Schedule a Call
Request A Demo

Key Medicare Advantage & Part D Compliance Updates (Week of June 16–June 20, 2025)

Beacon Alert:Week of June 16–June 20, 2025

 

As CMS continues refining guidance for Medicare Advantage (MA) and Part D sponsors, the week of June 16, 2025, brought a wave of impactful announcements. These include updated documentation for CY 2025 reporting, enforcement relief on health equity requirements, model document revisions for CY 2026, agent and broker compensation protocols, and a final opportunity for crosswalk changes.

This summary outlines all key updates with actionable compliance insights for Medicare organizations and stakeholders.

📊 CY 2025 Part C & D Reporting Requirements Updated

CMS released new file layouts and technical specifications for upcoming Contract Year 2025 reporting via HPMS. This impacts MA and Part D reporting under standard compliance frameworks.

Released Documents:

  1. Part D Medicare Prescription Payment Plan File Layout

  2. Part C Supplemental Benefit Utilization and Costs File Layout

  3. Part D Medication Therapy Management File Layout

  4. CY 2025 Data Entry Edit Rules

  5. FAQs for Part C Supplemental Benefit Reporting

📍 HPMS Path:
Quality and Performance > Plan Reporting > Documentation > CY 2025
🔗 CMS Part C FAQs

✅ Action Required: Review layouts and FAQs before 2025 reporting begins.

🚫 Enforcement Relief: Health Equity Requirements for MAOs Paused

Effective immediately, CMS is pausing enforcement of several requirements under 42 CFR § 422.137, originally set for July 1, 2025.

Paused Provisions:

  • Requirement for one UM committee member with health equity expertise

  • Mandate for an annual plan-level health equity analysis

  • Obligation to publicly post health equity analysis results

🔔 Note: These requirements are under review and may be formally revised for CY 2027 or later.

📧 Feedback can be submitted via: https://dpap.lmi.org/dpapmailbox

🔒 Still in Effect:
MAOs must still report prior authorization metrics starting in 2026 under 42 CFR § 422.122(c).

📄 CMS Releases CY 2026 Standardized Model Documents

CMS issued updated marketing and enrollment materials for MA and Part D plans for use in CY 2026.

Key Documents Include:

  • Annual Notice of Change (ANOC)

  • Evidence of Coverage (EOC)

  • Errata Notices

  • Formulary (Abridged and Comprehensive)

  • Explanation of Benefits (EOB)

  • Provider & Pharmacy Directories

  • LIS Rider & Premium Summary Table

  • Formulary Change Notices

  • Transition and Prescription Transfer Letters

🔧 Enhancements:

  • Fewer pages, simplified language

  • Streamlined regulatory references

  • Plain language and better formatting

  • Integrated contact details

📌 Compliance Requirement: Plans must adopt updated formats.
📞 Contact your CMS Account Manager or Marketing Reviewer for questions.

💵 Agent & Broker Compensation: Rates and Requirements for CY 2026

Due to ongoing litigation, CMS confirmed a return to pre-2025 rules for agent/broker regulations for CY 2026. Compensation limits have been updated based on region and plan type.

MA & Section 1876 Cost Plans (Fair Market Value):

RegionInitial YearRenewal Year
National$694$347
CT, PA, DC$781$391
CA$864$432
NJ$781$391
PR & USVI$474$237

PDPs:

  • Initial Year: $114

  • Renewal Year: $57

Referral/Finder’s Fees:

  • MA Plans: $100

  • PDP Plans: $25

📌 Submission Window:
June 2 – July 25, 2025, at 11:59 PM ET
📍 HPMS Path: Marketing Module > Compensation Submission

✅ Final Step: CEO/COO/CFO must attest
🚫 No changes allowed after July 25
📢 Public Disclosure: CMS will publish the data before AEP on cms.gov

🎓 Agent & Broker Training Requirements

All agents/brokers must:

  • Complete annual training and testing

  • Score ≥ 85%

  • Understand Parts A, B, C, D, and plan-specific rules

📘 CMS publishes minimum guidelines annually.
🔗 CMS Training & Testing Standards

🔁 Final Crosswalk Exception Deadline for CY 2026

CMS issued a final reminder regarding plan crosswalk exception requests in HPMS.

📅 Deadline: Friday, June 20, 2025, at 5:00 PM ET
📍 Submission Path:
HPMS > Plan Bids > Bid Submission > CY 2026 > Upload > Plan Crosswalk Exceptions

🛑 No further changes allowed after deadline
✅ Plans must verify accuracy to avoid downstream issues with enrollment, marketing, and member notices

📌 Takeaway for Compliance Teams

With multiple deadlines and updates converging this summer, MAOs and PDPs should ensure:

  • Reporting teams review and prep for CY 2025 layouts

  • Compliance departments adapt to paused rules and ensure continued reporting for PA metrics

  • Marketing teams align all member materials with updated CMS formats

  • Broker management teams validate compensation data and complete training/testing protocols

  • Product teams finalize CY 2026 crosswalks before June 20

Additional Modules

Todd Petersen,

Chief Executive Officer & Board Member

Todd brings 22 years of experience in scaling SaaS-based companies within the health plan payer market. He has a proven track record of fostering strong client relationships and building high-performing teams. Todd joined Beacon Healthcare Systems from HighRoads, where he played a pivotal role in providing SaaS solutions for health plan design and modification. His extensive career includes significant contributions to sales and growth at HealthSparq, a web-based consumer enablement solution provider; InstaMed, which facilitates financial transactions among payers, members, and providers; DestinationRx, specializing in Medicare shopping for government and commercial programs; and Ingenix, known for its cost containment technology services. Todd is also an acting board member for Beacon Healthcare Systems.

Jeremy Hays

Vice President of Strategic Accounts

Jeremy is an accomplished executive with extensive experience in health insurance and supporting technology. He is a seasoned sales and operational leader passionate about driving revenue growth and elevating customer satisfaction He has a long track record in Medicare leading teams to consistently exceed revenue targets by developing and executing highly effective growth strategies within organizations like United Healthcare, DestinationRx, and InstaMed, all while nurturing enduring, mutually beneficial customer relationships. Jeremy will be leading the existing Account Management team.

Alexis Elam JD, CHC

Vice President of Compliance

Alexis is a trusted and valued healthcare compliance, privacy, and risk leader with 18+ years of audit, oversight, and effective program management across payors, providers, and SaaS support tools. She specializes in implementing corporate initiatives and software solutions that promote adherence to government contracting and service delivery regulations.

Chris Mahoney

Chief Financial Officer

Chris Mahoney is a resourceful and results-driven senior finance executive with 25+ years of CFO-level experience leveraging keen financial expertise to create cost-efficient and sustainable financial results across both small and large corporate organizations. He consistently demonstrates the ability to critically evaluate and respond to rapidly evolving environments while identifying business-critical financial enhancements and developing proactive and actionable improvement initiatives.
Chris also utilizes business acumen and cross-functional communication skills to routinely produce sophisticated solutions and align all financial activities with strategic business goals. Chris has acquired and integrated businesses, assisted in raising millions in $30mm equity and debt through private placements, transformed a business from a Perpetual to a SaaS model, assisted in growing businesses from $250mm to $1bn, and has implemented Project Accounting systems, cost, and management information systems.

Ken Stockman

Chief Executive Officer
Ken Stockman, Founder and Chief Executive Officer of Beacon Healthcare Systems, is a seasoned healthcare executive with strong Payer and Provider experience focused on bringing innovative solutions to Government program revenue management, operations, compliance, and risk adjustment. Ken was an early leader in the Medicare Advantage Risk Adjustment industry building a full suite of tools such as Full Enrollment, Member Reconciliation And Part D Platform to support the health plans’ initiatives in 2006 as co-founder and former CEO of Dynamic Healthcare Systems, Inc. His expertise in Risk Adjustment Strategy, Transaction Processing And Analytics positions him as a unique subject matter expert. Additionally, his experience in CMS Transaction Processing And Regulatory Requirements led to the successful design and implementation of industry-leading information systems.