CMS released its proposed rule for contract year 2027 Medicare Advantage and Part D on November 25, and the Star Ratings provisions alone would reshape quality strategy for the rest of the decade. The rule proposes to abandon the health equity reward that was scheduled to begin with the 2027 Star Ratings, remove twelve measures, add a depression screening measure and open broad requests for information on risk adjustment and chronic condition special needs plans. Comments are due January 26, 2026. Here is what is on the table and where plans, MSOs and provider groups should focus their attention.

The Health Equity Reward Would Not Take Effect

Under rules finalized in 2023, the historical reward factor, which adds up to a fraction of a star for contracts with consistently high and stable performance, was set to be replaced starting with the 2027 Star Ratings (affecting 2028 payments). The replacement, originally called the Health Equity Index reward and more recently described by CMS as the Excellent Health Outcomes for All reward, would have rewarded contracts for strong performance among enrollees with social risk factors such as dual eligibility, low-income subsidy status and disability.

CMS now proposes not to implement that reward and to continue the historical reward factor. For contracts that built strategy around serving high concentrations of dual-eligible and low-income members, this removes an expected upside. For contracts that had modeled a loss under the equity reward, it removes a risk. Either way, finance teams should rerun their 2027 and 2028 Star projections, because the reward calculation can be the difference between 3.5 and 4 stars for contracts near the threshold.

Twelve Measures Proposed for Removal

CMS proposes to remove twelve measures, citing a focus on clinical care, outcomes and patient experience and a desire to retire administrative measures and measures with high performance and little variation. The list:

  • Plan Makes Timely Decisions about Appeals and Reviewing Appeals Decisions
  • Special Needs Plan (SNP) Care Management
  • Call Center: Foreign Language Interpreter and TTY Availability (Part C and Part D, counted separately)
  • Complaints about the Health/Drug Plan
  • Members Choosing to Leave the Plan
  • Medicare Plan Finder Price Accuracy
  • Diabetes Care: Eye Exam
  • Statin Therapy for Patients with Cardiovascular Disease
  • Customer Service
  • Rating of Health Care Quality

Most removals would take effect with the 2029 Star Ratings, based on the 2027 measurement year. The call center measures and the statin therapy measure would come out earlier, with the 2028 Star Ratings. The only proposed addition is Depression Screening and Follow-Up, which measures the share of members screened for clinical depression with a standardized instrument and, if positive, receiving follow-up care within 30 days. It would begin with the 2027 measurement year for the 2029 Star Ratings.

Why the Measure Changes Matter Financially

Many of the measures proposed for removal are ones where most plans score well. Appeals timeliness, complaints and the call center measures have averaged above four stars in recent years. Removing them concentrates weight on the clinical, outcome and survey measures where performance is harder to earn and cut points continue to rise. CMS's own analysis suggests most contracts would see no change in their overall rating, but more contracts would lose a half star than gain one.

At the same time, CMS estimates that keeping the historical reward factor and adopting the measure changes would increase Medicare Advantage payments by roughly $13 billion from 2028 through 2036. The net effect for any single contract depends on its measure profile, which is why contract-level modeling is essential before commenting.

The removal of SNP Care Management deserves particular attention. The measure tracks completion of health risk assessments for special needs plan members. Removing it from the ratings does not remove the regulatory obligation to complete HRAs and individualized care plans on time, and CMS program audits will continue to test those timeframes.

Other Notable Proposals

  • Risk adjustment request for information. CMS asks for input on alternatives to the current diagnosis-based model, including new data sources, approaches that rely less on diagnosis coding and the use of encounter data in model calibration. CMS also signals interest in reducing the lag between measurement and payment.
  • C-SNP scrutiny. A request for information addresses growth in dual-eligible enrollment in chronic condition SNPs rather than D-SNPs, and whether C-SNPs and institutional SNPs with high dual concentrations should need a contract with the state Medicaid agency.
  • D-SNP adjustments. Proposals revise passive enrollment rules and would codify loss of a state Medicaid agency contract as grounds for termination.
  • New special enrollment period. Members could change plans when a provider leaves the network, without CMS first deeming the network change significant.
  • Marketing rollbacks. Proposals would eliminate the 48-hour waiting period after a scope of appointment, allow marketing events to follow educational events and shorten retention of sales call recordings.
  • Health equity requirements. CMS proposes removing several health equity provisions, including the requirement for utilization management committees to conduct an annual health equity analysis of prior authorization.
  • Part D documentation. Plans would need standardized documentation supporting coverage determinations, retained in original format, with missing documentation treated as an improper finding in audits.

What to Watch and Comment On

  1. Model both reward scenarios. Quantify, by contract, the difference between the historical reward factor and the equity reward. That number belongs in your comment letter and your 2027 bid assumptions.
  2. Re-weight your quality portfolio. Simulate your overall ratings without the proposed removals. Measures that once provided a safe cushion may disappear, increasing reliance on adherence, intermediate outcome and survey measures.
  3. Prepare for depression screening. The new measure requires standardized instruments and documented follow-up within 30 days. Screening workflows and behavioral health referral capacity take time to build.
  4. Engage on risk adjustment. The request for information is an early signal. Plans and provider groups that depend on accurate diagnosis capture should explain how documentation quality and audit defensibility can coexist with any new model.
  5. SNP operators should comment specifically. If you operate C-SNPs with high dual enrollment, the integration questions could change your business model.
  6. Do not relax operational discipline. Measures leaving the ratings still reflect regulatory obligations. Appeals timeliness, call center access and HRA completion remain audit and compliance requirements.

How a Platform Approach Helps

Whatever the final rule looks like, the direction is clear: more weight on clinical outcomes and less on administrative performance. Curitics supports that shift by combining HEDIS gap tracking and closure, validated screenings within the Encounter Builder, AI-assisted care plans and patient-level CMS-HCC V28 RAF scoring with coder review that separates documented from inferred conditions, so quality and risk adjustment programs rest on the same defensible clinical record.

The comment period is short and overlaps with year-end operations. Organizations that run the numbers now will be in a stronger position to shape the final rule and to adjust strategy the moment it is published.