In early April, the Centers for Medicare & Medicaid Services (CMS) released final Medicare Advantage (MA) and Part D payment and policy changes for the 2026 plan year. These changes were issued through three documents: the Contract Year (CY) 2026 Policy and Technical Changes final rule, the MA and Part D Rate Announcement, and the Final Part D Redesign Program Instructions. Initially proposed under the Biden administration, some provisions were finalized as proposed or with modifications, while others were left unaddressed.  

Provisions that were deferred or implemented in a more limited fashion may signal areas the Trump administration could revisit in future policymaking. Several key areas to watch for Part D include: 

Coverage of Anti-Obesity Medications (AOMs): In the CY 2026 final rule, CMS did not finalize the proposed coverage of AOMs for treatment of obesity under Medicare Part D or Medicaid. Like other policies that were not finalized in the rules, CMS did not provide additional details on stakeholder feedback or the rationale for this decision. However, given the Make America Healthy Again initiative, the Trump administration may still focus on obesity prevention and treatment, potentially through a Center for Medicare and Medicaid Innovation demonstration or other regulatory action. Future efforts could target broader obesity prevention and treatment interventions in addition to AOMs. 

Standalone Prescription Drug Plan (PDP) Premium Stabilization Demonstration: In the Rate Announcement, CMS stated that it would evaluate CY 2026 bid submissions to “assess the need for, or effectiveness of, the elements of the [PDP premium stabilization] demonstration.” With 2026 bids due by June 2, plans will have less than six months of experience with the new 2025 benefit design to inform their bids. Plans will face additional uncertainty about the future of the demonstration. As noted in the Rate Announcement, CMS may rely on its ability to negotiate proposed bids with plan sponsors to address any significant changes in premiums. All of these factors are likely to impact plan offerings and premiums for 2026. 

Medicare Prescription Payment Plan: The rule finalized automatic re-enrollment into the Medicare Prescription Payment Plan for 2026 and makes some adjustments to beneficiary notification requirements. However, policies for 2026 remain largely unchanged from 2025. As plans, pharmacies, and beneficiaries gain experience with the program, CMS may continue to explore future policy changes, such as revisiting point-of-sale enrollment.  

Successor Regulation for Selected Drugs under the Medicare Negotiation Program: CMS finalized the more limited proposal allowing immediate formulary substitutions of selected drugs with generics and interchangeable biologics only. CMS declined to adopt policies for biosimilar substitutions or allow for broader substitutions via formulary maintenance changes. However, CMS noted that it may identify other successor regulations in the future.  

Pharmacy Protections: CMS did not address proposed policies to strengthen pharmacy protections related to plan sponsor pharmacy networks or contract negotiations. However, with the Trump administration’s ongoing interest in transparency and other pharmacy benefit manager practices, CMS could address these issues as part of broader actions on these topics.  

Future decisions in these policy areas could have wide-reaching effects on Part D plan offerings, benefit designs, patient access, and broader market strategies in the coming years. As such, these open policy areas present significant opportunities for stakeholders to engage with CMS and shape future action.  

To learn how Part D policy changes may impact your organization, connect with us.