2027 Healthcare Policy Updates for Plans and Health Systems

What should health plans and health systems track as they prepare for 2027? Start with two January milestones: the general deadline for states to implement Medicaid community engagement requirements for certain adults arrives, and a new round of negotiated Medicare Part D prices takes effect. The October Medicare Advantage and Part D rule remains a proposal for contract year 2028.

When do Medicaid community engagement requirements start?

Under current federal law, states generally must implement Medicaid community engagement requirements by January 1, 2027. They apply to certain adults, and exemptions are available. States may begin earlier and may offer short-term hardship exceptions in specified circumstances. Read the CMS Medicaid community engagement fact sheet.

For health plans, check your state’s guidance before updating member notices or renewal materials. For health systems, review how scheduling and financial counseling teams verify coverage and direct patients to enrollment assistance when coverage changes between visits.

Are Marketplace premium tax credits still available?

Yes. Standard Affordable Care Act Marketplace premium tax credits remain available to eligible enrollees. The temporary enhanced credits expired on December 31, 2025. See HealthCare.gov’s guide to Marketplace premium tax credits.

What changes for Medicare Advantage and Part D?

Negotiated prices for 15 additional Medicare Part D drugs are scheduled to take effect on January 1, 2027. Pharmacy and member services teams can use the CMS list when updating materials or preparing to answer member questions. See the CMS list of selected drugs and negotiated prices.

Separately, in October 2026 CMS proposed new provider directory accuracy standards for Medicare Advantage and new reporting and compensation requirements for pharmacy benefit managers in Medicare Part D. The proposal addresses contract year 2028. Plans can review how they verify provider information and track the rule as it moves through the regulatory process. Read the CMS summary of the Medicare Advantage and Part D proposal.

What should health systems watch in Medicare value-based payment?

Medicare value-based payment models remain an area to watch as CMS continues to tie payment to quality performance and spending. Read about CMS alternative payment models.

For a deeper look at the federal healthcare policy issues behind these updates, read Marc Ryan’s full analysis on The Healthcare Labyrinth.