Two days ago, on January 26, 2026, CMS released the Advance Notice of methodological changes for Medicare Advantage and Part D payment for calendar year 2027. Most practice managers never read these. They are written for plans, they are long, and the final numbers do not arrive until April. This one deserves twenty minutes of your time, because two of the proposals change what MA plans will ask of your practice starting now.
The headline number is almost zero: CMS proposes to pay MA plans 0.09 percent more in 2027 than in 2026 before accounting for coding trend, a change CMS estimates at roughly $700 million across the program. Comments are due February 25, 2026, and the final Rate Announcement must be published by April 6, 2026. In past years the final number has moved from the proposal, sometimes substantially, so treat 0.09 percent as an opening position.
Key takeaways
- CMS proposes a 0.09 percent net payment update for MA plans in 2027, with comments due February 25 and the final Rate Announcement due by April 6, 2026.
- Diagnoses from audio-only encounters would no longer count toward risk scores, so plans will push for video and in-person visits with your MA patients this year.
- Unlinked chart reviews would be excluded too, which means more frequent, more specific record requests tied to individual dates of service.
- None of this changes what the plan pays you for an audio-only visit; it changes what CMS pays the plan, and the plan will try to make that your problem.
- A flat update plus expanded RADV audits means tighter contracting and closer scrutiny of your documentation in 2027; know your renewal dates now.
Proposal one: audio-only diagnoses no longer count
MA plans are paid partly on the basis of risk scores built from the diagnoses recorded for each enrollee. The Advance Notice proposes to exclude diagnoses captured during audio-only encounters from the risk score calculation. Video visits and in-person visits continue to count. CMS's reasoning is that an audio-only encounter is a less reliable basis for a diagnosis, and it has been signaling this direction for two years.
For a practice, the consequence is direct. MA plans that have been comfortable with telephone annual wellness visits and telephone follow-ups for chronic conditions will now want those patients seen in person or by video. Expect plan outreach asking your practice to convert telephone visits to video, expect the plan's care coordinators to push in-person annual visits harder, and expect the plan's quality and risk adjustment teams to ask why a patient with a documented condition in 2025 has no video or in-person encounter in 2026. None of this is the practice's regulatory obligation. It is the plan's business problem, and the plan will try to make it yours.
Our view: the practices that do well here are the ones that already schedule MA patients for an in-person or video annual wellness visit early in the year, document every chronic condition that was assessed at that visit, and code to the level of specificity the record supports. That is good medicine and good documentation regardless of the plan's risk score.
Proposal two: unlinked chart reviews are excluded
Plans have long supplemented claims data with chart reviews, in which the plan's vendor reads the medical record and submits additional diagnoses to CMS. A chart review is "linked" when it ties to a specific encounter that was also reported to CMS, and "unlinked" when it stands alone. The Advance Notice proposes to exclude unlinked chart review records from the risk score calculation. Plans can still submit them, but they will not add to payment.
The practical effect is more record requests, not fewer. Plans will want chart reviews tied to specific encounters, which means asking your practice for the note from a particular date of service rather than for the entire chart. Expect the requests to be more frequent and more specific. Set up a process for them: one point of contact, a turnaround commitment, and a log. Many MA contracts require the practice to provide records for risk adjustment purposes at no charge; check yours before invoicing.
It helps to be precise about what "linked" means from the practice side. A linked chart review points to an encounter the plan already has on file, usually your claim for a specific date of service, and adds or deletes diagnoses for that encounter based on what the note says. If your claim for the March 12 visit carried only the hypertension code but the note also documents that chronic kidney disease stage 3 was assessed and the plan was adjusted, the plan's reviewer can link a chart review to March 12 and add the CKD code. That works only if there is a claim for March 12 in the first place, and only if the note supports the diagnosis with an assessment, not a mention in the past medical history. So the practical consequences are two: bill every encounter, including the nurse visits and the video visits, and make sure the assessment and plan section names every chronic condition that was actually addressed.
The model itself is also updated
The Part C risk adjustment model stays on version 28, the version phased in over 2024 to 2026, but CMS proposes to recalibrate it using 2023 diagnoses and 2024 expenditures instead of the 2018 and 2019 data it was built on. Recalibration changes the coefficients, which is a quiet way of saying that some conditions will be worth more to the plan and some less, without anyone announcing a list. Including the expected growth in risk scores, CMS puts the average change in plan revenue at 2.54 percent, which is where the plans' own commentary will land. For a practice, the recalibration is not something to act on. It is something to know when a plan's risk adjustment team suddenly cares about a condition it never asked about before.
What else is in the notice
| Area | Proposal | Practice relevance |
|---|---|---|
| Payment update | 0.09 percent net before coding trend | Flat plan revenue tends to mean tighter provider contracting and benefit design in 2027 |
| Risk adjustment | Exclude audio-only diagnoses and unlinked chart reviews | More in-person and video visits requested; more encounter-specific record requests |
| Star Ratings | Methodology updates for measures and cut points | Plans will press harder on quality gaps that feed Star measures |
| Part D | Updated benefit parameters | Patient cost sharing for drugs changes; expect more prior authorization on the pharmacy side |
| Comment deadline | February 25, 2026 | Specialty societies will comment; practices rarely do |
The broader context: audits are expanding
The Advance Notice sits alongside a separate change CMS announced in May 2025: an expansion of risk adjustment data validation audits so that every eligible MA contract is audited each payment year, rather than a sample. RADV audits check whether the diagnoses a plan submitted are supported by the medical record. The record they check is yours. Plans facing more audit exposure will be more careful about what they submit and more demanding about what your documentation says. A diagnosis in the problem list that was not assessed at the visit is the kind of thing that fails an audit, and plans will start telling you so.
Our closing gaps in care service handles exactly the panel review and outreach described in the first two steps, and our coders review MA encounters for specificity as part of medical billing engagements. Practices that want to talk through their MA contracting position before the April Rate Announcement can book a call.
Questions we hear
Does the audio-only exclusion mean we cannot bill audio-only visits for MA patients?
No. It changes how the plan is paid by CMS, not what the plan pays you. Audio-only visits remain billable where the plan covers them. What changes is that the plan has less reason to encourage them and more reason to ask for video or in-person encounters.
Will MA plans cut our rates in 2027 because of the flat update?
It depends on the plan and your contract. A flat update after several years of tighter payment generally means plans look for savings, and provider rates are one place they look. Know your renewal date and your current rate relative to the Medicare fee schedule before the plan calls you.
Should our practice submit a comment?
Most practices will not, and that is understandable. If you do, the useful comment is a specific one: how many of your MA patients are homebound or rural and rely on telephone visits, and what an in-person or video requirement would mean for them. Specialty societies and the AMA will file long comments on the methodology; a two-paragraph letter from a practice with numbers in it is the kind CMS actually quotes. The docket is CMS-2026-0034 on the federal rulemaking portal, and the deadline is 11:59 p.m. Eastern on February 25.
What to do this month
- Pull your MA patient panel by plan and check how many had only telephone encounters in 2025. Those are the patients the plans will ask about.
- Schedule annual wellness visits for MA patients early in the year, in person or by video, and document each chronic condition assessed with its status.
- Assign a records request coordinator for MA plans and set a turnaround standard.
- Review your MA contracts for records request obligations and for any 2027 renewal dates; plans facing a flat update will negotiate harder.
- Ask your coding team to review diagnosis specificity on MA encounters, particularly for conditions that map to hierarchical condition categories.
- Decide by mid-February whether the practice will comment, and if so, who writes it.
