Early each year, the Centers for Medicare & Medicaid Services (CMS) publishes an Advance Notice of methodological changes for the Medicare Advantage (MA) and Part D Star ratings program. These changes are then finalized in April, providing crucial information to MA plans for future Star ratings years. In this article, we explore key updates from the 2026 Final Rule and Rate Announcement, which deferred a significant number of proposals from the Advance Notice, discuss avenues for future rulemaking, and provide recommendations for MA plans to prepare for forthcoming changes.
Codified measure changes are minimal
In January 2025, the Advance Notice was published a few weeks earlier than in recent years and was therefore released before the transition to a new administration. Although several proposed changes were put forth in the notice, only a handful were codified by the Final Rule released by the new administration on April 4.
For the 2029 Star Ratings, which is based on Measurement Year (MY) 2027, the only substantive measure change finalized by the Final Rule was expanding the age range for breast cancer screening for women from 50–74 years old to 40–74. The updated measure will remain on the display page for two years before becoming part of the Star ratings program.
The Final Rule left alone several previously codified or proposed changes for the 2027, 2028, and 2029 Star ratings, including various measure additions, deletions, and changes.
The Health Equity Index becomes Excellent Health Outcomes for All
Introduced by CMS in the 2023 Final Rule, the Health Equity Index reward was slated to replace the previous reward factor for MA plans beginning in the 2027 Star ratings, incentivizing plans to improve care for members with social risk factors while also saving Medicare more than $5 billion over 10 years, according to previous estimates.
The 2026 Final Rate Announcement retains the reward for now, but under the name of Excellent Health Outcomes for All (EHO4all). Enrollees considered in EHO4all include members who are dually eligible for Medicaid, receive low-income subsidies, or are disabled. These groups are prioritized due to their risk for poor health outcomes according to Star ratings data, which reveals gaps in their care quality.
Noting “mixed support” for the previously proposed idea of adding geography as a factor in the EHO4all award, CMS stated that it will continue to evaluate this proposal, adding that “CMS may also consider additional changes regarding the EHO4all reward and any further changes would need to be proposed through rulemaking.”
Avenues for rulemaking and preparing for future updates
CMS has multiple methods for implementing changes, which are each suited for different situations. They include:
- Propose and comment: This is the traditional process followed for the Advance Notice and Final Rule, allowing stakeholders approximately 30–60 days to provide feedback before finalizing the rule. While transparent and participatory, it increases the amount of time to finalize rules.
- Interim final rule: Used for urgent situations, this method allows changes to go into effect immediately, followed by a post-implementation comment period. It offers flexibility and speed, as exemplified by CMS' response to the COVID-19 pandemic.
- Direct final rule: Intended for noncontroversial updates, this method is used when CMS publishes a rule with a specific effective date 30–60 days in advance, which becomes effective unless significant adverse comments are received during that period. This method avoids lengthy processes but limits public feedback. Examples include removal of obsolete regulations and routine updates to payment rates.
In late February, Secretary of Health and Human Services Robert F. Kennedy, Jr. ordered the agency to end the public comment rulemaking process in certain situations, pivoting from previous years. Given the current administration's emphasis on rapid rulemaking and less reliance on public comment, MA plans should expect more interim and direct final rules, necessitating a proactive approach to stay informed and adaptable.
Recommendations for MA plans and stakeholders
In the face of uncertainty, MA plans and stakeholders can focus on several strategic areas to navigate future changes effectively. Here are four key areas plans can focus on to move forward with success.
Shift the paradigm from individual measures to a holistic approach that considers all aspects of member information, compliance, and socio-economic factors. Proactive outreach and barrier removal are crucial to understanding what factors are preventing your member population from achieving compliance. Addressing smaller problems early and encouraging members to understand their benefits in a crisis can help prevent hospitalizations, leading to improved member experience scores. Take advantage of the required “Mid-Year Enrollee Notification of Unused Supplemental Benefits” as an opportunity to engage, improve the experience with the plan, close gaps, and drive member wellness.
Prioritize clinical care, outcomes, and patient experience over operational performance. Ensure members have follow-up visits, understand their medications, and have access to necessary resources to manage chronic conditions, including monitoring tools for blood pressure and blood sugar.
Invest in digital transformation and technological advancements to make data-driven decisions. Good data infrastructure enables better analysis, outreach, and provider performance recognition. Supportive data allows plans to analyze supplemental benefit usage and cost, which can help determine ROI on outreach programs and inform your P4P payment arrangements to recognize outstanding performers. Investing in good data will help your organization innovate and grow into the right areas for continued success.
Maintain close communication with CMS and other industry leaders to stay updated on changes. Socialize new updates within the organization and consider feedback from stakeholders and team members to make informed decisions.
Investing in good, complete data will always help make informed decisions that put members first and listening to our stakeholders will help make the best decisions with the specific needs of our organizations in mind. The 2026 CMS Final Rule and Rate Announcement highlight the importance of staying adaptable in a constantly evolving regulatory landscape. By focusing on whole member care, outcomes, innovation, and listening, health care providers can set themselves up for success regardless of changes to the Star ratings program. Proactive and comprehensive care can lead to better health outcomes and member satisfaction.
Stay informed on future updates with Cotiviti’s CMS Star ratings calendar. Check for proposed and confirmed upcoming changes to the CMS Star ratings system for the 2026 Star ratings and beyond.
About the author
Marge Ciancetta is the product manager of Cotiviti’s Star Intelligence solution, which helps health plans and providers improve their quality ratings and Star scores. She ensures that Star Intelligence represents the voice of Cotiviti’s customers and aligns with industry best practices. She also works closely with our development team, as well as with customers and stakeholders, to ensure that their feedback is incorporated into the product roadmap. With over a decade of experience in the quality space, Ciancetta has a unique perspective on the challenges and opportunities facing health plans and providers today.