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Falling Star Rating trajectory: 2027 Proposed Rule implications

8 December 2025

In November 2025, the Centers for Medicare and Medicaid Services (CMS) released the contract-year 2027 Medicare Advantage (MA) and Part D Proposed Rule. The release included significant proposed policy changes to the Star Ratings program. This paper summarizes the changes and their projected financial and Star Rating impacts.

Key highlights include:

  • CMS proposes to keep the current reward factor, reversing the previously finalized rule that would have replaced it with the Excellent Health Outcomes for All (EHO4All/Health Equity Index) reward starting in the 2027 Star Ratings (2028 payment year).
  • The agency proposes to remove 12 measures over the 2028 and 2029 Star Rating cycles.
  • Depression Screening and Follow-Up is the only proposed addition.
  • CMS estimates that reversing EHO4All—and adopting the proposed measure changes—increases MA payments by $13.18 billion from 2028 through 2036.
  • Medicare Advantage Organizations (MAOs) should expect lower Star Ratings and revenue once the measure removals are implemented.
  • To isolate the impact on the 2026 Star Ratings under the current reward system, we modeled the removal of the 12 measures proposed in the 2027 rule.

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