Regulatory Changes: Navigating the Revenue Headwinds Facing Medicare Advantage Plans

February 27, 2025

Navigating the Revenue Headwinds Facing Medicare Advantage Plans

The Winds Have Shifted – Are You Charting a Course or Just Holding On?

For years, Medicare Advantage (MA) plans have sailed forward, buoyed by steady growth, favorable regulations, and reliable risk adjustment models. But in 2024, the winds have shifted. The 2024 Advance Notice from CMS is more than a forecast — it’s a storm warning. If you’re not adjusting your sails, you’re heading straight for the rocks.

This isn’t business as usual. The proposed changes to Part C and Part D payments and the looming impacts of the V28 risk model represent a fundamental shift in the MA landscape. Combined with the relentless push for accountability, transparency, and cost containment, these changes are generating powerful revenue headwinds.

Adaptation isn’t optional. It’s survival.

Regulatory Changes

The Core of the 2024 Advance Notice: A New Reality for MA Plans

In February 2023, CMS released the 2024 Advance Notice, a 130+ page blueprint for a transformed payment landscape. The document outlines key changes that will have ripple effects for years to come. Here are the most critical elements:

1. Part C Risk Model Realignment

The Part C risk adjustment model is being recalibrated, with over 2,000 diagnosis codes eliminated and a shift to the V28 model. The result? An average payment reduction of 3.12%. This isn’t just a tweak — it’s a recalibration of the entire risk adjustment ecosystem. If your coding practices aren’t precise, you’re looking at a revenue drop that could cripple your plan’s ability to invest in member benefits.

2. Effective Growth Rate Adjustment

A technical change to the calculation of the effective growth rate means MA plans will receive lower payments than anticipated. In plain terms: you’re going to have fewer resources to work with in an environment where costs are climbing.

3. Part D Model Stability Amid Rising Liabilities

Despite the Inflation Reduction Act’s (IRA) provisions for lower drug costs and out-of-pocket caps, the Part D risk adjustment model remains unchanged. The result? Plans are left absorbing significant liabilities for drug coverage. The IRA is a win for patients, but for plans, it’s an exercise in financial gymnastics.

4. RADV Final Rule – The Compliance Hammer

The Risk Adjustment Data Validation (RADV) final rule allows CMS to extrapolate audit findings. A small error rate in your data can now translate to massive recoupments. The rule is clear: there’s no room for coding inaccuracies or questionable documentation.

These changes are not isolated events. They are part of a broader movement toward greater accountability, tighter oversight, and reduced spending. If you’re not actively steering your plan through these headwinds, you’re at the mercy of forces that don’t care if you sink or swim.

The Fallout: What These Changes Mean for MA Plans

The implications of these regulatory changes are profound and multi-faceted. Here’s how they’re impacting Medicare Advantage plans right now:

Revenue Compression
The combination of payment reductions and rising liabilities is squeezing margins tighter than ever. Plans that relied on steady revenue growth to fund innovative benefits are now being forced to rethink their strategies. The room for error has disappeared, and the consequences of inaction are measured in millions of dollars.

Investment Dilemmas
Lower revenue means harder choices. Should you invest in member benefits, provider incentives, or technology upgrades? Without a clear strategy, plans risk making cuts that damage their competitiveness and member satisfaction.

Increased Scrutiny and Risk of Recoupments
The RADV final rule has put a target on the back of every MA plan. If your risk adjustment data doesn’t withstand scrutiny, you’re looking at significant financial clawbacks. Plans must ensure their coding and documentation practices are beyond reproach.

Operational Strain
Adapting to these changes requires more than strategy — it requires operational agility. Plans need to streamline workflows, integrate systems, and ensure that every part of the organization is aligned with the new reality.

Regulatory Changes

The Path Forward: Bold Strategies for Thriving in the Storm

The challenges are real, but so are the opportunities. Plans that act decisively can not only weather the storm but emerge stronger. Here’s how to chart a course through the revenue headwinds:

1. Precision in Risk Adjustment
The new risk model demands accuracy like never before. Your coding practices must be flawless, real-time, and backed by documentation. Retrospective fixes are too late — precision must happen at the point of care.

2. Scenario Modeling and Forecasting
Don’t guess — model. Run scenarios to understand the impact of payment reductions, audit risks, and rising liabilities. What does a 3% revenue drop mean for your bottom line? How will different provider engagement strategies affect outcomes? Data-driven insights are your best defense.

3. Invest in Integrated Technology
Siloed systems are a luxury you can’t afford. Integrated platforms that unify risk adjustment, claims, and provider engagement are essential for efficiency and accuracy. Technology that evolves with regulations is the difference between sinking and swimming.

4. Compliance as a Strategic Priority
Compliance isn’t just about implementing processes to prevent penalties — it’s about protecting revenue coupled with enhancing services to increase patient care and treatment. Treat compliance as a core business function, not an afterthought. Regular internal audits, real-time validation, and airtight documentation are your safety net.

How Allymar Health Helps You Navigate the Headwinds

In the face of these challenges, Allymar Health provides the strategic advantage you need. The Medicare Advantage Suite is designed to address the complexities of today’s regulatory environment with precision, agility, and confidence.

●      Real-Time Risk Adjustment:
Capture and validate diagnoses at the point of care, enhancing accuracy and minimizing errors that lead to recoupments.

●      Dynamic Adaptation:
Stay ahead of regulatory changes with a platform that evolves seamlessly. From V28 to RADV audits, Allymar Health helps to enhance compliance and keeps you competitive in the market.

●      Integrated Workflows:
Eliminate silos with a unified platform that connects risk adjustment, claims, and provider engagement. Efficiency isn’t optional — it’s essential.

●      Predictive Analytics and Scenario Modeling:
Anticipate challenges and opportunities with data-driven insights. Develop strategies based on real forecasts, not guesswork.

●      Audit-Ready Compliance:
Enhance your documentation and processes in preparation for audits. Allymar Health helps you sleep at night, knowing you’re ready for whatever comes.

The Storm is Here – Will You Sail Through or Be Blown Off Course?

The regulatory winds are fierce, but they don’t have to sink you. Plans that adapt with precision, strategy, and the right technologywill not only survive — they’ll thrive.

Allymar Health equips you to face the headwinds head-on and come out stronger.

The choice is clear: Steer boldly or drift helplessly.

Which course will you take?


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