CMS released the CY2027 Medicare Advantage Final Rule and Rate Announcement within four days of each other. Together, they represent a systematic restructuring of how Medicare Advantage organizations will compete, be evaluated, and be paid. This guide covers six areas of change: what shifted, what’s at stake, and what your organization should be acting on now.
STARS & QUALITY | HIGH IMPACT
11 measures removed. Depression Screening & Follow-Up added (2029 Stars). HEI reward canceled. Historical Reward Factor retained.
What’s at Stake
- Remaining measures carry more weight
- Plans lose the cushion of high-performing operational measures that previously helped offset gaps elsewhere
Immediate Actions
- Identify your highest-weight gaps by contract
- Re-model your Stars portfolio under the new 30-measure set
RISK ADJUSTMENT | HIGH IMPACT
Diagnoses from unlinked chart review records excluded from risk scores. Effective CY2027. Exception: beneficiaries switching MA organizations.
What’s at Stake
- Plans relying on unlinked CRRs face direct revenue impact
- RADV scrutiny intensifies as CMS data access expands
- HCC documentation accuracy is now a financial imperative
Immediate Actions
- If your exposure is high on unlinked CRR, you can take action now
- Beyond factoring the changes into your bid, ensure your risk adjustment strategy is audit-durable
SUPPLEMENTAL BENEFITS | HIGH IMPACT
Debit card guardrails codified with real-time verification. SSBCI eligibility criteria must be publicly posted. Dollar value marketing continues to be permitted.
What’s at Stake
- CMS has already pursued compliance actions against plans using self-attestation for SSBCI
- Non-compliance exposure increases in a more data-transparent environment
Immediate Actions
- Evaluate 2026 SSBCI eligibility criteria for gaps before 2027 benefit administration planning begins
- Document criteria for determining high hospitalization risk and intensive care coordination needs. Assign ownership. Put it in a policy and procedure.
- Review debit card administration for real-time verification compliance
- Schedule a readiness assessment with your debit card administrator to confirm compliance
PART D REDESIGN | MEDIUM IMPACT
IRA codified: coverage gap eliminated. Deductible $615 → $700. OOPC $2,100 → $2,400. Manufacturer Discount Program replaces Coverage Gap Discount Program.
What’s at Stake
- Formulary strategy and pharmacy contracts must reflect the new benefit structure before bids are submitted
Immediate Actions
- Review formulary and pharmacy contracts against the new benefit design before June 1
NETWORKS & ENROLLMENT | LOW IMPACT
Proposed SEP for provider terminations not finalized. Existing SEPs codified. Behavioral health network adequacy now tied directly to the new DSF Stars measure.
What’s at Stake
- Network stability remains under CMS scrutiny
- BH access gaps will surface as low DSF scores in 2029
- PHQ-2/9 screening requires provider training at scale
Immediate Actions
- Assess behavioral health network adequacy
- Telehealth contracting is the fastest lever for closing BH access gaps
THE RATE ANNOUNCEMENT | HIGH IMPACT
The Rate Moved. The Pressure is Still On.
Rate landed at +2.48% / $13B+. The advance notice had proposed +0.09%. Why: CMS retained the 2024 risk model.
What’s at Stake
- The 5.9% coding adjustment was held at the statutory minimum — downward pressure on effective risk scores continues
- Future model updates remain on CMS’s agenda
- This is a window, not a reprieve
Immediate Actions
- Use the window to strengthen both RADV durability and encounter-based documentation
- Don’t let the rate increase substitute for cost of care and admin efficiency work
YOUR APRIL CHECKLIST
- Audit unlinked CRR usage. Quantify revenue exposure before bids lock.
- Re-model Stars performance under the new 30-measure set.
- Update bid assumptions: 2.48% net, 5.33% effective growth, 2024 model continuing.
- Start ECDS pipeline for Depression Screening & Follow-Up. MY2027 is live now.
- Update agent training and compliance programs for AEP 2027.
- Update framework for 2027 SSBCI eligibility determination and benefit administration.
- Assess BH network adequacy for 30-day DSF follow-up access.
About ATTAC Consulting Group
ATTAC Consulting Group is a specialized healthcare consulting practice focused on Medicare Advantage Star Ratings, risk adjustment, compliance program navigation, provider network strategy, and value-based care. Founded 23 years ago, ATTAC partners with health plans, health systems, and provider organizations to navigate regulatory change and translate it into executable strategy.
The industry has no shortage of AI-generated summaries and reactive hot takes. ATTAC translates regulatory change into executable strategy across every dimension of operations. Not as external advisors looking in. As operators.
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