The Alliance of Specialty Medicine submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Contract Year (CY) 2027 Medicare Advantage (MA) and Part D proposed rule, focusing on beneficiary access to specialty care, network adequacy, plan oversight, administrative burden, and the role of enforcement in ensuring compliance with existing MA requirements.
In comments, the Alliance supported CMS’s efforts to strengthen oversight of MA organizations but emphasized that these policies must be paired with consistent audits, compliance activities, and enforcement actions. The Alliance also urged CMS to use its existing authority to impose financial penalties and, where appropriate, terminate MA contracts when plans fail to meet access, network adequacy, and transparency requirements.
Finally, the Alliance expressed concern with CMS’s proposal to remove several beneficiary complaint and appeals measures from the MA Star Ratings program, noting that these measures are critical to identifying access problems and holding plans accountable for plan behavior that delays or denies medically necessary care. You can read the Alliance’s comments in full by clicking on the link below.






