The author submitted the comment letter to the Centers on Medicare and Medicaid Services on January 24, 2025.
Matthew Fiedler commented on policy changes to Medicare Advantage (MA) and Part D proposed by the Centers for Medicare and Medicaid Services (CMS) for the 2026 plan year. His letter made two comments on CMS proposals related to MA Medical Loss Ratio (MLR) requirements: (1) requiring MA plans to report claims spending disaggregated by type of payment arrangement would fill a major data gap, but barring public release of these data would reduce their value; and (2) barring MA plans from counting certain incentive and bonus arrangements in the MLR numerator would likely do little to address CMS’ MLR gaming concerns but could create unnecessary administrative burdens.
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Acknowledgements and disclosures
The author thanks Richard Frank for helpful comments, Yihan Shi for research assistance, and Rasa Siniakovas for editorial assistance.
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Commentary
Matthew Fiedler’s comments on the proposed 2026 Medicare Advantage and Part D rule
January 30, 2025