The longest government shutdown in U.S. history may impact changes for Medicare Advantage (MA) and Part D plans effective in 2027. Regulatory items that don’t have statutory deadlines, or deadlines set by current law, could have delayed releases.
Statutory Deadlines
The annual advance and final rate notices are the only regulatory items for Medicare Advantage (MA) with statutory deadlines. The federal Centers for Medicare and Medicaid Services (CMS) must release the MA and Part D advance notice of proposed payment rates and policies at least 60 days before releasing the final notice. This ensures that carriers and stakeholders have at least 30 days to review the notice and submit their comments. CMS must also release the final notice by the first Monday in April of that year. For the 2027 plan year, CMS must release the advance notice on or by February 5th and the final notice on or by April 6.
Non-Statutory Deadlines
The annual advance and final rate notices are the only regulatory items for Medicare Advantage (MA) with statutory deadlines. The federal Centers for Medicare and Medicaid Services (CMS) must release the MA and Part D advance notice of proposed payment rates and policies at least 60 days before releasing the final notice. This ensures that carriers and stakeholders have at least 30 days to review the notice and submit their comments. CMS must also release the final notice by the first Monday in April of that year. For the 2027 plan year, CMS must release the advance notice on or by February 5th and the final notice on or by April 6.
Source: “The government shutdown’s impact on Medicare Advantage: As clear as mud?” by Jeffrey Davis and Lynn Nonnemaker, Ph.D., McDermott+, October 16, 2025.
