Spring Into 2025 - CMS Updates!

Diving into final rules published by CMS for MA/Part D in 2025.

This week’s newsletter is Sponsored By: Modivcare

Here is what you’ll find in this week’s newsletter!

  1. Important links 🔗 - the best articles we found this week about the Medicare Market along with links to Jared’s recent LinkedIn posts.

  2. Deep Dive 📚 - Spring Into 2025 - CMS Updates!

  3. Compliance Chatter 📢 - The “Final” Tri-Agency Rule provides new requirements.

  4. Sponsor Snapshot 🚀 - brought to you by Modivcare.

  5. Data Visual of the week 📊 - See how many Part D enrollees could potentially benefit from the out-of-pocket spending cap of $2,000 in 2025.

It’s only a 5 minute read, but it will make you 10x smarter.

Here are IMPORTANT LINKS 🔗 for the week:

  1. CMS caps broker payments in Medicare Advantage | Healthcare Dive - (link)

  2. Hackers claim to obtain CVS, Medicare data in Change hack (beckershospitalreview.com) - (link)

  3. Harvard-Inovalon Medicare Study: The Importance of Plan Design in Medicare Advantage - Inovalon - (link)

  4. Why the CMS’ Medicare Advantage rate is hurting stocks of Humana, UnitedHealth - MarketWatch - (link)

  5. Medicare Supplement Market Premium Grows in 2023 | CSG Actuarial - (link)

Jared’s recent LinkedIn posts:

  1. Who are the top Medicare Focused Public Companies - (link)

  2. MA Star Rating redesign info from Melissa Newton Smith - (link)

  3. MA enrollment grew ~10,400 during AEP in Nevada. Up 3.6% - (link)

  4. Why isn't higher utilization experienced by MA orgs reflected in the 2025 rates? - (link)

  5. Thoughts from Andrew Toy on CMS rate notice - (link)

DEEP DIVE 📚

Spring Into 2025 - CMS Updates!

Spring can be a crazy time….Spring sports, yardwork, planting a garden, getting the boat ready for the lake, and not to mention our day jobs of keeping up with the ever-changing Medicare landscape.

It’s not just us!  CMS has been busy over the past week, finalizing rules that will impact Medicare Advantage and Part D plans in 2025.

2025 MA/Part D Rate Announcement

On April 1st, CMS finalized the 2025 Medicare Advantage (MA) and Part D Rate Announcement.

Payments from the Medicare Program to MA plans are expected to increase by an average of 3.70%, with an increase of over $16 billion in expected MA payments from 2024 to 2025. This expected increase includes the different elements that impact MA payment:

  • growth rates of underlying costs;

  • 2024 Star Ratings for 2025 quality bonus payments;

  • continued phase-in of risk adjustment model updates; and

  • increases to risk scores.

According to the CMS Fact Sheet, under the policies finalized in the CY 2025 Rate Announcement, CMS anticipates adequate payment to MA and Part D plans to ensure stable premiums, benefits, and plan options for individuals for CY 2025.

The chart below indicates the expected impact of the policy changes and updates on MA plan payments relative to 2024.

Year-to-Year Percentage Change in Payment

Impact

2025 Advance Notice

2025 Rate Announcement

Effective Growth Rate

2.44%

2.33%

Rabasing/Re-pricing

TBD

0.07%

Change in Star Ratings

-0.15%

-0.11%

MA Coding Pattern Adjustment

0%

0%

Risk Model Revision and FFS Normalization

-2.45%

-2.45%

MA risk score trend

3.86%

3.86%

Expected Average Change in Revenue

+3.70%

+3.70%

Source: CMS 2025 Medicare Advantage and Part D Rate Announcement Fact Sheet

The full rate announcement can be found here.

MA/Part D Broker Compensation

On April 4, CMS finalized the long-awaited and contested policies (CMS-4205-F) concerning broker compensation. 

CMS is increasing the final national agent/broker fixed compensation amount for initial enrollments into a Medicare Advantage or Part D plan by $100 (50% for renewals), which is higher than what was proposed ($31). This increase will be added to agent and broker compensation payments for AEP in Fall 2024 and applied to all enrollments effective in CY2025. 

Source: Medicare Program; Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Program for Contract Year 2024--Remaining Provisions and Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-inclusive Care for the Elderly (PACE)

Also interesting to note, the final rule, including agent broker compensation rules at §422.2274(d), is limited to independent agents and brokers, and does not extend to TMPOs more generally or place limitations on payments from an MAO to a TPMO who is not an independent agent or broker for activities that are not undertaken as part of an enrollment by an independent agent or broker.

MA Supplemental Benefits

As part of CMS-4205-F, CMS is also implementing rules to improve supplemental benefits offered by plans.  Beginning January 1, 2026, all Medicare Advantage plans are required to issue a “Mid-Year Enrollee Notification of Unused Supplemental Benefits” annually, between June 30 and July 31 of the plan year, that:

  • is personalized to each enrollee;

  • includes a list of any supplemental benefits not accessed during the first six months of the year;

  • includes the scope of the benefit, cost-sharing, and instructions on how to access the benefit;

  • includes network application information for each available benefit; and

  • has a customer service number to call for additional help. 

Also starting in 2025, CMS is requiring MA plans to demonstrate with research that Special Supplemental Benefits for the Chronically Ill (SSBCI) items and services meet the legal threshold of having a reasonable expectation of improving the health or overall function of chronically ill enrollees.

Now that CMS has provided this guidance for 2025, it will be interesting to see how the plans adjust and react.  Keep watching for more updates as we get closer to Medicare AEP.  It will be here before we know it!

Sponsor Snapshot 🚀: Modivcare

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  • Transportation,

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  • Virtual & Remote Care Management,

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COMPLIANCE CHATTER 📢

This week’s newsletter is packed with tons of informative regulatory updates!  Here is another BIG update:

Back in February we shared information about Hospital Indemnity insurance, that is commonly used to supplement the benefits of Medicare Advantage or Medicare Supplement plans.

The Departments of Health and Human Services, Labor, and the Treasury just finalized the Tri-Agency Rule, providing new requirements for Fixed Indemnity, including Hospital Indemnity, and Short-Term, Limited-Duration (STLDI) insurance policies.  Read our recent blog detailing the final Tri-Agency Rule here.

If you would like to learn more about our compliance services, reach out to [email protected].

DATA VISUAL of the Week 📊

The data visual of the week comes from KFF’s article, “Millions of People with Medicare Will Benefit from the New Out-of-Pocket Drug Spending Cap Over Time,” showing how many Part D enrollees could potentially benefit from the out-of-pocket spending cap of $2,000 in 2025.

If you’re ready, here are some ways we can help you:

  • Newsletter Sponsorship opportunities: Promote your product or services to leaders in the Medicare space. Let’s discuss. (link)

  • Market Research: Reports that help you wrap your arms around the Senior focused insurance markets. (link)

  • Consulting: We can help you develop new insurance products for the Medicare market, appraise your books of business, and keep you compliant. Let’s discuss. (link)

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