies that protect access to care for Medicare beneficiaries in rural areas. In our comments, Premier specifically recommends that CMS pursue policies that:
- Strengthen network adequacy standards down to the plan (rather than contract) level;
- Provide greater incentives for MA organizations to make a good faith effort to contract with rural providers in their network design; and
- Ensure that the benchmark payment boost that health plans receive from critical access hospitals (CAHs) in their counties is passed on to CAHs and other rural providers, sustaining access to care.
In its detailed comments, Premier also recommends changes that could make significant strides toward addressing issues that were surfaced in a recent national survey of Premier’s member hospitals and health systems that points to the need for policies that advance the needs of patients enrolled in MA and the providers who care for them. These include:
- Finalizing new transparency requirements for MA plans’ internal coverage criteria;
- Codifying regulatory requirements that prevent MA plans from reopening or revising approved authorizations for medically necessary inpatient care;
- Collecting and analyzing data on payment delays and denials between MA plans and in-network, as well as out-of-network, contracted providers;
- Monitoring and enforcing compliance with Medicare coverage policies for post-acute care to ensure that MA beneficiaries do not face undue barriers to care after inpatient hospital stays;
- Developing demonstration programs to provide MA plans with additional flexibilities and/or financial rewards for implementing real-time prior authorization programs with contracted providers;
- Finalizing proposed changes to improve transparency through medical loss ratio reporting;
- Collecting more granular data on the dollar amounts of health plan payments to owned/employed versus contracted providers to monitor whether vertical integration undermines medical loss ratio requirements;
- Collecting and monitoring data about the timeliness of plans’ data-sharing with providers, to promote strong payer-provider partnerships in the movement to value-based care;
- Finalizing and enforcing protections for pharmacies included in the Medicare Prescription Payment Plan program; and
- Finalizing proposed changes to help integrate care for dual-eligible enrollees.
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