Weekly Roundup -
February 25, 2026
Smart. Strategic. Essential.
Unmatched Healthcare Insights from 黑料不打烊,
Leavitt Partners & Wakely.
Featured:
Webinar Replay – Proposed ACA 2027 Notice of Benefit and Payment Parameters: Implications for Issuers and States
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Outlook 2026: Medicare Advantage Advance Notice鈥擶hat It Means for the 2027 Market
In this conversation,听Andrea Maresca, Senior Principal at 黑料不打烊听(黑料不打烊), caught up with听,听Director,听Wakely, and听, Co-Founder & Managing Partner at Health Transformation Strategies, LLC, to unpack the biggest questions emerging from the Calendar Year (CY) 2027 Medicare Advantage (MA) and Part D Advance Notice. Of particular interest was the Centers for Medicare & Medicaid Services鈥檚 (CMS鈥檚) proposed risk adjustment and diagnosis source changes, which are drawing significant attention across the industry.听
Q:听The headline is 鈥渇lat鈥� payments. How should the market interpret CMS鈥檚听projected rate change?听
Tim Courtney:听CMS听听a net average payment change of just +0.09听percent听for CY 2027鈥攁bout $700听million (M).听The effective growth rate is about 4.97听percent, but it鈥檚 largely offset by risk model and normalization changes and the proposed diagnosis听source policy.听
Jon Blum:听Exactly.听It鈥檚听important to note that CMS鈥檚听impact projections are听based听on the change听in听its average payments. Its proposed policies will have much more far-reaching distributional impacts, depending on the diagnoses of their enrolled members. At the same time CMS recently proposed changes to its听Star听Ratings听methodologies. Over time, we could see quite significant changes to the balance of Medicare Advantage payments distributed across the country that could significantly affect benefit offerings and premium amounts.听
Q:听What鈥檚听most surprising in the Advance Notice听for 2027?听
Blum:听The diagnosis听source tightening is the big one. CMS proposes excluding diagnoses from 鈥渦nlinked Chart Review Records鈥� from risk score calculation starting in CY 2027. That signals a continued听progression by the agency听toward encounter-anchored data integrity.听Assuming this policy is finalized,听Medicare Advantage plans听must听continue to听invest in systems to respond to CMS鈥檚 program integrity focus.听
Courtney:听And it鈥檚 not only chart review.听CMS also proposes excluding diagnoses from audio-only services for Part C and similarly for Part D. Operationally, that鈥檚 a big deal. Plans need to understand where diagnoses originate, how they鈥檙e supported, and what the downstream听risk adjustment factor (RAF)听impact looks like by segment and provider channel.听
Q:听The听Wakely听team听estimates a different 鈥渇eel鈥� than CMS鈥檚听topline. What does Wakely鈥檚 analysis add?听
Courtney:听听helps translate CMS components into听both听benchmark and听plan payment change.听
Blum: This point is really key. Wakely鈥檚 analysis flags that rebasing/repricing impacts aren鈥檛 fully reflected yet, which means county-level outcomes can diverge materially once the final Rate Announcement is released. The rebasing could be particularly volatile this year as CMS adjusts for rural emergency hospital payments and the removal of anomalous and suspect DME claims. Both adjustments vary by geographic area.听
Q:听How should plans think about bid strategy and benefit pressure for 2027?听
Courtney:听The tighter risk adjustment environment could squeeze rebates and supplemental benefit richness鈥攅specially if bids听don鈥檛听adjust quickly. Wakely estimates risk-adjusted bid听and听rebate听revenue听is听down听roughly听0.35听percent听under a set of simplifying assumptions, underscoring the margin sensitivity.听
Practically this means plans should run a few scenarios: 1) RAF compression from diagnosis source changes, 2) normalization updates, and 3) Star-related shifts鈥攅ven if the Star change is estimated to be small nationally.听
Blum: I鈥檇 add provider contracting and clinical program return on investment (ROI) will likely be an even greater focus for Medicare Advantage plans. When risk score lift is constrained, the value of medical cost management and quality performance becomes more important. We have seen tremendous pushback by healthcare providers over the greater use of prior authorization, with some major health systems dropping their contracts with Medicare Advantage plans altogether. Medicare Advantage plans will have to carefully balance the need to reduce medical expenditures and maintain their provider networks to attract enrollment. Establishing strong partnerships with provider systems will be more important than ever.听
Q:听What听do plans听need most right now?听
Courtney:听This is where integrated strategy and actuarial and policy听expertise听really听matter.听黑料不打烊 is supporting stakeholders with payment impact modeling, scenario analysis, and advisory services tied to benchmark rebasing, risk adjustment, Star Ratings,听product strategy,听and Part D payment policy, so clients can translate the Notice into concrete bid and operating decisions.听
From Wakely鈥檚 side, the detailed benchmarking and methodology interpretation helps clients quantify what CMS鈥檚 technical updates mean in dollar terms and across geographies.听
The CY 2027 Advance Notice is听also听a reminder听that听average听impacts hide听portfolio听impacts. The plans that model 鈥渨here the change hits鈥� (diagnosis sources, provider channels, county mix, Stars trajectory) will be best positioned heading into April鈥檚 final Rate Announcement.听
Blum: And from a policy lens, plans need to connect the dots. CMS鈥檚 proposed rate notice is both an articulation of its current priorities and continued progression toward more payment accuracy, encounter-linked data, and program integrity. Medicare Advantage plans should be both prepared to operationalize these policies and to work with the agency to ensure its policies better serve Medicare beneficiaries.听
Medicare Advantage plan听leaders听will be听those听organizations that operationalize听these听policy directions听early, constructively engage in the policy process, and form far stronger partnerships with health care providers.听
You can find more insights on听the听important proposed changes in plan payments, risk adjustment,听and other financial and regulatory requirements for 2027 in Wakely鈥檚 summary analysis,听.听
2027 NBPP Proposed Rule Signals Further Marketplace Changes
The Centers for Medicare & Medicaid Services听(CMS)听听proposed rule,听published February 11, 2026,听arrived听at a pivotal moment for the听Affordable Care Act (ACA)听Marketplaces. The temporary enhanced premium tax credits (ePTCs), first expanded in 2021听and听extended through 2025, expired at the end of last year, returning Marketplace subsidies to their original ACA structure in 2026.听As we discussed in earlier articles听(here听and听here), that shift is already affecting affordability, plan selection, and enrollment dynamics鈥攑articularly for consumers who听are ineligible听for听premium assistance.听
The proposed 2027 NBPP represents a significant reset for the Marketplace, reflecting CMS vision and policy priorities to strengthen program integrity while expanding plan design flexibility and consumer choice as a pathway to affordability, as well as policies to defer to state authority. Healthcare organizations and other interested stakeholders may submit comments on the proposed rule through March 13, 2026.听
The听remainder听of this article addresses the key policy proposals and听considerations for issuers, states, and consumer groups.听
CMS鈥檚听Proposals听
The proposed NBPP听for 2027听sets听standards for the Exchanges and ACA-compliant individual and small group markets and updates听payment parameters for risk adjustment and risk adjustment data validation听(RADV). The rule also implements changes听approved under the听, (P.L. 119-21, OBBBA) and includes a range of policies spanning plan certification, eligibility and verification, and Exchange oversight.听
Expanded听Plan听Design听Flexibility听
CMS proposes to discontinue standardized plan options in the Federally-facilitated Marketplace (FFM) and remove limits on the number of non-standardized plans offered by issuers on the FFM and state-based Marketplaces on the federal platform (SBE-FPs). Issuers would be permitted to decide whether to discontinue existing standardized or chronic condition plans or continue them with modified cost sharing.听
Considerations:听This change is听designed听to allow greater innovation in plan design.听It also听raises questions听about听the potential return of a more complex Marketplace shopping experience听for consumers听who will have to shift through more plans.听
Certification of听Non-Network QHPs听
One of the most consequential proposals would allow听鈥�non-network鈥� plans to be certified as qualified health plans beginning in 2027. These plans would not rely on contracted provider networks. Instead, they would set benefit payment amounts and require issuers to demonstrate that sufficient providers鈥攊ncluding Essential Community Providers (ECPs) and mental health and substance use disorder providers鈥攁re willing to accept those amounts as payment in full.听
Considerations:听CMS positions non-network plans as a way to create lower听premium options.听For states and issuers,听this proposal introduces new oversight and operational considerations related to access standards, consumer protections, the risk of balance billing or access gaps听for consumers, and potential market instability.听
Changes in听Catastrophic and Bronze听Cost听Sharing听
The proposed rule would further expand access to catastrophic plans by codifying hardship exemptions for individuals ineligible for advance premium tax credits (APTCs) or cost-sharing reductions (CSRs) because of projected income. CMS also proposes to allow multiyear catastrophic plans with contract terms of up to 10 consecutive years. In addition, CMS proposes new flexibility for certain bronze plan designs in the individual market. In both cases, CMS proposes to allow catastrophic and bronze plans to exceed the annual maximum out-of-pocket limit.听
Consideration:听These policies reflect听CMS鈥檚听emphasis on affordability through lower premiums and expanded consumer choice, while shifting more financial risk to enrollees through higher cost听sharing.听
Network听Adequacy and Essential Community Providers听
CMS proposes to give states greater discretion in provider access for network adequacy and ECP certification reviews, including allowing federally funded exchange (FFE) states to conduct their own reviews if CMS determines they have sufficient authority and technical capacity. CMS also proposes to reduce the minimum percentage of ECPs that issuers must include in their networks from 35 percent to 20 percent.听
Considerations: These changes reduce federal prescriptiveness and could lower issuer compliance costs but also place more responsibility on states to monitor access and ensure that vulnerable populations are not adversely affected.听
Essential Health Benefits and听State听Mandates听
The proposed rule would prohibit issuers from including routine non-pediatric (adult) dental services as an Essential Health听Benefit听(EHB). More significantly for states, CMS proposes changes to cost听defrayal requirements for state-mandated benefits, requiring states to听cover听the cost of benefits considered 鈥渋n addition to EHB鈥� under specified criteria,听even if those benefits are embedded in the state鈥檚 EHB benchmark plan.听
Consideration: These changes could have direct budgetary implications for states, pricing implications for issuers, and could stunt or potentially decrease benefits for consumers.听
Program听Integrity and听Increased听Eligibility听Verification听
CMS includes a robust set of program integrity provisions, including:听
- Strengthened听standards for agent, broker, and web听broker marketing practices听
- Required use of a听US听Department of Health and Human Services (HHS)-approved consumer consent and application review form听
- Codification of听听policies听and reintroduction of听听provisions听not听previously听implemented,听including听expanded special enrollment period (SEP) verification听and听increased eligibility standards for enrollees applying for APTCs听(see听Navigating CMS鈥檚 2025 Marketplace Rule: What It Means for ACA Marketplaces, Insurers, and Consumers)听
- Implementation of the State Exchange Improper Payment Measurement (SEIPM) program for state-based Marketplaces听
Consideration: These policies continue CMS鈥檚 heightened scrutiny of enrollment activity and subsidy eligibility. CMS鈥檚 policies are likely to increase data matching issues (DMIs), which could increase burden on Marketplaces and enrollees, resulting in reduced enrollment.听
Preparing for听Policy Driven Changes in ACA Marketplaces听
The 2027 NBPP underscores a clear policy shift听away from extending听federal subsidies听toward听advancing a Marketplace framework that emphasizes program integrity, state flexibility, and expanded plan design options as mechanisms to promote affordability and consumer choice.听
The proposed rule sets the stage for significant strategic and operational decisions听for听issuers and states听ahead of the 2027 plan year.听黑料不打烊听(黑料不打烊), including Wakely, an听黑料不打烊 company,听works with issuers modeling enrollment and risk shifts听and to听assist in pricing decisions.听States also should consider the need for new strategies and approaches to adapt to federal policy changes that are expected for ACA Marketplace programs.听
For more information about the policies described鈥痠n this article, support with scenario-based modeling of enrollment and data-informed strategy development for 2027 and beyond, please contact鈥痮ur experts ,听Lina Rashid,听or听Zach Sherman.听
Federal Policy News
Fueled By Weekly Health Intelligence
Healthcare Priorities Take Center Stage in 2026 State of the Union
On Tuesday, February 24, 2026, President Trump delivered the 2026 State of the Union (SOTU) address before a joint session of Congress. Among鈥痭umerous鈥痮ther issues, the speech highlighted a few of the Administration鈥檚 major healthcare priorities, with a particular emphasis on reducing prescription drug costs and increasing transparency, in keeping with the鈥�鈥�鈥痓y the White House last month.听
The address also called for continued efforts to shore up program integrity, including through a 鈥渨ar on fraud鈥� led by Vice President Vance. With respect to entitlements, President Trump echoed his听previous听assurance that 鈥淸w]e will always protect Social Security and Medicare.鈥�听
While some of the healthcare policies outlined in the speech would require Congressional action, such as restructuring enhanced Affordable Care Act (ACA) insurance subsidies or codifying most-favored-nation (MFN) drug pricing changes, other components, such as the Administration鈥檚 TrumpRx site for direct-to-consumer (DTC) medication sales, have progressed without legislation.听
Other portions of the SOTU address, such as the president鈥檚 discussion of immigration policy, proved contentious, but the healthcare priorities highlighted in the speech听largely aligned听with听previous听statements and proposals from the White House, rather than pivoting or straying from expectations.
FDA Signals Shift Toward Flexible Approval Pathways During Rare Disease Week
In the past week, there has been a flurry of activity from the Hill and Administration focused on the US Food and Drug Administration鈥檚 (FDA) ability to review and approve new cures efficiently and effectively, with a particular focus on therapies aimed at treating rare and ultra-rare diseases, in light of Rare Disease Week, which began February 23, 2026.听
Tuesday morning, February 24, 2026, FDA and HHS held an announcing the launch of FDA鈥檚 new framework for accelerating the development of individualized therapies targeting specific genetic conditions, which the agency articulated in 听from the Center for Biologics Evaluation and Research (CBER) and Center for Drug Evaluation and Research (CDER). The guidance, titled, 鈥淐onsiderations for the use of the Plausible Mechanism Framework to Develop Individualized Therapies that Target Specific Genetic Conditions with Known Biological Cause,鈥� provides recommendations in line with the 鈥淧lausible Mechanism鈥� concept that FDA Commissioner Marty Makary and CBER Director Vinay Prasad had previously听听in a November NEJM article.听The Plausible Mechanism framework proposed in the draft guidance is intended to be applied for individualized, mutation-specific therapies where traditional randomized trials are infeasible, such that after manufacturers demonstrate success across several consecutive patients, FDA may approve a treatment and rely on post market, real-world evidence to monitor durability, off-target effects, and safety.听
The pair also recently co-authored an NEJM听听titled, 鈥淥ne Pivotal Trial, the New Default Option for FDA Approval 鈥� Ending the Two-Trial Dogma,鈥� which details the leaders鈥� plans for the FDA鈥檚 new 鈥渄efault position鈥� that 鈥渙ne adequate and well-controlled study, combined with confirmatory evidence, will serve as the basis of marketing authorization of novel products,鈥� rather than two studies. In the article, Dr. Makary and Dr. Prasad acknowledge that FDA has previously granted approvals based on a single premarket study, and that in some fields, the agency has granted approval for听the majority of听drugs based on a single trial. However, they express concern that听maintaining听a default听option听of two trials 鈥渁nchor[s] individuals and institutions psychologically,鈥� and hypothesize that articulating a new default of one trial will provide clarity and 鈥渟pur biomedical innovation.鈥� The authors go on to note that the agency may still听require听multiple studies if听deemed听appropriate.听
The recent activity from FDA is indicative of continued interest in providing regulatory flexibility and clarity to medical product developers and manufacturers but comes as the agency faces scrutiny from stakeholders and members of Congress over a perceived lack of transparency and dependability in their regulatory decision-making.听
This includes a released by Senate HELP Committee Chair Bill Cassidy last week, proposing legislative and regulatory recommendations which the Committee contends would modernize FDA approval and product oversight processes and enhance patient access and safety. The report asserts that, despite major advances in personalized medicine, AI-enabled tools, and the growth of generics and biosimilars, innovation does not benefit patients if FDA processes function as an unpredictable 鈥渂lack box鈥濃�攊ncluding what stakeholders describe as a 鈥渞eviewer lottery鈥� that can drive inconsistent expectations and delays. Senator Cassidy鈥檚 report proposes reforms across drugs, biologics, and devices. Such reforms include extending 鈥渓east burdensome鈥� principles beyond devices; piloting a notification-style pathway for Phase I trials to build incentives for early research to stay within the U.S.; expanding standards for decentralized trials and real鈥憌orld evidence; and adopting AI to streamline review processes. Chair Cassidy鈥檚 report also calls for creating an intermediate pathway for biologics and biosimilars that would be modeled on the existing 505(b)(2) intermediate small molecule drug pathway, reducing delays to generic competition, enhancing transparency in FDA鈥檚 handling of clinical holds, and tightening FDA Human Foods Program and ingredient safety oversight (including Generally Recognized as Safe (GRAS) review requirements). The report from Chair Cassidy did not outline next steps for legislative and regulatory reforms but notes the 鈥淐ommittee looks forward to coordinating with FDA鈥� to implement the recommendations.听
Shifting Leadership at CDC as ACIP Meeting Is Canceled
On February 18,听National Institutes of Health (NIH)听Director Jay Bhattacharya was听 as the new acting director of the Centers for Disease Control and Prevention (CDC), following the departure of the previous acting director, HHS Deputy Secretary Jim O鈥橬eill. Mr. O鈥橬eill has 听been selected by the White House as the nominee for National Science Foundation Director. Mr. O鈥橬eill has led CDC in an acting capacity since then-Director Dr. Susan Monarez was dismissed from the post in August.听The Senate has still not received a nomination from the White House to fill the vacancy left by Dr. Monarez.听An executive branch 鈥渁dvise and consent鈥澨�, a role appointed by the President and confirmed by the Senate, may be filled by temporary appointment under the Vacancies Act for up to听210 days听after the date the vacancy occurred; however, the acting officer can continue to serve in the role without restriction if a nomination for the position has been submitted to the Senate for consideration.听
Further, on February 23, the CDC听 that Principal Deputy Director Dr. Ralph Abraham had stepped down from his role, effective immediately.听He started in the role on January 5, 2026. As Principal Deputy Director, Dr. Abraham was the most senior permanent official at the CDC, and the most senior official with a consistent presence at the CDC campus in Atlanta.听
Amidst the changes to leadership, last week CDC also confirmed that it would not hold the Advisory Committee on Immunization Practices (ACIP) meeting that had been scheduled from February 25鈥�27. CDC had failed to meet the statutory deadline by which to share the agenda planned for the meeting in the Federal Register.听On the听, the February meetings have been removed from the schedule altogether, with no set rescheduled date.听
FDA Review Back on Track for Moderna鈥檚 mRNA Influenza Candidate
On February 18, FDA听听Moderna鈥檚 biologics license application (BLA) for review of its investigational seasonal influenza vaccine candidate, mRNA-1010, and assigned a Prescription Drug User Fee Act (PDUFA) goal date of August 5. The acceptance follows a Type A meeting between Moderna and FDA鈥檚 Center for Biologics Evaluation and Research (CBER) after the agency previously issued a听 letter for the application. To advance the review, Moderna proposed a revised regulatory pathway seeking traditional approval for adults aged 50 to 64 and 听for adults 65 and older. Pending FDA approval, mRNA-1010 would be available for U.S. adults aged 50 years or older for the 2026/2027 flu season. The vaccine has also been accepted for review in Europe, Canada, and Australia, with Moderna expecting the first potential approvals later in 2026.听
In response to reports that听stated听FDA had 鈥渞eversed鈥� its position on the BLA due to pressure from the White House, HHS posted on听听stating, 鈥淲RONG. The sponsor returned to鈥�听with听additional听information鈥痑nd pending approval鈥痠s committed to a study of older adults using a proper control group.鈥�听
OIG Expands CMS Audit Agenda with Medicaid and Part D Reviews
On February 17,听the Office of the Inspector General (OIG) for the US Department of Health and Human Services (HHS)听 four new听Centers for Medicare & Medicaid Services-focused, in-progress projects added to its Work Plan.听The OIG Work Plan outlines audits and evaluations underway or planned for the current fiscal year (FY) and beyond. The newly announced projects, which have estimated completion dates in FY 2028, include:听
- 听This audit will examine the use of听, as opposed to general funds, by selected states to finance their share of Medicaid expenditures. The data brief will also听identify听state-funded healthcare programs that provide services beyond emergency Medicaid coverage to individuals who do not meet Medicaid eligibility requirements.听
- 听As required under Section 3313 of the Affordable Care Act (ACA), OIG will conduct its annual study examining the extent to which Medicare Part D plan formularies include drugs commonly used by dual eligible enrollees, who are enrolled in both Medicare and Medicaid.听
- 听This audit will assess whether selected state agencies ensured that nursing homes听complied with听federal and state pharmacy service requirements to prevent the overuse of opioids among residents, as well as whether nursing homes implemented effective internal controls to prevent misuse or diversion of opioids.听
听This audit will听determine听whether state Medicaid agencies properly claimed services for American Indians and Alaska Natives (AI/ANs) at the enhanced 100 percent Federal Medical Assistance Percentage (FMAP) rate.听
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State Policy News
Arkansas
Arkansas to Soft Launch Medicaid Work Requirement Checks Ahead of 2027 Enforcement. The Arkansas Advocate鈥�鈥痮n February 20, 2026, that Arkansas will begin a 鈥渟oft launch鈥� of Medicaid work requirement checks in July 2026 to test verification systems ahead of enforcement in January 2027. Using existing wage data and information from the Supplemental Nutrition Assistance Program (SNAP), the state will notify beneficiaries enrolled in the Arkansas Health and Opportunity for Me (ARHOME) Medicaid expansion program whether they appear to meet the upcoming requirement of 80 monthly hours of work or qualifying activities, while offering outreach and call center support.听
Connecticut
Connecticut FQHCs Seek State Action to Offset Coverage Losses from Federal Medicaid Changes. CT News Junkie鈥�鈥痮n February 20, 2026, that Connecticut federally qualified health centers (FQHCs) are urging state lawmakers to streamline Medicaid enrollment to prevent procedural disenrollments, fully implement reimbursement for community health worker services, and stabilize the healthcare workforce to reduce anticipated听coverage losses resulting from federal policy changes. State leaders are also evaluating longer-term coverage solutions, including a Basic Health Program, as federal changes are expected to increase uninsured rates and strain safety-net providers.听
Missouri
Missouri House Advances Constitutional Amendment for Medicaid Work Requirements. KY3鈥�鈥痮n February 23, 2026, that the Missouri House approved legislation that would ask voters to amend the state constitution to require most Medicaid recipients to complete听80 hours听per month of work, volunteering, or education to听maintain听coverage. The proposal, modeled on upcoming federal Medicaid work requirements set to begin in 2027, would permanently embed the policy in state law if approved by the Senate and voters in November.听
Nevada
Nevada Health Policy Activity Accelerates Across Medicaid and Medicare Programs. Nevada continues to advance听several听health policy initiatives across its publicly financed coverage programs, with several developments听unfolding on听parallel tracks.听On February 20, 2026, the Nevada Health Authority issued guidance reinforcing provider compliance expectations under the state鈥檚 Battle Born State Plan (BBSP) public听option. Specifically, this听guidance reminds Medicaid managed care organizations (MCOs) that, under BBSP public听option听requirements, providers听participating听in Medicaid networks must contract with at least one BBSP plan as a condition of participation. Although the state has temporarily waived enforcement of this requirement for calendar year 2026 to ensure beneficiary access during the public听option鈥檚听rollout, MCOs are expected to actively prepare their networks for full compliance. This includes updating provider contracts, educating providers about BBSP participation requirements,听assisting听with enrollment, and conducting outreach to providers that are not yet compliant. Nevada Medicaid has听indicated听it will support these efforts through direct outreach and by听identifying听non-compliant providers, with enforcement听anticipated听to begin January 1, 2027.听
The state is also听restructuring听its approach to听care听coordination for听Medicare and听Medicaid听dually eligible beneficiaries.听On February 20,听the state announced听it had received eight proposals in response to听its听听for the听state announced the听health plans competing for its new Coordination Only Dual Eligible Special Needs Plan (CO D-SNP) contracts:听United/Sierra Health, Centene/WellCare, Elevance, Humana, CVS/Aetna, Alignment Health, Devoted Health, and Prominence Health Plan. Nevada plans to issue a notice of intent to award on March 4, 2026, with final awards expected by May 12, 2026. The four-year contracts, which include two optional one-year renewals, are scheduled to begin January 1, 2027.听
Wisconsin
Wisconsin Legislature Votes to Extend Medicaid Postpartum Coverage. The Associated Press鈥�鈥痮n February 19, 2026,听that听the Wisconsin Assembly voted 95-1 to pass a bipartisan bill that will extend Medicaid postpartum coverage from听60 days听to one year. Once signed by the governor, Arkansas will remain the only state that does not offer extended postpartum coverage.听
Private Market News
Fueled By
Unprecedented Spike in Plan Exits Threatens Medicare Advantage Stability
The听听included an article听covering a new听听study听regarding听Medicare Advantage听(MA)听听beneficiaries. According to the study, MA beneficiaries听face forced disenrollment in 2026 as plan exits drive coverage termination, pushing millions toward traditional Medicare and Part D鈥檚 $2100 cap,听Medicare Advantage is seeing a sharp rise in 鈥渇orced disenrollment鈥� in 2026 of about 10% of enrollees (~2.9 million people) as insurers exit plans or markets. This is up from听roughly 1%听on average in 2018-2024 and ~6.9% in 2025. This disruption is expected to hit non-SNP and PPO members especially hard and be disproportionately felt in rural areas, raising concerns about care continuity and plan stability.听
Our Insights
Fueled By Experts Across Our 黑料不打烊 Companies
黑料不打烊
Webinar: Proposed ACA 2027 Notice of Benefit and Payment Parameters: Implications for Issuers and States
This听webinar听offers听a timely, strategic overview of the recently released proposed 2027 Notice of Benefit and Payment Parameters and what it signals for the evolving coverage landscape. We will unpack the key policy changes, operational requirements, and market assumptions embedded in the rule, with a focus on implications for the individual and small group markets beginning in 2026 and extending beyond.
Wakely
黑料不打烊 and Wakely Report: Summary of Provisions in HHS鈥檚 Proposed 2027 Notice of Benefit and Payment Parameters and Other Key Regulations
On February 9, 2026, the Department of Health and Human Services (HHS) released the proposed Notice of Benefit and Payment Parameters (proposed Payment Notice) for 2027. The notice includes important proposed rules and parameters for the operation of the individual and small group health insurance markets in 2026 and beyond. This paper summarizes key provisions of the proposed notice and maximum out of pocket information recently released by HHS.
Webinar: PACE: Advance Notice Review
On February 26, experts from Wakely will听be听reviewing changes to the PACE program announced in the recent鈥�2027 Medicare Advantage and Part D Advance Notice. Primary amongst these changes, the risk adjustment model transition for PACE programs from the legacy Risk Adjustment Processing System (RAPS) to the encounter data system (EDS) is accelerating to a 50/50 weighting in 2027.鈥� The webinar will also review how the commonly quoted Effective Growth Rate translates to PACE plan Medicare revenue in 2027. Finally, the webinar will discuss how all of the model changes coming to the Medicare Part D program affect PACE plans. How will these changes impact your organization’s bottom line? Tune in to learn more.听
Weight of the Matter 鈥� Obesity鈥檚 Financial Impact in Medicare Populations
Among Medicare-aged individuals, obesity is strongly associated with chronic conditions such as diabetes, cardiovascular听disease听and musculoskeletal disorders, all of which increase healthcare听utilization听and spending. As costs continue to rise, understanding the听financial impact听of obesity management is increasingly important for policymakers,听payers听and providers.听This analysis uses detailed traditional Medicare claims and eligibility data to examine how obesity levels relate to healthcare expenditures and how costs change as members move between different diagnosed obesity categories over time.听
Save the Date: October 5-7 | New Orleans
黑料不打烊 Conference: U.S. Healthcare 2026 鈥� Signals, Signs & Flashing Lights
RFP Calendar
RFP Calendar
| Date | State/Program | Event | Beneficiaries |
|---|---|---|---|
| Date: February 2026 | State/Program: Illinois | Event: Awards | Beneficiaries: 2,400,000 |
| Date: March 20, 2026 | State/Program: Hawaii Community Care Services | Event: Proposals Due | Beneficiaries: 5,500 |
| Date: April 10, 2026 | State/Program: Hawaii Community Care Services | Event: Awards | Beneficiaries: 5,500 |
| Date: May 1, 2026 | State/Program: Nevada Children's Specialty | Event: Proposals Due | Beneficiaries: NA |
| Date: May 12, 2026 | State/Program: Nevada CO D-SNP | Event: Awards | Beneficiaries: 88,000 |
| Date: June 24, 2026 | State/Program: Wisconsin LTC GSR 3 | Event: Awards | Beneficiaries: 56,000 (all GSR) |
| Date: July 1, 2026 | State/Program: Hawaii Community Care Services | Event: Implementation | Beneficiaries: 5,500 |
| Date: July 28, 2026 | State/Program: Nevada Children's Specialty | Event: Awards | Beneficiaries: NA |
| Date: August 2026 | State/Program: Indiana | Event: RFP Release | Beneficiaries: 1,400,000 |
| Date: January 1, 2027 | State/Program: Illinois | Event: Implementation | Beneficiaries: 2,400,000 |
| Date: January 1, 2027 | State/Program: Nevada CO D-SNP | Event: Implementation | Beneficiaries: 88,000 |
| Date: January 1, 2027 | State/Program: Wisconsin LTC GSR 3 | Event: Implementation | Beneficiaries: 56,000 (all GSR) |
| Date: January 1, 2027 | State/Program: Illinois Tailored Care Management Program | Event: Implementation | Beneficiaries: 22,400 |
| Date: July 1, 2027 | State/Program: Nevada Children's Specialty | Event: Implementation | Beneficiaries: NA |
| Date: January 1, 2028 | State/Program: Wisconsin LTC GSR 4,6 | Event: Implementation | Beneficiaries: 56,000 (all GSR) |
| Date: Fall 2027 | State/Program: Oregon | Event: RFP Release | Beneficiaries: 1,200,000 |
| Date: 2028 | State/Program: North Carolina | Event: RFP Release | Beneficiaries: 2,200,000 |
| Date: 2029 | State/Program: California | Event: RFP Release | Beneficiaries: NA |