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Medicare Cost Stability Obscures Structural Uncertainty

September 29, 2025
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Victoria Morain, Contributing Editor

The Centers for Medicare & Medicaid Services (CMS) recently announced that premiums and benefits for both Medicare Advantage (MA) and Medicare Part D will remain stable in 2026, with modest reductions in average monthly costs. On the surface, this announcement suggests program resilience and affordability. But for health system leaders and risk-bearing entities, a flat trajectory in cost structure does not equal strategic certainty, nor does it address rising questions about sustainability, equity, or administrative complexity.

Stability may sound reassuring, but in the context of Medicare’s evolving pressures, it can also signal avoidance of harder reforms.

Beneath the Premiums: Structural Crosswinds

The reported average monthly premium for MA plans is projected to drop to $14.00 in 2026, down from $16.40 in 2025. The average premium for standalone Part D plans is also expected to decline slightly. While these changes may reduce immediate out-of-pocket costs for beneficiaries, they mask broader operational and financial forces at play.

Enrollment in MA is projected to decline, from 34.9 million in 2025 to 34 million in 2026. Though CMS suggests this figure may underestimate actual uptake based on recent trends, the signal is hard to ignore. After years of steep growth, MA may be approaching a plateau.

At the same time, CMS has introduced more aggressive oversight of standalone Part D plan bids, even rejecting those with “unacceptable” premium hikes or benefit cuts. This use of regulatory leverage is a response to a volatile PDP market, but it also reflects rising tension between affordability and actuarial viability. Recent research from Health Affairs has raised concerns about the increasing administrative costs and complexity associated with MA plan operation, trends that are not alleviated by premium stabilization alone.

Narrowing Networks, Expanding Scrutiny

More than 99% of Medicare beneficiaries will still have access to an MA plan in 2026, and 97% will have 10 or more options. But access in number is not access in function. As documented by KFF, many MA plans continue to operate with narrow provider networks, restrictive formularies, and opaque prior authorization processes that limit actual care choice. These structural features rarely appear in headline figures about cost or benefit continuity, yet they shape patient outcomes far more directly than year-over-year premium deltas.

Additionally, the projected decrease in the total number of MA plans, from 5,633 in 2025 to approximately 5,600 in 2026, is small but notable. Whether this reflects market consolidation, increased regulatory pressure, or declining margins for fringe plans is unclear. But for provider organizations negotiating narrow network participation or capitation contracts, even minor reductions in plan variety can have operational impact.

Technology, Transparency, and the Burden of Choice

CMS has added AI-powered prescription cost estimators and more granular provider comparison tools to Medicare.gov. These changes are intended to help beneficiaries navigate increasingly complex plan options during Open Enrollment. While enhanced tools are welcome, the underlying problem remains: choice overload often leads to decision fatigue, particularly among older adults with chronic conditions or cognitive decline.

A recent JAMA study found that more than half of Medicare beneficiaries struggle to identify the plan that best matches their clinical and financial needs, even with assistance tools. As the MA and Part D markets become more competitive and more complex, the burden of understanding shifts further onto the individual, a dynamic that disproportionately affects low-income seniors, dual eligibles, and those with limited digital literacy.

Stability in cost may ease public concern, but it does not simplify the process of selecting a plan that aligns with individual care priorities or long-term needs.

Accountability Versus Affordability in Part D

CMS’s handling of standalone PDP bids this year marks a meaningful shift in tone. The agency rejected bids deemed unjustifiable, exercising a level of authority that has rarely been invoked. This suggests a growing willingness to prioritize structural accountability over short-term market leniency. Yet there are risks: aggressive bid denials may lead to plan exits, regional disparities in availability, or reduced innovation among smaller sponsors.

Meanwhile, the Part D Premium Stabilization Demonstration continues in its second year, aiming to prevent sharp premium swings while restoring competitive dynamics. While nearly all current PDP enrollees are in plans participating in the demonstration, it remains unclear whether this policy will produce sustained pricing predictability or merely delay the reckoning.

Stakeholders should watch how rebate strategies and pharmacy benefit management practices evolve under this model. As shown in a GAO report, variation in negotiated prices, rebates, and out-of-pocket structures across MA-PD plans creates persistent disparities in access and affordability that average premiums do not reflect.

A Strategic Pause or a Systemic Stall?

The optics of stability serve a purpose. They calm markets, signal administrative control, and offer political insulation. But for health system executives, payer strategists, and digital health integrators, stability in Medicare program inputs does not mean predictability in outcomes.

Payment models continue to shift, particularly around value-based design. Regulatory pressures on prior authorization and supplemental benefits are mounting. And while average premiums may drop slightly, the cost of program participation, for patients, providers, and plans alike, continues to grow in complexity and resource demand.

Rather than viewing 2026 as a year of quiet consistency, healthcare leaders should treat this as a strategic pause: a moment to evaluate how current structures align with emerging value, equity, and compliance imperatives. Stability is not a finish line. It is a temporary condition in an ecosystem overdue for redesign.

For this story, HIT Leaders and News used generative AI to help with an initial draft. An editor verified the accuracy of the information before publishing.