AAMC Comments on CY26 MA Advance Notice

The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the Calendar Year (CY) 2026 Medicare Advantage (MA) Advance Notice [refer to Washington Highlights, Jan. 17]. The advance notice, issued annually, proposes updates to MA payment rates and technical updates to keep MA payments up to date and accurate.

The AAMC’s comments focused on two topics affecting the calculations and methodologies used to determine payment to MA plans (PDF). First, the AAMC urged the CMS to ensure encounter data is accurate and complete prior to incorporating it into a risk adjustment model for MA payment calculations and methodologies. Within the advance notice, the agency had acknowledged it may be capable of phasing in such a model as soon as 2027. Comments asked the CMS to explore options to enforce the reporting of complete, timely, and accurate encounter data and consider the addition of additional data elements to expand what is included in the encounter data collected and made public to improve transparency.

Lastly, the AAMC reemphasized its position in response to the CMS’ 340B Drug Pricing Program remedy, calling on the agency to address the final rule’s failure to remedy the impact these polices had on MA payments [refer to Washington Highlights, Aug. 29, 2023]. The CMS stated in the notice that the upcoming reduction in payment for nondrug Outpatient Prospective Payment System (OPPS) in fee-for-service would be reflected in its MA payment methodologies and calculations. However, during the timeframe that OPPS payments were reduced, many MA plans also reduced reimbursement for 340B-acquired drugs, but providers were never repaid from these reductions in MA payments. Comments call on the CMS to work with policymakers and take all possible measures within its authority to ensure hospitals are made whole and not penalized twice with reductions in payments from MA plans due to remedy policies.