With CMS Poised to Roll Back the Mid-Year Notice Rule, Strategic Member Communication Matters More Than Ever

Originally published by Command Direct

In April 2024, the Centers for Medicare & Medicaid Services (CMS) finalized a requirement obligating Medicare Advantage (MA) organizations to send personalized mid-year notifications to members who had not used their supplemental benefits. The rule, codified under 42 CFR §§ 422.111(l) and 422.2267(e)(42), required plans to deliver individualized notices between June 30 and July 31 that detailed unused supplemental benefits and explained how members could access them.

The policy was designed to address longstanding issues around awareness and utilization of supplemental benefits, which CMS has identified as contributing to poorer health outcomes, diminished member experience, and weaker Star Ratings. Benefits such as dental, vision, transportation, meals, and over-the-counter allowances often go underused despite being highly valued by members.

Operationally, the rule presented significant challenges. Plans were expected to aggregate data across internal systems and multiple third-party vendors, verify accuracy at the member level, and generate compliant communications at scale, tasks that required considerable coordination and new infrastructure.

Enforcement Pause: September 2025

In September 2025, CMS issued an HPMS memo pausing enforcement of the mid-year notification requirement. The regulation technically remained in effect, but CMS suspended audits and penalties while it reassessed the timeline and implementation challenges.

The pause provided temporary relief, yet plans were still expected to prepare for eventual compliance.

November 2025: CMS Proposes Rescinding the Requirement

On November 28, 2025, CMS released the Contract Year 2027 Proposed Rule (CMS-4212-P), which includes a proposal to fully remove the mid-year supplemental benefits notification requirement.

CMS explained that its proposal was driven by several considerations. Recent analysis indicated that supplemental benefit utilization may already be higher than previously assumed, reducing the value of a mandated reminder. The agency also acknowledged the administrative and financial burden placed on MA organizations, particularly the complexity of consolidating data across multiple vendors and disparate systems to generate accurate, personalized notices. In addition, CMS noted that much of the required information is already communicated to members through existing materials, raising questions about redundancy.

The proposal is now open for public comment. If finalized, it would eliminate the mid-year notification requirement and remove its associated information-collection burden.

Where Things Stand Today

As of December 2025:

• The requirement remains codified but is not currently enforced

• Plans are not required to issue the notice for 2026

• CMS is actively considering full rescission

• Final action is expected in 2026 as part of the Contract Year 2027 Final Rule

The industry now sits in a transitional period, one where the rule still exists on paper but its long-term future is uncertain.

Updated Perspective: Strategic Priorities for Plans

Even as CMS moves away from a mandated mid-year notice, the underlying challenges that motivated the original policy persist. Supplemental benefit engagement remains inconsistent across MA populations, and a lack of clarity continues to influence member experience, satisfaction, and Stars performance.

For these reasons, plans should maintain momentum and continue strengthening the work already underway. Improved data integration across vendors and internal systems will support better oversight, analytics, and operational reliability. Clear, member-focused benefit communication, regulatory or voluntary, remains essential for improving understanding, increasing appropriate utilization, and supporting stronger CAHPS performance.

CMS’s broader priorities around equitable access, benefit clarity, and member comprehension are not shifting. Even if this specific notice requirement is rescinded, plans should expect continued emphasis on transparency and engagement. Organizations that invest now in structured, proactive communication strategies will be better prepared for evolving regulatory expectations.

The following actions should guide plan decision-making:

1. Maintain and strengthen supplemental benefit data integration.

   The integration work many plans initiated remains critical for long-term reporting accuracy and operational readiness. Stronger data infrastructure also allows plans to respond more quickly to future CMS requirements.

2. Continue developing clear, member-focused benefit communications.

   Thoughtful outreach, even without a regulatory mandate, reduces member confusion, supports preventive care, and contributes to stronger Stars and CAHPS results. Member comprehension continues to be a competitive advantage.

3. Anticipate a continued CMS emphasis on transparency and access.

   CMS’s priorities are consistent and will remain central to oversight. Plans should expect future expectations related to accuracy, clarity, and equitable access to benefits, regardless of this specific rule’soutcome.

4. Strengthen competitive differentiation through better communication.

   Plans have an opportunity to rethink and refine how they communicate supplemental benefits. Proactive education and personalization can create meaningful improvements in member experience and set a plan apart in an increasingly competitive MA landscape.

Introducing the NOTICE Method: A Framework for Sustainable Member Communication

Regardless of whether CMS maintains, pauses, or permanently rescinds mandates like the mid-year supplemental benefits notice, plans benefit from a structured approach to communication. Command Direct has developed the NOTICE Method, a framework that defines the core components of effective communication and supports clarity, actionability, and consistency.

The NOTICE Method provides a foundation for sustainable member engagement that aligns with both regulatory expectations and member needs. It helps plans maintain quality and focus, even as regulatory requirements shift. This involves everything from notifying your members through creating a continuous process for organizational mandate readiness.

Plans can learn more about the framework here:

commanddirect.com/notice-method

Conclusion

The proposed rescission of the mid-year supplemental benefit notification represents a significant policy change, but it does not diminish the importance of clear, proactive communication about supplemental benefits. Instead, it offers plans the flexibility to design communication strategies that support member experience and organizational goals without relying on a strictly defined regulatory template.

Command Direct continues to partner with health plans to strengthen data integration, refine communication workflows, and ensure readiness for whatever direction CMS ultimately takes. Plans that prioritize member engagement, not just compliance, will be best positioned for success in the years ahead.

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