Article

The CMS 2027 Final Rule Just Rewrote the Star Ratings Playbook. Is Your Member Services Operation Ready?

  • April 15, 2026

On April 2, 2026, CMS finalized the Contract Year 2027 Medicare Advantage and Part D rule1, and the changes will reshape how health plans earn, protect, and lose revenue for years to come. CMS finalized the removal or retirement of 11 Star Ratings measures, declined to implement the Health Equity Index reward, added a new Depression Screening and Follow-Up measure, codified the Inflation Reduction Act's Part D benefit redesign, tightened supplemental benefit oversight, updated call recording retention requirements, and scaled back several health equity provisions. The agency received over 42,000 public comments on the proposed rule.2

The financial stakes are significant. According to CMS projections published in the final rule, the Star Ratings changes are estimated to have a net impact of approximately $18.6 billion on the Medicare Trust Fund over the 2027 to 2036 period.3 Independent actuarial estimates, including analyses from Milliman and Wakely Consulting, suggest roughly 25% of contracts could lose half a Star, with at least 42 contracts potentially falling below the 4.0 threshold that determines quality bonus payments.4 Industry analyses from Press Ganey and others estimate that by 2029, CAHPS and HOS survey measures could account for nearly 40% of total Star weight5, meaning the administrative measures that padded most plans' ratings are gone, and member experience is now the primary financial driver.

What CMS Changed: The Complete Picture

The rule touches nearly every operational function in a health plan. The Star Ratings overhaul is the headline: CMS finalized the removal or retirement of 11 measures, many of which were considered topped-out administrative or process measures with little performance variation across plans. CMS retained the Diabetes Care Eye Exam measure after comment period feedback, and added a new Depression Screening and Follow-Up measure for the 2027 measurement year (reflected in 2029 Stars). CMS also declined to implement the Health Equity Index reward, retaining the historical reward factor instead.

Beyond Stars, CMS codified the IRA's Part D benefit redesign into permanent regulation: the coverage gap is eliminated, a $2,000 annual out-of-pocket cap is in place, and catastrophic phase cost sharing is zero. CMS strengthened supplemental benefit oversight, including requiring that debit cards used for SSBCI be electronically linked to plan-covered items through an identification mechanism at the point of sale. CMS also updated call recording retention requirements, reducing the overall retention period for marketing and sales calls from 10 to six years with a tiered structure. Separately, documentation supporting coverage determinations must be retained in original format, including audio files; CMS has indicated that failure to produce original-format documentation may result in adverse audit findings, including potential PDE record adjustments.6 CMS also loosened marketing rules (eliminating the 48-hour SOA waiting period and the 12-hour gap between educational and marketing events), scaled back or deferred several health equity provisions for QI programs and UM Committees, and rescinded the mid-year supplemental benefit notice mandate.

Table 1: CY2027 Star Ratings Measure Changes

Measure Part(s) Affected Effective Status
Call Center: Foreign Language Interpreter and TTY AvailabilityPart C and Part D2028 StarsRemoved
Statin Therapy for Patients with Cardiovascular DiseasePart C2028 StarsRemoved
Plan Makes Timely Decisions about AppealsPart C2029 StarsRemoved
Reviewing Appeals DecisionsPart C2029 StarsRemoved
Complaints about the Health PlanPart C2029 StarsRemoved
Complaints about the Drug PlanPart D2029 StarsRemoved
Members Choosing to Leave the PlanPart C and Part D2029 StarsRemoved
SNP Care ManagementPart C2029 StarsRemoved
Medicare Plan Finder Price AccuracyPart D2029 StarsRemoved
Depression Screening and Follow-UpPart C2029 StarsAdded
Diabetes Care: Eye Exam (retained after comment period)Part CN/AKept

Source: CMS CY2027 Final Rule (CMS-4208-F3/CMS-4212-F), April 2026. Red = removed. Green = added. Yellow = retained after comment period. Note: Call Center and Members Choosing to Leave measures each apply to both Part C and Part D, accounting for 11 individual measure removals across the two programs.

Operational Impact: What This Means for Member Services and Payer Operations

CAHPS Now Drives the Revenue Equation

With industry estimates projecting survey measures could approach 40% of total Star weight by 2029, every member interaction that feeds a CAHPS response carries direct financial consequence. CAHPS measures getting needed care, getting appointments quickly, customer service quality, and health plan information. Each maps directly to call center performance: how quickly a member reaches a knowledgeable agent, whether the issue was resolved on the first call, and whether the member felt the plan gave them the information they needed.

Plans that treated member experience as secondary to clinical gap closure need to reverse that calculus. The AHA raised concerns during the comment period that CAHPS is high-level and lagged7, which underscores the operational problem: by the time CAHPS data reveals an issue, the damage spans months of interactions. Plans need real-time quality intelligence, not annual survey results, to manage at the speed CMS now requires.

The Language Access Measure Is Gone. The Requirement Is Not.

CMS removed the Call Center Foreign Language Interpreter and TTY Availability measure from Stars, effective 2028. But CMS will continue enforcing language access through compliance mechanisms, and member experience with language access will be captured through CAHPS survey questions.8 When language access was a binary, pass-fail administrative measure, plans met the standard by having an interpreter line available. Now it is measured through member experience surveys. The bar shifts from availability to quality. Did the Spanish-speaking member feel heard? Was the Mandarin-speaking member's question actually resolved? Multilingual quality monitoring becomes more important under this rule, not less.

Complaints, Retention, and the Signals You Are About to Lose

The Complaints about the Health Plan and Drug Plan measures are both removed, as is Members Choosing to Leave the Plan. Plans used these as governance signals for grievance operations and retention. Their removal from Stars does not mean CMS stops watching; these will likely continue as display measures and compliance enforcement tools. Complaint trends remain among the strongest leading indicators of CAHPS deterioration. And every lost member still represents lost premium revenue. The difference now is that plans lose the early warning signals. The QA system that monitors member interactions must compensate by surfacing complaint trends and churn risk from interaction data, feeding quality insights directly into retention strategy.

Depression Screening Creates a Member Services Coordination Challenge

The new Depression Screening and Follow-Up measure evaluates two rates: the percentage of eligible members screened, and the percentage who receive follow-up care within 30 days of a positive screen. The screening rate depends on clinical workflows. The follow-up rate depends on member services infrastructure: outreach, appointment scheduling, and confirmation. Plans that silo this as a purely clinical initiative will underperform.

Part D Benefit Changes Will Hit the Phones

The codified three-phase benefit structure (deductible, initial coverage, catastrophic) replaces the four-phase model members have known for years. The $2,000 out-of-pocket cap is the most significant Part D financial protection in a generation, but it requires agents to explain new cost-sharing mechanics accurately. Members will call about why their coverage gap disappeared, what counts toward TrOOP, and what happens at the OOP threshold. Every call center needs updated knowledge base content, retrained agents, and revised IVR scripts before October 2026. Benefit misinformation during AEP is one of the fastest paths to CAHPS degradation.

Debit Card Declines Will Become Call Volume

CMS strengthened SSBCI debit card requirements, including that cards be electronically linked to plan-covered items through an identification mechanism at the point of sale. In practice, this means tighter verification when members use flex cards. When a member's card is declined at a store because a specific item does not qualify, the next action is a phone call. Member services teams should anticipate a new category of inbound inquiries. Plans that do not prepare agent scripts and escalation workflows will see resolution times spike and CAHPS-relevant frustration increase.

Appeals Measures Gone: BPO Accountability Gap Widens

Two appeals measures are removed: Plan Makes Timely Decisions about Appeals and Reviewing Appeals Decisions. For plans outsourcing appeals to BPO vendors, this eliminates one of the few externally visible accountability signals on that process. Plans must build internal SLA monitoring to ensure outsourced operations maintain standards. The risk is not a Star Rating drop; it is a CMS compliance finding.

Health Equity Provisions Scaled Back: The Mandate Is Gone. CAHPS Is Not.

CMS scaled back or deferred several health equity provisions in this rule: the HEI reward was not implemented, QI program disparity reduction requirements were removed, UM Committee equity expert and analysis mandates were eliminated, and the supplemental benefit notice was rescinded. For plans serving significant dual-eligible or LEP populations, the regulatory pressure is reduced but the operational reality is unchanged. Experience disparities still surface in CAHPS. Voluntarily maintaining equity-focused quality monitoring, particularly multilingual QA, is not compliance theater. It is CAHPS protection.

Operational Impact Matrix: Every Change, Every Action

Table 2: CY2027 Final Rule Operational Impact Matrix

Rule Change Operations Affected Action Required
Star Ratings: 11 measures removed or retired, CAHPS weight rising significantlyMember services, call center QA, quality improvementRetool QA scorecards to mirror CAHPS dimensions; deploy 100% interaction monitoring; shift from administrative compliance to experience optimization
Call Center Language Access measure removed from StarsCall center operations, multilingual QA, complianceMaintain full multilingual QA; CMS still enforces via compliance and CAHPS; quality of LEP interactions now measured by member perception, not binary availability
Depression Screening and Follow-Up measure addedCare management, member outreach, call centerBuild member services workflows for follow-up scheduling; connect clinical screening data to outreach systems; track 30-day follow-up completion
Complaints measures removed (Part C and Part D)Grievances and appeals, member services governanceDo not deprioritize complaint tracking; CMS retains as display measures; complaint trends remain leading indicators of CAHPS deterioration
Appeals measures removed (Timely Decisions, Reviewing Appeals)Utilization management, appeals processingMaintain internal SLA tracking; removal from Stars does not reduce CMS audit scrutiny; plans outsourcing appeals lose a public accountability signal
Members Choosing to Leave the Plan removedRetention, member engagement, CX strategyDisenrollment still drives revenue loss; monitor churn through interaction data; connect QA insights to retention strategy
Part D benefit redesign codified ($2,000 OOP cap, no coverage gap)Member services training, call center knowledge baseRetrain agents on three-phase benefit structure; update IVR and knowledge base; anticipate high call volume around OOP threshold
SSBCI debit card oversight strengthened (POS identification mechanism)Supplemental benefits, member servicesPrepare for calls when cards are declined at POS; train agents on eligibility rules; update escalation workflows
Call recording retention updated (reduced to 6-year period)Call center IT, compliance, legalReview and update retention policies per new tiered requirements; audit current storage infrastructure
Documentation retention in original formatPart D operations, pharmacy, compliancePreserve all coverage determination documentation in original format including audio; non-compliance may result in adverse audit findings including potential PDE adjustments
Marketing deregulation (SOA, agent contact rules)Marketing, enrollment, call center surge planningAnticipate higher AEP contact volume; scale QA for enrollment surge; monitor for complaint spikes
Health equity provisions scaled back or deferredQuality improvement, UM governanceVoluntary continuation recommended for high dual-eligible/LEP plans; disparities surface in CAHPS regardless of mandates

Share this matrix with your leadership team to assign ownership and timelines for each action item.

What to Look for in a Member Experience Quality Solution

When evaluating solutions, health plan leaders should look for these capabilities:

100% interaction monitoring, not sampling. With CAHPS and survey measures carrying increasingly dominant weight in Star Ratings, sampling-based QA cannot identify the systemic patterns that drive survey responses.

Multilingual quality scoring at native-language fidelity. With language access measurement shifting to CAHPS, multilingual QA must be integrated into the same framework applied to English interactions.

Real-time coaching signals. CAHPS is lagged. Quality intelligence must surface coaching opportunities within hours, not quarters.

CAHPS-aligned scoring frameworks. The QA scorecard must mirror what CMS measures: getting needed care, customer service, getting appointments, and health plan information.

Complaint and churn early warning. With complaint and disenrollment measures removed, the QA platform must surface these signals from interaction data.

Plan-owned data and analytics. If your quality data lives inside a vendor's platform, you do not own your operational intelligence. That intelligence must belong to the plan.

How Mizzeto Supports This Shift

Mizzeto's Multilingual QA Solution was built for this inflection point: AI-powered quality monitoring across 100% of member interactions, in multiple languages, with CAHPS-aligned scoring, real-time coaching signals, and complaint and churn analytics. All data stays in the plan's hands. For more on connecting these capabilities to call center performance, see our guides on improving call center performance and modernizing call center operations.

The Window Is Open. Here Is How Long You Have.

The rule is effective June 1, 2026. Marketing begins October 1. Coverage starts January 1, 2027. The 2027 measurement year, which feeds 2029 Star Ratings, will be the first scored under the new CAHPS-heavy measure set. Plans that retool now have time. Plans that wait for 2029 ratings to reveal a problem will discover it started in 2027.

References

1. CMS, 'Contract Year 2027 Medicare Advantage and Part D Final Rule' Fact Sheet, April 2, 2026.

2. Federal Register, CMS-4208-F3/CMS-4212-F, published April 6, 2026.

3. CMS Final Rule financial projections; Becker's Hospital Review, April 2, 2026.

4. Milliman, 'Falling Star Rating Trajectory,' December 2025. Healthcare Labyrinth, April 2026.

5. Press Ganey, December 2025. Upward Growth, April 2026. Healthcare Labyrinth corroborates.

6. AArete, 'Reading the Signals,' December 2025.

7. American Hospital Association, Comment Letter on CY 2027 Proposed Rule, January 26, 2026.

8. Holland & Knight, April 2026. Crowell & Moring, December 2025.

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AI Data Governance - Mizzeto Collaborates with Fortune 25 Payer

AI Data Governance

The rapid acceleration of AI in healthcare has created an unprecedented challenge for payers. Many healthcare organizations are uncertain about how to deploy AI technologies effectively, often fearing unintended ripple effects across their ecosystems. Recognizing this, Mizzeto recently collaborated with a Fortune 25 payer to design comprehensive AI data governance frameworks—helping streamline internal systems and guide third-party vendor selection.

This urgency is backed by industry trends. According to a survey by Define Ventures, over 50% of health plan and health system executives identify AI as an immediate priority, and 73% have already established governance committees. 

Define Ventures, Payer and Provider Vision for AI Survey

However, many healthcare organizations struggle to establish clear ownership and accountability for their AI initiatives. Think about it, with different departments implementing AI solutions independently and without coordination, organizations are fragmented and leave themselves open to data breaches, compliance risks, and massive regulatory fines.  

Principles of AI Data Governance  

AI Data Governance in healthcare, at its core, is a structured approach to managing how AI systems interact with sensitive data, ensuring these powerful tools operate within regulatory boundaries while delivering value.  

For payers wrestling with multiple AI implementations across claims processing, member services, and provider data management, proper governance provides the guardrails needed to safely deploy AI. Without it, organizations risk not only regulatory exposure but also the potential for PHI data leakage—leading to hefty fines, reputational damage, and a loss of trust that can take years to rebuild. 

Healthcare AI Governance can be boiled down into 3 key principles:  

  1. Protect People Ensuring member data privacy, security, and regulatory compliance (HIPAA, GDPR, etc.). 
  1. Prioritize Equity – Mitigating algorithmic bias and ensuring AI models serve diverse populations fairly. 
  1. Promote Health Value - Aligning AI-driven decisions with better member outcomes and cost efficiencies. 

Protect People – Safeguarding Member Data 

For payers, protecting member data isn’t just about ticking compliance boxes—it’s about earning trust, keeping it, and staying ahead of costly breaches. When AI systems handle Protected Health Information (PHI), security needs to be baked into every layer, leaving no room for gaps.

To start, payers can double down on essentials like end-to-end encryption and role-based access controls (RBAC) to keep unauthorized users at bay. But that’s just the foundation. Real-time anomaly detection and automated audit logs are game-changers, flagging suspicious access patterns before they spiral into full-blown breaches. Meanwhile, differential privacy techniques ensure AI models generate valuable insights without ever exposing individual member identities.

Enter risk tiering—a strategy that categorizes data based on its sensitivity and potential fallout if compromised. This laser-focused approach allows payers to channel their security efforts where they’ll have the biggest impact, tightening defenses where it matters most.

On top of that, data minimization strategies work to reduce unnecessary PHI usage, and automated consent management tools put members in the driver’s seat, letting them control how their data is used in AI-powered processes. Without these layers of protection, payers risk not only regulatory crackdowns but also a devastating hit to their reputation—and worse, a loss of member trust they may never recover.

Prioritize Equity – Building Fair and Unbiased AI Models 

AI should break down barriers to care, not build new ones. Yet, biased datasets can quietly drive inequities in claims processing, prior authorizations, and risk stratification, leaving certain member groups at a disadvantage. To address this, payers must start with diverse, representative datasets and implement bias detection algorithms that monitor outcomes across all demographics. Synthetic data augmentation can fill demographic gaps, while explainable AI (XAI) tools ensure transparency by showing how decisions are made.

But technology alone isn’t enough. AI Ethics Committees should oversee model development to ensure fairness is embedded from day one. Adversarial testing—where diverse teams push AI systems to their limits—can uncover hidden biases before they become systemic issues. By prioritizing equity, payers can transform AI from a potential liability into a force for inclusion, ensuring decisions support all members fairly. This approach doesn’t just reduce compliance risks—it strengthens trust, improves engagement, and reaffirms the commitment to accessible care for everyone.

Promote Health Value – Aligning AI with Better Member Outcomes 

AI should go beyond automating workflows—it should reshape healthcare by improving outcomes and optimizing costs. To achieve this, payers must integrate real-time clinical data feeds into AI models, ensuring decisions account for current member needs rather than outdated claims data. Furthermore, predictive analytics can identify at-risk members earlier, paving the way for proactive interventions that enhance health and reduce expenses.

Equally important are closed-loop feedback systems, which validate AI recommendations against real-world results, continuously refining accuracy and effectiveness. At the same time, FHIR-based interoperability enables AI to seamlessly access EHR and provider data, offering a more comprehensive view of member health.

To measure the full impact, payers need robust dashboards tracking key metrics such as cost savings, operational efficiency, and member outcomes. When implemented thoughtfully, AI becomes much more than a tool for automation—it transforms into a driver of personalized, smarter, and more transparent care.

Integrated artificial intelligence compliance
FTI Technology

Importance of an AI Governance Committee

An AI Governance Committee is a necessity for payers focused on deploying AI technologies in their organization. As artificial intelligence becomes embedded in critical functions like claims adjudication, prior authorizations, and member engagement, its influence touches nearly every corner of the organization. Without a central body to oversee these efforts, payers risk a patchwork of disconnected AI initiatives, where decisions made in one department can have unintended ripple effects across others. The stakes are high: fragmented implementation doesn’t just open the door to compliance violations—it undermines member trust, operational efficiency, and the very purpose of deploying AI in healthcare.

To be effective, the committee must bring together expertise from across the organization. Compliance officers ensure alignment with HIPAA and other regulations, while IT and data leaders manage technical integration and security. Clinical and operational stakeholders ensure AI supports better member outcomes, and legal advisors address regulatory risks and vendor agreements. This collective expertise serves as a compass, helping payers harness AI’s transformative potential while protecting their broader healthcare ecosystem.

Mizzeto’s Collaboration with a Fortune 25 Payer

At Mizzeto, we’ve partnered with a Fortune 25 payer to design and implement advanced AI Data Governance frameworks, addressing both internal systems and third-party vendor selection. Throughout this journey, we’ve found that the key to unlocking the full potential of AI lies in three core principles: Protect People, Prioritize Equity, and Promote Health Value. These principles aren’t just aspirational—they’re the bedrock for creating impactful AI solutions while maintaining the trust of your members.

If your organization is looking to harness the power of AI while ensuring safety, compliance, and meaningful results, let’s connect. At Mizzeto, we’re committed to helping payers navigate the complexities of AI with smarter, safer, and more transformative strategies. Reach out today to see how we can support your journey.

February 14, 2025

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Feb 21, 20242 min read

Article

Fewer Star Ratings Measures, Higher Stakes for Your Call Center

CMS just made its Star Ratings math less forgiving, and the change lands squarely on the member service line. The Contract Year 2027 Final Rule, issued in April 2026, removes 11 measures from the Medicare Advantage and Part D Star Ratings, most of them administrative or process measures that CMS said no longer meaningfully distinguished one plan from another.1 Removing them does not simply shrink the scorecard. It reweights it. With fewer measures in the total, CMS has tilted relative weight toward the survey based and clinical outcome measures that remain, and several of the survey measures that gained ground are shaped directly on member calls.2

For a Medicare Advantage plan, that raises the stakes on a part of the operation many still treat as a cost center. In a smaller measure set, a weak call center is no longer a contained quality problem. It is a direct drag on the overall rating and the quality bonus payment that depends on it.

The measure set just got smaller

Some context on where ratings sit. The 2026 enrollment weighted average Star Rating for Medicare Advantage plans with drug coverage was 3.98, and only about 40 percent of MA contracts earned four stars or higher, the threshold that triggers a quality bonus payment.3 Most plans are already sitting below the line that funds richer benefits.

Into that tight environment, the Contract Year 2027 rule removes 11 measures and tilts relative weight toward the survey based and clinical outcome measures that remain.4 Patient experience and access measures already had their weight cut from four times to two times for the 2026 ratings, so member experience carries less raw weight than it did a few years ago.5 What the removals change is the denominator. With the low differentiation measures gone, the surviving CAHPS experience measures are a larger share of a smaller set. Clinical HEDIS measures gain the most, but they move slowly. Among the measures a plan can influence quickly through daily operations, the CAHPS experience measures are the most reachable, and the call center shapes several of them.

Several of the survivors are decided on the phone

The experience measures CMS kept lean heavily on what members actually go through, and much of that happens on a call. Surviving CAHPS composites such as customer service, getting needed care, getting appointments and care quickly, and overall rating of the plan are shaped directly by how member calls go. When a member cannot get a question resolved, is transferred repeatedly, or feels unheard, that experience surfaces later as a lower survey score.

There is a sharper point in the timing. Among the measures CMS removed were the ones that used to grade call center and complaint handling directly, including the appeals timeliness, plan complaints, and call center interpreter measures. The call center lost its own dedicated scorecard, yet the experience it drives still flows into the CAHPS survey measures that remain. The rating exposure did not go away. It moved into measures where a sampling based QA program cannot tell a plan why a score moved.

What this looks like in practice: a plan's customer service composite has been flat for two years. Leadership assumes the scripts and training are fine because the quarterly QA sample looks clean. The sample, a few hundred manually scored calls, never surfaces the systemic issue, a recurring transfer loop on benefit questions, because it lives in calls that were never selected. The composite stays flat, and in a smaller measure set that flat score costs more than it used to.

Why sampling is now a ratings risk, not just a quality gap

Traditional call center QA reviews a small manual sample, historically a few percent of calls, and scores it well after the interaction. That model was always a blind spot. In a concentrated Star Ratings environment, it becomes a financial one.

When a plan reviews less than 5 percent of its member calls, it is inferring the experience behind measures that now move its rating and its bonus payment from a fraction of the evidence. Non-English calls are rarely sampled at all, which means the experience of entire language groups goes effectively unmeasured, even as those calls feed the same composites. A sample can tell a plan that a composite is stuck. Only the full population of calls can tell it why. The contrast between the two models is direct.

How a sampling model and a full call model compare

Sampling based QA Full call scoring
Reviews a few percent of member calls Reviews 100% of member calls
Infers the experience behind CAHPS composites Measures that experience directly
Systemic issues hide in unselected calls Root causes surface across the full population
Non-English calls rarely scored Every language translated and scored
Vendor self reported quality metrics Intelligence owned and controlled by the plan

What to look for in a member experience solution

Improving the experience measures that now carry more weight starts with actually seeing them. When evaluating how to monitor and improve member calls, plans should look for:

  • Evaluation of every member call rather than a sample, so systemic issues surface instead of hiding in unselected calls
  • Scoring tied to the experience measures that drive ratings, including customer service quality and complaint drivers
  • Translation and scoring of calls in every language, so no member group goes unmeasured
  • Root cause visibility that explains why a composite is stuck, not just that it is
  • Intelligence the plan owns and controls, rather than quality metrics self reported by a vendor

Claro by Mizzeto was built to give plans that full view. Its Member Sentiment & At-Risk Identification and Agent Empathy & Communication scoring evaluate 100 percent of member calls in any language, turning the experience behind CAHPS composites into something a plan can measure and improve rather than infer.

The bottom line

The Contract Year 2027 rule did not lower the bar for member experience. By removing the measures plans could coast on, it left the surviving experience measures carrying more of what a plan can actually influence, with no dedicated call center scorecard to flag trouble early. In a concentrated Star Ratings set, a member service operation measured by sampling is a rating left partly to chance. Plans that can see every call can find and fix what is holding a composite down, while plans reviewing a small sample keep guessing. To see how full call scoring maps to the Star Ratings measures that now carry the most weight, send us a sample of your calls and we will return scored transcripts before you commit to anything.

References

1. Crowell & Moring LLP, CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors. https://www.crowell.com/en/insights/client-alerts/cms-finalizes-cy-2027-medicare-advantage-and-part-d-rule-key-implications-for-plan-sponsors

2. Becker's Payer Issues, CMS pitches star ratings reform in 2027 Medicare Advantage rule: 7 notes. https://www.beckerspayer.com/payer/medicare-advantage/cms-pitches-star-ratings-reform-in-2027-medicare-advantage-proposed-rule-7-notes/

3. Cohere Health, CMS Star Ratings 2027 Final Rule: Health Plan Impacts (citing the CMS 2026 MA and Part D Star Ratings Fact Sheet). https://www.coherehealth.com/blog/cms-star-ratings-2027-final-rule-health-plans

4. CMS, Contract Year 2027 Medicare Advantage and Part D Final Rule fact sheet (April 2, 2026). https://www.cms.gov/newsroom/fact-sheets/contract-year-2027-medicare-advantage-part-d-final-rule

5. AJMC, The Stars Have Realigned (Again): What Medicare Advantage Plans Need to Know. https://www.ajmc.com/view/contributor-the-stars-have-re-aligned-again-what-medicare-advantage-plans-need-to-know

Jan 30, 20246 min read

August 17, 2026

2

min read

Article

The Marketplace Members You Are About to Lose Are Already Calling You

The fallout from this year's premium shock did not wait for open enrollment. When the enhanced premium tax credits expired at the end of 2025, the price of 2026 coverage moved for almost everyone who buys it on the individual market, and it moved sharply. Average premium payments for subsidized Marketplace enrollees more than doubled heading into 20261, and effectuated enrollment is on track to fall from 22.3 million to roughly 17.5 million2.

For a Marketplace plan, that is not an abstract policy shift. It is a wave of confused, price sensitive members calling right now, mid plan year, to ask why their bill changed, whether they still qualify for help, and whether a cheaper plan exists. Those calls are happening months before the next open enrollment window even opens, and the decision to stay or leave is being made on them well ahead of any renewal file. Marketplace member retention is being decided on the member service line today, and most plans are barely listening to it.

The 2026 reset changed who is on the phone

The expiration of the enhanced tax credits did more than raise prices. It changed the mix of people calling. A disproportionate share of the enrollment drop, about 27 percent, came from households just above the old subsidy cliff, even though that group made up only 3 percent of plan selections the year before2. These are members who lost eligibility for help entirely and are now weighing coverage on price alone.

The result is higher call volume made up of harder calls. Billing questions, subsidy confusion, and plan comparison requests are exactly the interactions that resolve least often on the first attempt. And first call resolution is where this problem turns expensive: SQM Group benchmarks put first call resolution for complaint calls at 47 percent, the lowest of any call type and far below the healthcare insurance average3. The same research shows that in a given year, roughly 40 percent of customers who do not get their issue resolved on the first call defect to another company4. A price shocked Marketplace member whose billing question is transferred twice and never resolved is not a service statistic. That member is a renewal the plan is about to lose.

Churn shows up in the call before it shows up in the data

Retention data is a lagging indicator. By the time a member appears in a disenrollment report, the decision was made and the window to intervene has closed. The signal that predicts that outcome is audible much earlier, in the tone and content of the call itself.

What this looks like in practice: a member calls in October asking why the subsidy that covered most of the premium shrank. The agent explains the tax credit change, cannot fully resolve the affordability concern, and the call ends. Nothing flags the member as at risk. No follow up is triggered. In January the member is gone, and the plan learns about it from a report rather than from the call that predicted it.

Why sampling misses the members who matter most

Most plans still evaluate member calls the way they did a decade ago, by pulling a small manual sample and scoring it after the fact. When a plan reviews less than 5 percent of its member calls, the leaving decision almost always forms inside the 95 percent no one listens to. The signals that predict churn, the second unresolved call, the audible frustration, the mention of a competitor's premium, sit in the calls that were never selected.

The gap is widest exactly where the 2026 population is most exposed. Non-English calls are rarely part of a manual sample at all, yet language access is where affordability confusion compounds fastest. A sampling model does not just miss volume. It systematically misses the members whose experience is deteriorating and who are most likely to leave.

How a sampling model and a full call model compare

Sampling based call review Full call member intelligence
Reviews less than 5% of member calls Reviews 100% of member calls
At risk members found by chance, if at all At risk members identified by sentiment and tone
Distress surfaces later in surveys and disenrollment data Distress surfaced while there is still time to intervene
Non-English calls rarely sampled Every language translated and scored
Quality data owned and reported by a vendor Intelligence owned and controlled by the plan

What to look for in a member call intelligence approach

The problem is not that plans lack member data. It is that the most predictive data, what members actually say when they call, is captured and then discarded. When evaluating how to close that gap, plans should look for:

  • Coverage of every member call, not a sample, so at-risk members are identified rather than missed by chance
  • Sentiment and risk detection that surfaces the members most likely to disenroll while there is still time to act
  • Translation and scoring of calls in every language your membership actually calls in, so non-English members are not the least understood
  • Transparency the plan controls, with the logic and the intelligence owned by the plan rather than a vendor
  • Signal that reaches retention and enrollment teams quickly enough to intervene before renewal, not after

Claro by Mizzeto was built for this. Member Experience Insights is one of four capability areas within Claro, and it is the one focused specifically on this problem: identifying at-risk members before they disenroll, using the actual content and tone of their calls rather than a survey that arrives months later. It reviews 100 percent of member calls, scores sentiment and risk across every language a plan's membership calls in, and surfaces the members most likely to leave in time for retention teams to act, so outreach can happen before open enrollment closes rather than after the member is already gone.

The bottom line

The 2026 subsidy reset handed Marketplace plans a harder, more price sensitive population and a narrower margin for error. Retention this year will not be won by surveys that arrive after the decision or reports that confirm a loss already booked. It will be won on the call, in the moment a member is deciding whether the plan is worth the new price. Plans that can hear every one of those calls will keep members that sampling based plans never knew were leaving.

To see how full call member intelligence identifies at-risk Marketplace members before they disenroll, send us a sample of your calls and we will return scored transcripts before you commit to anything.

References

1. KFF. Analysis of premium payment increases for subsidized Marketplace enrollees following the expiration of enhanced premium tax credits, 2026. www.kff.org

2. Congressional Budget Office. Projected effects of the expiration of enhanced premium tax credits on Marketplace enrollment, 2026, including subsidy cliff impact by income band. www.cbo.gov

3. SQM Group. First call resolution benchmarks by call type, healthcare and insurance industry comparison. www.sqmgroup.com

4. SQM Group. Customer defection rates following unresolved first-call issues. www.sqmgroup.com

Jan 30, 20246 min read

August 10, 2026

2

min read

Article

This Year, Retention Is a Fight on Two Fronts

In most years, Medicare Advantage disenrollment is a defensive problem: a plan keeps the members it has, and the losses are gradual. 2026 broke that pattern. A wave of plan exits pushed roughly 2.9 million Medicare Advantage members, about 10 percent of enrollees, out of plans that stopped serving their counties, a nearly tenfold jump from the 1 percent average that held from 2018 through 2024.1 The market filled with switchers, and every plan is now fighting on two fronts, defending the members it has and competing for a large pool of switchers. The same thing decides both: whether the plan is easy to be a member of.

The same failure now costs a plan twice

Forced disenrollment, the county exits that drove the 2026 spike, is not a service problem, and no plan can prevent it. But everything the disruption set in motion afterward is within a plan's control. A market this unsettled taxes a weak member experience twice, once as the plan loses its own members and again as it fails to keep the switchers it wins. A new member arrives with no goodwill in reserve. A tenured member might forgive a bad call after ten good years; a member of ten days simply shops again.

Members leave for reasons a plan can see coming

On both fronts, the reasons are documented, and they are not mainly about price. In the Medicare Current Beneficiary Survey, the strongest predictors of leaving were difficulty accessing care, which raised the odds by about a third, and low plan generosity, by roughly half; cost alone was not significant once the other factors were accounted for.2 CMS confirms it in its own monthly Disenrollment Reasons Survey,3 where close to a fifth of disenrollees cite problems getting services covered and roughly one in eight cite customer service.4 Those are the substance of member service calls.

The decision is usually audible before it is final

An honest caveat first: access and benefit design, the largest drivers, are not call center problems in origin, and listening does not widen a narrow network. What it does is surface the trouble first. Members rarely leave over a benefit design in the abstract; they phone to ask why a service was denied or a drug dropped, and hang up without an answer long before they fill out a form. A member who has called three times about one issue is not satisfied, yet first call resolution in health insurance is only about 72 percent,5 and for complaint calls just 47 percent.6 Traditional quality assurance reviews only 2 to 5 percent of calls,7 so the slow walk to disenrollment, and nearly every call in a language other than English, goes unheard.

Why the loss counts twice on the books

The cost shows up plainly. CMS caps broker pay at $694 for a new Medicare Advantage enrollment in 2026 and $347 for a renewal, so acquiring a member costs at least twice keeping one.8 In a churning market a plan pays that premium at volume, and winning a switcher only to lose them a year later to an unreviewed call means it bought nothing. On top sits the Star Ratings bonus: eligibility turns on the four star threshold, and a half star slip from 4.0 to 3.5 erases the entire 5 percent bonus,9 several million dollars a year for a midsize plan.

CMS just removed the disenrollment scorecard

The timing is unkind. On April 2, 2026, the Contract Year 2027 Final Rule removed 11 Star Ratings measures, including Members Choosing to Leave the Plan, the measure that graded plans on voluntary disenrollment, effective with the 2029 Star Ratings.10 That looks like relief, but nothing underneath it changed. CMS still fields the Disenrollment Reasons Survey and reports disenrollment publicly, CAHPS remains in the formula at double weight,11 and a lost member still has to be replaced. CMS stopped keeping score in the very year a plan can least afford to look away.

What to look for in a way to see it coming

Finding these members while there is still time to act is a different exercise from grading agents on a sample. A plan should look for:

  • Whole population analysis rather than sampling, so a single member's escalating calls and the patterns across the book are both visible.
  • Scoring that reads the member, weighing sentiment, unresolved issues, and repeat contact, not just whether the agent's greeting was correct.
  • The same rigor for every language, including interpreter lines, which Section 1557 of the Affordable Care Act makes a legal duty.
  • Plan ownership of the data and scoring models, so the retention signal survives changes in vendors, staffing, and telephony.
  • A direct link from calls to CAHPS, grievances, and disenrollment, so sentiment does not sit in a report no one connects.

Two ways to manage member retention

Reactive retention (sampling model) Predictive retention (whole population analysis)
Call coverage2 to 5 percent of calls sampledClose to 100 percent of calls analyzed
What gets measuredAgent greeting, script, and etiquetteMember sentiment, unresolved issues, members at risk
Calls not in EnglishRarely reviewed or scoredAnalyzed at the same depth as English calls
New members you just wonTreated like any other call in the sampleFirst calls flagged before a new member sours
When a leaving member becomes visibleAfter the member disenrolls, on a surveyWhile the member is still enrolled and reachable
Systemic patternsInvisible inside a small sampleSurfaced across the full member population
Data and scoring logicHeld in a vendor or reporting layerOwned by the plan and portable across changes

Sources: SQM Group call center benchmarking; CMS Contract Year 2027 Final Rule.

This is the gap Claro by Mizzeto was built to close. Claro analyzes the full volume of member calls, including the languages and interpreter lines sampling never reaches, and its Member Sentiment & At-Risk Identification scoring surfaces the unresolved, escalating conversations that turn into disenrollment months later, for tenured and newly won members alike, while the plan keeps ownership of the data. For the upstream work, see how payers can fix their call centers.

The bottom line

For one year at least, retention is a contest a plan can lose on both sides at once. The reasons people leave Medicare Advantage plans are documented, they turn on usability more than price, and they surface on calls long before an enrollment form, for members of a decade or a week. CMS took away the measure. The cost, paid twice over in a churning market, did not fall.

References

1.  Johns Hopkins Bloomberg School of Public Health and Georgetown University, JAMA (Feb. 18, 2026): approximately 2.9 million Medicare Advantage members, about 10 percent of enrollees, faced forced disenrollment for 2026 as plans exited markets, up from a mean of 1 percent from 2018 to 2024 and 6.9 percent in 2025. jamanetwork.com

2.  Health Affairs, study of Medicare Advantage disenrollment using the Medicare Current Beneficiary Survey (2015 to 2020): difficulty accessing care associated with roughly 1.33 times greater likelihood of disenrollment; low plan generosity roughly 1.47 times; dissatisfaction with care quality significant; dissatisfaction with cost alone not a significant independent predictor (approx. 1.03 times). healthaffairs.org

3.  Centers for Medicare and Medicaid Services, Medicare Advantage and Prescription Drug Plan Disenrollment Reasons Survey. Captures why beneficiaries voluntarily leave; results publicly reported in the annual Star Ratings Data Table and Display Measures. cms.gov

4.  The Commonwealth Fund, analysis of CMS Medicare Advantage Disenrollment Reasons Survey data: approximately 18 percent of disenrollees cited problems getting the plan to cover services and approximately 13 percent cited customer service issues such as trouble obtaining accurate information; voluntary disenrollment across MA contracts rose about 70 percent between 2017 and 2021. commonwealthfund.org

5.  SQM Group, First Call Resolution Benchmarking by Industry: health insurance first call resolution approximately 72 percent. sqmgroup.com

6.  SQM Group, first call resolution by call type: complaint calls resolve on first contact approximately 47 percent of the time, the lowest of all call types. sqmgroup.com

7.  SQM Group, call center quality assurance benchmarking: traditional programs review roughly 2 to 5 percent of interactions. sqmgroup.com

8.  Centers for Medicare and Medicaid Services, Agent and Broker Compensation memorandum for Contract Year 2026 (June 18, 2025): national maximum Fair Market Value of $694 for a new Medicare Advantage enrollment and $347 for a renewal. cms.gov

9.  Centers for Medicare and Medicaid Services, Medicare Advantage Quality Bonus Payment methodology: bonus payments apply to contracts at or above the four star threshold; loss of four star status removes the 5 percent quality bonus applied to the benchmark. cms.gov

10.  Centers for Medicare and Medicaid Services, Contract Year 2027 Medicare Advantage and Part D Final Rule (April 2, 2026): removal of 11 Star Ratings measures, including Members Choosing to Leave the Plan, effective with the 2029 Star Ratings. cms.gov; Federal Register, April 6, 2026.

11.  Centers for Medicare and Medicaid Services, 2026 Medicare Part C and D Star Ratings Technical Notes: CAHPS and patient experience measure weights reduced from quadruple (4x) to double (2x) effective with the 2026 Star Ratings. cms.gov

Jan 30, 20246 min read

July 31, 2026

2

min read

Article

The Grievance That Had a Six Week Warning

By the time a formal grievance reaches a health plan’s Grievance and Appeals team, it arrives looking like an emergency. The member is angry. A response deadline is already running. A regulator may eventually read the file. What the file rarely shows is that the grievance did not begin that week, or even that month. It began on an ordinary call that did not get resolved and was never reviewed. The warning was there. No one was assigned to look for it.

Most health plans treat reducing member grievances as a downstream chore: staff the queue, meet the deadline, close the case. That posture quietly concedes the grievance as inevitable, and it is not. A grievance is the visible end of an escalation that usually runs about six weeks, and nearly all of it is recorded, in the plan’s own phone system, in the member’s own words. The signal is not missing. It is simply never listened to.

A grievance is a six week escalation, not a single event

CMS defines a grievance as a complaint about a plan’s delivery of service, and the rules let a member arrive there slowly. A Medicare Advantage enrollee has up to 60 days after the triggering event to file, and the plan then has 30 days to resolve a standard grievance, with a 14 day extension.5 That window is the outer edge of a story that almost always starts earlier, on the phone.

The arc is familiar to any member services team. It opens with a single call about a denied claim, a benefit change, or a stalled prior authorization, and the member hangs up with an answer that is incomplete or simply wrong. That is common. SQM Group puts first call resolution for health insurance at roughly 72 percent, so close to three in ten member calls are not settled the first time.1 The member calls back, and calls again, and these repeat calls are the hardest to fix, because complaint calls resolve on the first contact only 47 percent of the time, the lowest rate of any call type SQM tracks.2 By the fifth or sixth week the member gives up and files. Only then does the plan open a case.

The shape of it is mundane. A member is told on the phone that a drug is covered, learns at the pharmacy counter that it is not, gets a different answer from a second agent, and files after a third. Three recorded calls, one avoidable grievance, and a member now drifting toward disenrollment. Every call was captured. None was flagged.

Appeals run on the same current. A denial explained badly prompts an appeal, not just frustration. The recording of that call is the clearest account of what the member was told, and the one document the appeals file rarely contains. A single unreviewed call can feed both outcomes, a grievance about the service and an appeal against the decision, both audible weeks before either was filed.

Why the warning stays invisible

The reason is not indifference. It is arithmetic. Traditional call center quality assurance, whether member service is run internally, outsourced, or split between the two, reviews somewhere between 2 and 5 percent of calls.3 The other 95 percent, which includes nearly every repeat call in an escalating grievance, is never heard by anyone whose job is to catch problems. A sample that small will almost never contain the three or four particular calls that make up one member’s slow walk to a filing, and it is even less likely to reveal the shape of the trouble when the same benefit is being miscommunicated to hundreds of members at once.

Sample size is only half of the failure. The deeper flaw is what the sampling was built to measure. A conventional scorecard asks whether the agent greeted the member, verified identity, and read the required disclosures. It does not ask whether the member’s problem was actually solved, or whether the member hung up angrier than they picked up. A call can earn a clean score and still be a grievance in motion. The program was designed to grade etiquette, and etiquette is not the thing that turns into a filing. We have made this case before, that most grievances start as calls that never got reviewed, and nothing in the underlying mechanics has changed since.

The calls in languages other than English are the least visible of all. When a member with limited English proficiency cannot be helped without an interpreter, the quality of the resolution is harder to verify, the member is less likely to push back on an answer they do not fully understand, and the interaction is almost never scored at all. Those are precisely the calls where a small misunderstanding hardens, unseen, into a grievance.

CMS just removed your grievance scorecard

On April 2, 2026, CMS issued the Contract Year 2027 Medicare Advantage and Part D Final Rule and, with it, removed 11 measures from the Star Ratings. Four of them speak directly to this problem, and all four leave the formula beginning with the 2029 Star Ratings: Complaints about the Health and Drug Plan, Members Choosing to Leave the Plan, Plan Makes Timely Decisions about Appeals, and Reviewing Appeals Decisions.4 Read in a hurry, that looks like a reprieve. The measures that once turned complaints, disenrollment, and appeals handling into a Star score are going away, and the natural temptation is to slide grievance and appeals monitoring down the list of things worth watching.

That reading has it exactly backward. The measures are leaving the scorecard. The exposure is staying exactly where it was. CMS still runs the Complaints Tracking Module, and plans are still bound to the resolution timelines set at 42 CFR 422.125 and 422.564.5 The complaint and customer service questions remain on the CAHPS survey, and the survey based measures carry heavy and rising weight in the Medicare Advantage formula.6 A member who leaves still leaves. What actually changed is narrower and more dangerous than relief: the warning light that used to sit on the Star dashboard has gone dark. Plans that had quietly relied on those measures as their grievance scorecard now have no scorecard, and precisely the same risk underneath it.

What it takes to see it coming

Seeing a grievance coming means catching the escalation while it is still a service problem, not a case number. It rests on a reversal: stop sampling calls to grade agents, and start reading all of them to find members. A plan that analyzes every interaction can connect the several calls behind one escalation and watch the same complaint surface across the population, where a single systemic fix replaces hundreds of grievances not yet filed.

The point is not more scores but earlier ones. A member who has called three times about one decision is a retention risk however politely each call was handled, and no rubric that grades greetings will say so. A few practical tests separate a system that sees a grievance coming from one that only counts calls afterward:

  • Whole population analysis, not sampling, so one member’s escalating calls and the patterns forming across the book are both visible before anyone files.
  • Scoring that reads the member, not just the agent, weighing sentiment, unresolved issues, and repeat contact rather than whether the greeting was correct.
  • The same rigor for calls in every language, including interpreter lines, because that is where hidden escalation collects and Section 1557 makes language access a legal duty.
  • Plan ownership of the conversation data, scoring models, and trend lines, so the early warning system survives changes in telephony and staffing and can be retuned in days.
  • Alerts that reach the people who can act, so member services, grievance and appeals, and compliance see a trend while there is still time to intervene.

Two ways to run grievance and appeals operations

Reactive grievance handling (sampling model) Predictive early warning (whole population analysis)
Call coverage 2 to 5 percent of calls sampled Close to 100 percent of calls analyzed
What gets measured Agent greeting, script, and etiquette Member sentiment, unresolved issues, members at risk
Calls not in English Rarely reviewed or scored Analyzed at the same depth as English calls
When a problem surfaces After the grievance is filed While it is still a service issue, weeks earlier
Systemic patterns Invisible inside a small sample Surfaced across the full member population
Data and scoring logic Held in a vendor or reporting layer Owned by the plan and portable across changes

Sources: SQM Group call center benchmarking; CMS Contract Year 2027 Final Rule.

Mizzeto built Claro for exactly this gap. It analyzes the full volume of member calls, including the ones in other languages and on interpreter lines that sampled QA never reaches, and its Member Sentiment & At-Risk Identification scoring is built to surface the unresolved, escalating conversations that become grievances and appeals weeks later, all while the plan keeps ownership of the underlying data and the logic that scores it. If a grievance and appeals team is meeting every deadline and still watching volume climb, the explanation is usually sitting in calls the plan has already recorded and has never had a way to hear.

The bottom line

A formal grievance is the most expensive way a health plan can learn about a problem it could have seen six weeks earlier. The information was never missing. It was sitting, unheard, in the 95 percent of calls no one reviews. CMS has taken away the measures that once forced plans to watch their complaints and their appeals, but the price of a grievance, paid in CAHPS, in disenrollment, and in compliance exposure, has not fallen by a cent. Reducing member grievances begins with a decision to stop waiting for them to arrive.

Any plan can find out what its own calls are already saying. Mizzeto will score a sample of them and show a plan the warnings hidden inside before it commits to anything further. For the upstream work that keeps these calls from going wrong in the first place, see how payers can fix their call centers.

References

1.  SQM Group, “First Call Resolution Benchmarking by Industry” (health insurance first call resolution approx. 72 percent). sqmgroup.com

2.  SQM Group, first call resolution by call type (complaint calls resolve at 47 percent, the lowest of all call types). sqmgroup.com

3.  SQM Group, call center quality assurance benchmarking (traditional programs review roughly 2 to 5 percent of interactions). sqmgroup.com

4.  Centers for Medicare & Medicaid Services, “Contract Year 2027 Medicare Advantage and Part D Final Rule,” April 2, 2026 (removal of 11 Star Ratings measures, including Complaints about the Health and Drug Plan, Members Choosing to Leave the Plan, Plan Makes Timely Decisions about Appeals, and Reviewing Appeals Decisions, effective with the 2029 Star Ratings). cms.gov; Federal Register, April 6, 2026.

5.  42 CFR 422.564 (grievance procedures: 60 day filing window, 30 day standard resolution, 14 day extension) and 42 CFR 422.125 (resolution of complaints in the Complaints Tracking Module). ecfr.gov

6.  Analysis of the CY2027 Final Rule finding relative Star Ratings weight shifting toward survey based measures such as CAHPS for Medicare Advantage plans (e.g., Crowell & Moring; Holland & Knight client alerts, April 2026).

Jan 30, 20246 min read

July 14, 2026

2

min read