CMS Proposes Medicare Advantage, Part D Reforms; 340B Rebate Delay Bill
CMS issued a proposal to overhaul Medicare Advantage and Part D while a House bill aims to delay the finalization of the 340B rebate model, creating uncertainty for insurers, pharma, and providers.
CMS’s proposed rule, part of the Consolidated Appropriations Act, 2026 implementation, intends to rethink how Medicare Advantage plans reimburse providers and to reshape Part D drug benefit structures, potentially tightening premiums and altering benefit tiers for beneficiaries.
A concurrent bipartisan House bill would delay the finalization of the 340B rebate model, giving manufacturers and hospitals additional time to adjust to the new pricing framework. The combination of a CMS proposal and congressional action creates a period of regulatory uncertainty for all stakeholders—plans, pharmacy benefit managers, manufacturers, and covered entities—who must prepare for possible changes in data submissions, reimbursement formulas, and compliance timelines.
Lawyers should advise clients on scenario planning, risk assessment, and early engagement with CMS technical assistance programs to mitigate exposure. The roadmap for the rule’s approval and the bill’s passage will affect strategic decisions early next year, making this development a priority for all large‑firm healthcare practices.