AMGA Urges CMS to Protect Medicare Advantage’s Sustainability in 2026 Advance Notice

Alexandria, VA – AMGA today submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Advance Notice of Methodological Changes for Calendar Year 2026 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. Representing multispecialty medical groups and integrated delivery systems that care for one in three Americans, AMGA emphasized the importance of ensuring that the proposed changes support high-quality, value-based care while protecting access for vulnerable patient populations.

“Medicare Advantage can help providers deliver coordinated, patient-centered care, and CMS must ensure that proposed policy changes do not inadvertently disrupt care delivery,” said AMGA President and CEO Jerry Penso, MD, MBA. “We are particularly concerned about the impact of risk adjustment changes, the implementation of the Health Equity Index in Star Ratings, and the growing administrative burden of prior authorization.”

AMGA urged CMS to reconsider the shift from a three-year to a two-year rolling average for risk score trends, which could significantly reduce plan payments and ultimately impact provider reimbursement. AMGA also cautioned against frequent recalibration of the risk adjustment model without fully modeling its effects on care delivery.

AMGA supported CMS’ proposal to incorporate social risk factors into the Health Equity Index but emphasized the need for MA plans to collaborate with providers. Ensuring equitable care requires appropriate reimbursement structures, investments in data-sharing, and targeted support for high-need populations.

AMGA also reaffirmed the importance of flexible benefit design to address social risk factors and improve outcomes. However, AMGA raised concerns about prior authorization policies creating barriers to care, calling on CMS to reduce or eliminate restrictive requirements, rather than layering additional administrative burdens on providers.

The letter is available on AMGA’s website. 

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About AMGA

AMGA is a trade association leading the transformation of healthcare in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high-quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans. 

AMGA represents medical groups and integrated systems of care. Its diverse membership includes multispecialty medical groups, integrated delivery systems, accountable care organizations, and other entities committed to improving healthcare outcomes. AMGA advocates for the formation of innovative, clinically integrated systems of care that advance population health, enhance patient experience, and reduce healthcare costs. For more information, please visit www.amga.org.