On February 25, 2026, CareFirst BlueCross BlueShield (CareFirst) submitted two comment letters in response to the Centers for Medicare & Medicaid Services’ (CMS) Calendar Year 2027 Medicare Advantage (MA) Advance Rate Notice.
In a joint comment letter signed by CareFirst, Alterwood Health and Kaiser Permanente of the Mid-Atlantic States, we highlighted longstanding challenges in Maryland’s Medicare Advantage market and explained how the proposed rates could destabilize the market. We emphasized payment distortions driven by Maryland’s unique all-payer model and the state’s transition to the AHEAD Model.
In a separate letter, we urged CMS to delay implementation of its proposal to exclude diagnosis information from unlinked chart review records in risk score calculations and to create a narrow exception for established beneficiaries who switch Medicare Advantage plans. We explained how the proposal would disproportionately disadvantage smaller, regional MA plans like CareFirst that are experiencing significant enrollment growth from plan switchers. We also reiterated concerns about CMS’ use of alternative data and methodologies to calculate direct graduate medical education, indirect medical education and kidney acquisition cost carve-out for hospitals participating in the Maryland Total Cost of Care Model.
