The AAMC submitted Jan. 27 comments (PDF) to the Centers for Medicare & Medicaid Services (CMS) in response to the Contract Year 2026 Medicare Advantage (MA) and Part D Policy and Technical Changes proposed rule [refer to Washington Highlights, Dec. 6]. The proposed rule covered various policy topics related to MA and Part D plans, including prior authorization, network adequacy, supplemental benefits and marketing, the use of Artificial Intelligence (AI), Medical Loss Ratio (MLR) reporting, dual special needs plans, Part D plans, and additional policies.
The AAMC’s comments focused on supporting improvements to transparency and access in MA plans by adopting policies to address narrow provider networks, increased use of utilization management tools such as prior authorization and denials, and lack of transparency in supplemental benefits. Comments also touched on affordability by asking the agency to finalize a proposal to align cost sharing to behavioral health services with Medicare Fee-for-Service. Additionally, the association asked the CMS to finalize proposed guardrails for safe and equitable use of AI by MA plans and changes to improve MLR reporting and calculations to improve accuracy. In response to an included request for information on vertical integration, the AAMC urged the agency to monitor the impact of consolidation in the insurer market, including pharmacy benefit managers, and how it may affect the availability of services and providers and quality of care. Related to Part D plans, the AAMC requested that the CMS prohibit utilization management practices that are more stringent than corresponding clinical guidelines and increase access to prescription drugs by limiting cost sharing and adopting policies that improve beneficiary affordability. Lastly, the AAMC continued to urge the CMS to finalize proposals to streamline enrollment and encourage integration of dual special needs plans.