“We actually read the comments,” Chris Klomp, CMS Deputy Administrator and Director of the Center for Medicare, noted during a fireside chat at the 2026 Better Medicare Alliance Executive Policy Summit.
The line—like Klomp’s suggestion that comment closing periods are followed by “comment-paloozas”—drew a laugh, but it also captured where Medicare Advantage policy is heading. CMS is signaling that stakeholder input will play a role, particularly as the agency revisits payment, risk adjustment, and prior authorization. At the same time, officials made clear that engagement will not slow a broader push to tighten oversight and refine how the program operates.
Speaking with BMA’s Mary Beth Donahue, Klomp and CMS Deputy Administrator and Chief Policy and Regulatory Officer John Brooks framed Medicare Advantage as a central component of Medicare, particularly in supporting beneficiary choice and competition. Both also pointed to the need to strengthen payment accuracy, reinforce program integrity, and ensure long-term sustainability.
As Brooks put it, “the road to stability goes through greater payment accuracy,” tying the agency’s recent policy direction to concerns about trust and long-term program viability.
That focus is especially clear in risk adjustment, where CMS has been working to sharpen its understanding of how the program actually operates. Earlier this year, Klomp and Brooks co-authored an article examining coding intensity differences between Medicare Advantage and fee-for-service. Their analysis found a gap of approximately one and a half to two percent—significantly lower than the ten percent figure MedPAC had previously estimated for 2022. Brooks explained that much of the difference came down to timing: CMS was modeling forward from current data, while MedPAC’s estimate reflected a point-in-time snapshot, and neither had yet fully incorporated the impact of the V28 risk model adjustment. The exchange with MedPAC was described as collaborative, with both sides working through their methodologies together.
The implications for policy are significant. CMS’s view is that good policymaking requires a clear-eyed baseline, and that understanding exactly what is driving coding differences—whether legitimate clinical documentation or practices oriented toward payment advantage—is essential to getting the policy response right. As Klomp put it, “we do not want plans competing on the basis of risk adjustment.” The goal, he said, is to shift competition toward improving outcomes for beneficiaries, with risk adjustment serving its intended purpose of ensuring accurate payment for the patients plans actually serve.
CMS is pushing for a more level playing field across Medicare’s risk-based options. Risk adjustment and prior authorization remain central to that effort, and both are areas where the agency is actively seeking stakeholder input.
For plans, the timing of upcoming changes is as important as the substance. Several policy updates could converge on January 1, 2027, and industry participants raised concerns about cumulative impact. If changes to risk adjustment, chart review, and related policies are implemented together, plans could face pressure to scale back supplemental benefits or adjust premiums.
Risk adjustment remains the immediate flashpoint. Proposed updates in the Advance Notice have already triggered stakeholder concerns about downstream effects, particularly for plans serving beneficiaries with multiple chronic conditions. Some speakers argued that changes of this scale require a more deliberate process than the current notice-and-comment timeline allows.
The summit also considered longer-term structural questions. In conversation with Mark Newsom, of Health Evaluations and Stacey Benseler, BMA’s Vice President of Policy and Research, Tom Kornfield, of MAST Health Policy Solutions and a former CMS official, noted that the current risk adjustment model traces its origins to the mid-1980s, when the program was a fraction of its current size. He argued that moving toward a fundamentally different framework would better align plan incentives with the quality of beneficiary care rather than the mechanics of payment. Continuing to debate coding intensity within an outdated structure, he suggested, would mean having the same argument indefinitely without addressing the underlying problem. That view was echoed by others at the Summit who pointed to the need to move beyond incremental updates toward a more fundamental redesign.
Gable Brady, Senior Health Policy Advisor to the U.S. Senate Committee on Finance, described a more measured outlook on Capitol Hill. She pointed to continued interest in preserving competition and beneficiary choice within Medicare Advantage, while acknowledging that legislative movement is likely to be limited in the near term.
That includes the Improving Seniors’ Timely Access to Care Act, which would streamline prior authorization requirements in MA. While the proposal continues to draw bipartisan attention, Brady indicated that it would likely need to move as part of a broader healthcare package, potentially after the midterm elections.
Attention is also turning to how Medicare Advantage can function in more complex markets, including rural areas where plan participation and provider alignment can be uneven.
Artificial intelligence surfaced as a secondary but persistent theme. CMS officials, including Klomp, and other panelists pointed to its potential to address access challenges and administrative burden. However, many conference participants acknowledged that there is no clear pathway for integrating AI into existing payment structures, which remain tied to time-based services rather than computational processes.
That tension was echoed by Liz Fowler, former Director of the CMS Innovation Center, who observed what she described as an escalating dynamic in which providers are deploying AI to capture every possible code while plans are using it to scrutinize those same claims. In her view, that kind of AI-versus-AI standoff represents a missed opportunity. The better vision, she suggested, is one in which AI enables systems to communicate, automates friction out of the process, and ultimately supports better care rather than fueling an administrative arms race.
Ultimately, the takeaway from the Summit was not a shift away from Medicare Advantage, but recognition of a more demanding phase for a program CMS continues to recognize as central to Medicare’s future.
