ACAP Statement on 2025 Medicare Advantage Final Rule  


FOR MORE INFORMATION: Jeff Van Ness, (202) 204-7515, 


WASHINGTON—Margaret A. Murray, Chief Executive Officer of the Association for Community Affiliated Plans (ACAP), issued the following statement regarding the Announcement of Calendar Year 2025 Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies:

“We have substantial concerns with where CMS landed on MA-PD rates in two respects. 

“First, the assumptions CMS used to inform the Part C rate components don’t sufficiently take into account the increased utilization associated with high-need, high-risk Medicare beneficiaries served by Safety Net Health Plans.  

“Second, with respect to Part D, we are concerned that the adjustments to the Part D risk adjustment model understate the true cost of the highest need dually eligible individuals enrolled in fully-integrated and highly-integrated D-SNPs offered by Safety Net Health Plans.  

“Safety Net Health Plans in the Medicare Advantage space which serve people who are dually eligible for Medicare and Medicaid generally operate on slim margins. These small differences in rates and risk-adjustment accuracy make an outsized difference in their sustainability. As our members assess the impact of this rate notice on their 2025 benefit offerings, we will continue to work with CMS to recognize the diversity of plans operating D-SNPs, and the impacts that changes to the rate components have on Safety Net Health Plans.   

“We understand the need of CMS to constrain the growth of costs – Safety Net Health Plans take their role as stewards of public resources very seriously indeed. But we have substantial concerns about where rates for Medicare Advantage plans have landed for 2025.”

About ACAP:
ACAP represents 79 health plans, which collectively provide health coverage to more than 25 million people. Safety Net Health Plans serve their members through Medicaid, Medicare, the Children’s Health Insurance Program (CHIP), the Marketplace and other publicly sponsored health programs. For more information, visit 


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