A comprehensive commentary by the Medicare Rights Center on the Centers for Medicare & Medicaid Services (CMS) proposed rule for Contract Year 2026 (CMS–4208–P). The document outlines feedback and recommendations on changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and related policies. Topics include consumer protections, health equity, benefit transparency, drug affordability, and the integration of AI in healthcare services. This submission emphasizes safeguarding beneficiary access to affordable, equitable, and transparent healthcare.
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Our comments focus on the important proposals in support of formerly incarcerated individuals. We appreciate the Centers for Medicare & Medicaid Services (CMS) working to ensure Medicare payment and enrollment rules align with the lived experiences of this population and their responsibility for their own health care costs.
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As science and medicine progress, they reveal the interconnectedness of bodily systems and expose the folly of historic silos in care. We greatly appreciate the Centers for Medicare & Medicaid Services (CMS) focusing on mental health and substance use disorder treatment and to medically necessary dental services.
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Medicare Rights’ comments are informed by our work helping thousands of people with Medicare apply for Medicare Savings Programs (MSPs). As the Centers for Medicare & Medicaid Services (CMS) has documented, MSP processes are notoriously confusing for applicants, as well as many advocates and eligibility workers.
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Consolidation and market concentration impact many aspects of the U.S. health care system. Our response to the RFI focuses on the consequences for Medicare and its enrollees. We discuss opportunities for policymakers to better protect older adults, people with disabilities, and the range of public programs that support their access to care.
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It is evident Medicare Advantage (MA) enrollment and costs are growing, that access issues abound, and that transparency is long overdue. To ensure MA works well for those it is supposed to serve, the Medicare Rights Center urges the immediate and thorough collection and publication of additional data on (I) Equity, (II) Provider Directories and Networks, (III) Marketing, (IV) Utilization Management and Appeals, (V) Supplemental Benefits, (VI) Dually Eligible Individuals and D-SNPs, and (VII) Favorable Selection and Risk Adjustment. This information should be granular, regularly reported, and used to guide MA and program-wide improvements. CMS must finally hold plans accountable for the public dollars they use and the promises they make.
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The Medicare Rights Center welcomes CMS’s efforts to refine Medicare Advantage payment methodology and supports further action to improve costs and the beneficiary experience, program wide.
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The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Proposed Rescission of the 2018 Association Health Plan Final Rule. We applaud this full rescission of the final 2018 Association Health Plan (AHP) rule. Though the rule was never fully implemented, this rescission will eliminate any uncertainty regarding applicable definitions and standards.
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The Medicare Rights Center commented on the 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 proposed rule.
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Medicare Rights comments on medically necessary dental and mental health and substance use disorder provisions in the 2024 Physician Fee Schedule.
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