Press Releases
March 8, 2024

Better Medicare Alliance Joins Provider and Patient Advocacy Groups in Urging CMS to Account for Seniors’ Rising Health Care Needs in CY 2025 Rate Notice

Official comment letters from Better Medicare Alliance, Association for Behavioral Health and Wellness (ABHW), agilon health, Meals on Wheels in Hillsborough County, NH, Arizona Nurses Association, and others call on CMS to protect the stability of the Medicare Advantage program for the millions of seniors and people with disabilities who depend upon it.

WASHINGTON—Better Medicare Alliance (BMA), the nation’s leading research and advocacy organization supporting Medicare Advantage, as well as community organizations, providers, health plans, aging service organizations, and beneficiary advocates, submitted comment letters to the Centers for Medicare and Medicaid Services (CMS) urging the agency to account for rising health care utilization when issuing next year’s Medicare Advantage rates.

In its comment letter released today, BMA expressed that CMS’ 2025 Medicare Advantage and Part D Advance Notice risks the stability of the Medicare Advantage program. CMS’ estimated growth rate in the Advance Notice does not fully reflect current medical trends in cost and utilization rates and proposes a technical change to the normalization factor calculation that puts additional pressure on the program.

BMA’s comment letter, and the letters from provider and patient advocacy groups, follow support voiced earlier this year by a bipartisan group of 61 U.S. Senators who sent a letter to CMS urging stability for Medicare Advantage for the more than 32 million beneficiaries who rely on it. Additionally, in January, 65 health care organizations, including community-based organizations, providers, health plans, aging service organizations, and beneficiary advocates at the national and state level, sent a letter to CMS urging the Administration to consider policies that promote stability and support a strong, sustainable Medicare Advantage program.

“Over 32 million beneficiaries rely on a strong and stable Medicare Advantage program to get the care they need when they need it,” said Mary Beth Donahue, President and CEO of the Better Medicare Alliance. “BMA, alongside patient and provider advocacy groups, encourages CMS to prioritize the program’s stability in issuing its final rate notice for CY 2025 to ensure Medicare Advantage remains a high-quality, cost-effective option for beneficiaries.”

Provider and patient advocacy organizations agree, echoing BMA’s concerns that CMS’ proposal does not account for the reality of health care trends:

Association for Behavioral Health and Wellness (ABHW)

“We request that CMS update the effective growth rate to reflect documented increases in Medicare utilization and service cost, especially for those relying on Medicare Advantage for quality behavioral health care. This is critical for individuals who rely on Medicare Advantage for quality behavioral health care.”

agilon health

“Our Network’s concerns regarding the Advance Notice center on our desire for all our Medicare patients, including those in Medicare Advantage, to maintain access to high-quality care at a reasonable cost. We are concerned that the proposals in the Advance Notice amount to significant, downward cost pressures on the program at a time when utilization and medical costs have risen to unpredictably high levels. As Medicare Advantage plans adjust to absorb higher costs and potentially declining benchmark rates, those downstream – patients and providers – will likely feel the greatest impact.”

Meals on Wheels of Hillsborough County (New Hampshire)

“Every day, we witness firsthand the value of in-home care and are grateful for programs like Medicare Advantage that enable us to make a meaningful difference in the lives of seniors. Medicare Advantage allows seniors to take full advantage of our services and live happier, healthier lives. That’s why we strongly urge CMS to stabilize and protect Medicare Advantage. Our patients are relying on it.”

Arizona Nurses Association

“There are over 32 million seniors and individuals with disabilities, including more than 715,000 here in Arizona, who depend on Medicare Advantage for access to high-quality and affordable care. For the benefit of all beneficiaries, I urge CMS to protect and strengthen Medicare Advantage and ensure the stability of the program continues for years to come.”

Click here to read BMA’s full comment.


Better Medicare Alliance is a community of more than one million grassroots beneficiaries and 200+ ally organizations working to improve health care through a strong Medicare Advantage. Learn more at

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