The CMS Advance Notice: What Medicare Advantage Plans Should Be Doing Now
Written by: Lesley Weir, CRC, Principal Solution Consultant, Veradigm
The CMS Advance Notice is not just a preview—it’s a signal
Each year, the CMS Advance Notice provides early insight into where Medicare Advantage policy is heading. For 2026, the shifts are clear. CMS projects an average payment increase of 4.33% from 2025 to 2026 and proposes updates to Star Ratings that emphasize clinical care, patient experience, and consistency across measures. CMS also plans to fully implement the V28 risk adjustment model for 2026, completing the transition that began in 2024.
These changes increase scrutiny across risk adjustment, quality performance, documentation, and operational compliance. For health plans, the Advance Notice should not be viewed as passive background noise ahead of the April Rate Announcement. It is a preparation window. Plans that respond early will enter bid season with strategic clarity. Plans that wait for the final rule may find themselves making critical decisions under time pressure.
Signal 1: Revenue growth will not absorb operational inefficiency
Although CMS projects an average 4.33% revenue increase for Medicare Advantage plans in 2026, the increase is largely driven by FeeForService cost growth rather than operational performance. CMS also notes that risk adjustment model refinements, Star Ratings updates, and normalization factors will affect plan payments and overall performance expectations.
This means financial stability in 2027 will depend more on operational precision than on rate updates. To achieve this, plans should focus on:
- Accurate RAF capture
- Defensible documentation
- Predictable Star performance
- Lower administrative overhead
In constrained rate cycles, small inaccuracies can compound into significant margin erosion. More plans are using the CMS Advance Notice period to reconfigure integrated performance models that align analytics, provider engagement, documentation validation, chart retrieval, and submissions under one coordinated system. CMS’s emphasis on accurate payments and program accountability reinforces the need for operational integration.
Platforms such as the Veradigm Core Payer Platform support this alignment by connecting risk, quality, and compliance functions within a unified ecosystem.
Signal 2: Risk adjustment must be defensible, not just maximized
CMS’s full implementation of the CMSHCC V28 model for 2026 redefines how risk scores are calculated and what documentation is required to support them. The V28 model restructures condition categories using ICD10 coding and updated FeeForService data to ensure risk scores reflect current clinical complexity.
These refinements increase expectations around diagnosis validity, documentation traceability, and defensibility. As CMS strengthens oversight of coding accuracy and encounter data quality, plans need to demonstrate not only that diagnoses were identified but that they were documented, validated, and clinically appropriate.
The central operational question becomes:
How much risk can we defend?
Plans should use this period to:
- Review documentation audit trails
- Evaluate coding validation processes
- Identify diagnosis sources vulnerable to scrutiny
- Map RADV exposure scenarios
Plans increasingly recognize that prospective gap identification must be paired with structured coding validation and centralized documentation governance. Integrated payer platforms that combine risk analytics, chart intelligence, and coding validation help close this defensibility gap before audit exposure increases.
Signal 3: Stars cannot be reactive
CMS continues to refine MA and Part D Star Ratings, proposing updates for 2026 that emphasize outcomes, patient experience, and measure consistency. CMS also highlights updated quality bonus payment calculations and the need for greater alignment across clinical and experiential measures.
Despite these changes, many organizations still operate in a reactive cycle:
Measure → Identify gap → Scramble → Report
The CMS Advance Notice period provides a critical opportunity to operationalize Stars improvement. Plans can strengthen quality performance by:
- Delivering care gap alerts within provider workflow
- Aligning member outreach with priority measures
- Preparing documentation before visits
- Coordinating scheduling and member engagement strategies
Because CMS is elevating expectations around consistency and outcomes, plans must move from reporting toward yearround orchestration. Technology that integrates analytics into the point of care enables realtime execution rather than endofyear scrambling.
Signal 4: Fragmentation is the hidden risk
Many Medicare Advantage plans still rely on fragmented vendor arrangements for analytics, coding, chart retrieval, and submissions. This introduces gaps between:
Insight → Action → Validation → Submission
These operational disconnects increase financial risk and reduce compliance readiness. CMS continues to emphasize accurate payments, documentation integrity, and the elimination of unnecessary spending across MA and Part D programs.
The Advance Notice period is an ideal time for plans to evaluate whether their operational infrastructure is truly connected or simply adjacent. Integrated payer platforms reduce vendor sprawl, create cleaner handoffs across workflows, and strengthen audit defensibility by improving traceability.
The strategic outlook for 2027 and beyond
The Advance Notice is not just a preview of upcoming CMS changes. It is an indicator of what success in Medicare Advantage will require in the years ahead. Across risk adjustment, quality, documentation, and financial modeling, CMS is signaling a more precise, accountable, and integrated regulatory environment.
Plans that act now will enter 2027 with stronger operational foundations. They will be better prepared to manage regulatory updates, maintain documentation integrity, and support continuous improvement across their organizations. They will also be more resilient as CMS continues refining risk adjustment models and quality programs.
The plans that will compete most effectively in the future will be those that connect the performance ecosystem. This includes analytics, provider engagement, documentation management, coding validation, and submission oversight. It also requires internal coordination that supports consistency, transparency, and realtime responsiveness.
The future of Medicare Advantage will reward plans that invest early and build connected, defensible, and datadriven performance operations. Preparing now positions plans not only to comply with policy but to compete confidently as the program continues to evolve.