On October 16, CMS released the first of what it says will be two proposed rules for Contract Year 2028 in Medicare Advantage and Part D. This one implements provisions of the Consolidated Appropriations Act, 2026, and it is narrower than the annual policy rule MA leaders usually brace for. It still carries real operational weight, and it signals what may come next.
What the proposal would do
The headline change is provider directory accuracy. Under the proposal, MA plans would have to verify and update their directory information at least every 90 days and report an accuracy score to CMS. Those scores would also be displayed on each plan's public-facing directory, so beneficiaries could compare plans on directory quality. If an enrollee relies on an inaccurate listing and ends up seeing an out-of-network provider, the enrollee would pay no more than the in-network cost-sharing amount.
The second piece targets pharmacy benefit managers. PBMs would report their compensation and cost performance to plan sponsors and CMS every year, and payments to PBMs would have to reflect fair market value for the services provided rather than the cost of the drugs. The proposal also adds cost-saving protections for low-income Medicare beneficiaries. The comment period runs 60 days after the rule is published in the Federal Register.
Why it matters for plan operations
Quarterly directory verification is a data and provider-relations workload, not a one-time compliance project. Plans will need clean provider data, a repeatable outreach process, and a way to explain a published accuracy score to members and brokers. The in-network cost-sharing protection also puts financial exposure behind directory errors. On the Part D side, plan sponsors that rely on PBMs will need contract terms and reporting that can support the new compensation transparency.
The second rule is the one to watch
CMS says it expects to release another proposed rule with policy and technical changes for Parts C and D later this fall. That is the vehicle where Star Ratings, special needs plan, and risk adjustment changes would normally appear. Analysts quoted by Fierce Healthcare after the 2027 Star Ratings release said they expect CMS to cut more Stars measures in that rule, which would hurt plans that have scored well on administrative measures. CMS already removed 11 such measures for 2027, with a phase-out through 2029.
The timing matters. The 2027 Star Ratings came out on October 8 with harder thresholds and heavier outcome weighting, and Alignment Healthcare sued over them days later. Plans are now planning for 2028 with a rule that has not been written yet.
Where to hear more
The Star Ratings Master Class, December 14–16 in Scottsdale, includes The CY2028 Proposed Rule: What It Means for Your Stars Strategy on December 16, along with a workshop on navigating the new reality of Medicare Advantage on December 14. The session is designed for quality, Stars, and compliance leaders who need to translate proposed policy into next year's plan. Register at stars.risehealth.org.
Sources: CMS press release, October 16, 2026; Fierce Healthcare, October 9, 2026; Healthcare Dive, October 13, 2026.