Wakely Wire

New Insights

Whitepapers, briefs, press releases and more

Wakely Summary: Advance Notice of Methodological Changes for CY 2027 MA Capitation Rates and Part C and Part D Payment Policies

The Centers for Medicare & Medicaid Services (CMS) recently released the 2027 Advance Notice of Methodological Changes for Medicare Advantage Capitation Rates and Part C/D Payment Policies, which proposes important changes in plan payments, risk adjustment and other financial and regulatory requirements for 2027. Wakely summarizes key changes that will affect Medicare Advantage pricing for ... Continue reading

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2025 Individual Market Risk Pool Considerations Updated

This paper updates a prior paper on 2025 Individual market risk pool considerations. This updated version of the paper includes data through October 2025. Results indicate an overall increase in normalized relative risk in 2025 from 2024. Related Resources:

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ACCESS Model Implications for Care Management Vendors

Historically, Medicare has facilitated payments for services primarily supporting in-person care. These payments are tied to a specific set of Medicare-reimbursable procedures, which have provided limited coverage for remote patient monitoring, care coordination, and longitudinal management activities. As a result, providers have faced structural disincentives to adopt technology-enabled care models, creating barriers to continuous monitoring ... Continue reading

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Week in Washington – 2/5/26

Budget Bill Congress passed a budget bill this week to end a short-term partial government shutdown. The budget bill funds most of the federal government agencies through the end of the fiscal year. The exception is the Department of Homeland Security (DHS), which only received a 2-week extension. Negotiations are expected to continue and if ... Continue reading

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Events & More

CMMI’s GUARD Model: Drug Scope, Geographic Design, and Implications for Medicare Part D Plans

WAKELY WEBINAR
February 11, 2026 | 1 PM ET

This webinar is intended for Medicare Part D plan leaders, actuaries, pharmacy and rebate strategy teams, policy and compliance professionals, and health plan executives seeking to understand the practical implications of the proposed GUARD Model.

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Summary & Impacts of the 2027 Medicare Advantage Advance Notice

WAKELY WEBINAR
February 12, 2026 | 1 PM ET

The Centers for Medicare & Medicaid Services (CMS) recently released the 2027 Advance Notice of Methodological Changes for Medicare Advantage Capitation Rates and Part C/D Payment Policies, which proposes important changes in plan payments, risk adjustment and other key financial and regulatory requirements for 2027. During this webinar, Wakely consultants will provide an overview of the proposed changes, with an emphasis on the likely impact that the new rates and policies will have on Medicare Advantage bids, membership growth, quality and strategy. This Advance Notice is more consequential than others in recent history, as the effective payment rate falls substantially below the averages seen in years past. Speakers will also touch on the important items from the CY2027 Proposed Rule, released on 11/25/2025.

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CY2026 Trends in Medicare Advantage Part D Plan Benefits

WAKELY WEBINAR
February 25, 2026 | 12 PM ET

Join the experts from Wakely, an HMA Company, for a data-driven discussion of the key Part D benefit trends shaping Medicare Advantage Part D plans in CY2026. The Inflation Reduction Act’s Part D benefit redesign commenced January 1, 2025, with Maximum Fair Price drugs introduced January 1, 2026. As benefit design becomes more uniform across Part D plans, this webinar explores how sponsors adjusted the Part D benefits of their plans to meet the requirements of the legislation, while still remaining competitive. We will review the CY2025->CY2026 movements of Part D benefits and formulary placement, in addition to exploring benefit & formulary differences between MAPD & PDP plans for CY2026.

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Newsworthy Findings

Trump Signs $1.2T Spending Package That Funds HHS, Enacts PBM Reforms, Telehealth and Hospital-at-Home Measures

President Donald Trump signed a $1.2 trillion government funding bill that finances HHS through the end of the fiscal year while enacting PBM transparency reforms, extending Medicare telehealth flexibilities for two years, and renewing the hospital-at-home program for five years. The legislation drew praise from pharmacy groups and providers, but criticism from PBMs, who warned the reforms could disrupt existing drug pricing arrangements.

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Editor's Note
While it is nice to see steps towards transparency, there is still a big issue for lawmakers to contend with - Group Purchasing Organizations (GPOs). PBMs often create or control GPOs to help negotiate rebates and fees with drug manufacturers. While they increase negotiating leverage, many PBM critics argue that regulating PBMs without also regulating their affiliated GPOs simply shifts profits rather than increasing transparency.

HHS Plans to Invest $100M to Support Addiction Recovery and Address Homelessness

The Department of Health and Human Services (HHS) announced a $100 million initiative called STREETS (Safety Through Recovery, Engagement and Evidence-based Treatment and Supports) to fund outreach, psychiatric care, crisis intervention, and other supports for people experiencing homelessness and substance use disorders as part of the Great American Recovery Initiative. The program emphasizes long-term recovery and coordination across government, healthcare, faith and community groups, and criticizes prior harm-reduction and housing-first policies as ineffective.

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Editor's Note
HHS is explicitly linking homelessness, addiction recovery, and mental health treatment into a single coordinated funding strategy, signaling a shift away from siloed programs toward integrated, recovery-oriented care.

Medicare Advantage Prior Authorization Requests Rise in 2024: Report

Nearly 53 million prior authorization requests were sent to insurers in 2024, compared with nearly 50 million in the prior year, according to KFF.

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Editor's Note
In 2024, nearly 53 million prior authorization requests were submitted for Medicare Advantage enrollees, averaging 1.7 per beneficiary, with about 8% fully or partially denied. While few denials were appealed, most appeals succeeded, highlighting that patients often face delays for services that are ultimately approved. The number of requests continues to rise as enrollment in the privatized Medicare program grows, and practices vary across insurers, with some submitting more requests per enrollee but denying fewer.

Express Scripts Reaches ‘Landmark’ Settlement with FTC in Insulin Suit

The agreement includes sweeping changes to the Cigna pharmacy benefit manager’s (PBM’s) business practices, including no longer preferring expensive drugs over cheaper equivalents on standard formularies.

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Editor's Note
Express Scripts, one of the largest PBMs in the U.S., has agreed to significant reforms that enabled it to withdraw from a Federal Trade Commission lawsuit targeting major PBMs. The company plans to stop favoring high-list-price drugs on its standard formularies when lower-cost alternatives are available, delink its compensation from the savings it negotiates with drugmakers, increase transparency by disclosing data on drug spending and broker fees, and reshore its group purchasing organization from Switzerland back to the United States.

CMS Has Opportunity to Improve Public Health Data Reporting

The op-ed argues while the Centers for Medicare & Medicaid Services (CMS) has made progress incentivizing electronic health data reporting, current measures rely too heavily on simple attestation rather than true performance metrics, and the agency should develop quantitative measures of data timeliness and completeness to better support public health surveillance and action.

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Editor's Note
Efforts to modernize public health data reporting are essential for actionable surveillance and quicker responses to community health threats, but too often data systems remain siloed or qualitative rather than performance oriented. Strengthening CMS reporting incentives to focus on measurable quality, timeliness and completeness could help public health agencies allocate resources more effectively and improve real-time decision-making for disease prevention and control.

Bonus Article

Just for Fun

Math Riddle

I’m a whole number greater than 1. I’m not prime. If you add up all of my positive factors except me, you get exactly me. What number am I?

Prior Week

Q: Why don’t statisticians argue loudly?

A: They prefer results that are robust to noise

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