CMS recently released updated operational guidance for Contract Year (CY) 2027 Medicare Advantage (MA) applications. This guidance introduces pivotal shifts in how organizations manage network adequacy and exception requests, meaning the “old way” of managing deficiencies is no longer sufficient for those preparing for the February submission.
Key Update 1: Accelerated Exception Request (ER) Timeline
The most significant operational change for CY 2027 is the timing of Exception Requests.
The Update: Applicants no longer have to wait for later stages to justify network gaps. You can now submit ERs immediately after receiving your Automated Criteria Check (ACC) results for the initial submission.
The Strategy: This allows for a more proactive approach to addressing network challenges early in the cycle.
Key Update 2: Formalizing the Path for Letters of Intent (LOIs)
CMS has clarified how applicants can use LOIs to address network deficiencies.
- The Update: When responding to a Deficiency Notice or Notice of Intent to Deny, you may include providers on your HSD tables with whom you have secured valid LOIs.
- The Requirement: You must explicitly notify CMS each time an LOI is used to address a noted deficiency.
Key Update 3: Volatility in Time and Distance (T&D) Standards
Networks that met standards for CY 2026 may no longer be adequate for CY 2027. We are seeing significant volatility in Time and Distance (T&D) requirements:
- Increased Standards: Many county-specialty requirements have been enhanced, requiring more robust provider density.
- Reduced Distance Thresholds: A significant number of county-specialty distance requirements have been reduced, which can create immediate gaps in networks that previously relied on wider “customized” criteria.
- Return to Base & Customization: CMS mapping now shows many areas can pass standard base distances, meaning previous “customizations” may no longer be accepted.
Conclusion
Don’t wait for an ACC failure to discover your gaps. With the February deadline approaching, early testing of your Health Service Delivery (HSD) tables is critical to identify upload errors and determine if ERs are necessary.
Contact ATTAC today to assist with evaluating your network against the new CY 2027 adequacy requirements. We help you identify gaps created by these criteria changes and secure the necessary providers before you hit “final submit.”
