New Analysis: No UPCODE Act Would Cut Medicare Advantage Benefits, Raise Seniors’ Costs, and Reduce Enrollment by Nearly 6 Million

Cuts fall hardest on rural and Upper Plains states; findings come amid existing affordability pressures for 35 million Medicare Advantage beneficiaries

WASHINGTON — The No Unreasonable Payments, Coding, or Diagnoses for the Elderly (No UPCODE) Act, S.1105, would sharply reduce Medicare Advantage benefits, increase seniors’ out-of-pocket costs, and slow enrollment growth across every state — with the steepest impacts in rural and Upper Plains regions — according to a new analysis from Berkeley Research Group (BRG).

BRG estimates that the No UPCODE Act would reduce, by 43% to 58% between 2027 and 2035, the resources that support lower premiums, reduced cost sharing, and supplemental benefits —resulting in reduced affordability and fewer benefits such as dental, vision, hearing and transportation services that seniors consistently value.

“This independent analysis of the No UPCODE Act provides a clear picture of how harmful this legislation would be for millions of Medicare Advantage beneficiaries, particularly those in rural areas who already struggle with health care access,” said Mary Beth Donahue, President and CEO of Better Medicare Alliance. “We share policymakers’ goal of improving the Medicare Advantage program, but this legislation is not the answer. It would increase seniors’ health care costs, reduce crucial health benefits, and weaken care coordination that beneficiaries count on. We can strengthen Medicare Advantage while protecting seniors, and we are eager to work with policymakers on solutions.”

BRG also finds that the legislation would:

• Increase seniors’ costs or require new premiums of approximately $2,663 per year — about $222 per month — for plans to maintain today’s level of benefits, including services like dental, vision, hearing, and transportation;
• Cut total Medicare Advantage funding by 9%–20% nationally, resulting in a cumulative $1.5 trillion decrease over 10 years relative to current expectations;
• Lead to nearly 6 million fewer Medicare Advantage enrollees by 2035, a 12% decline from current projections;
• Deliver disproportionate losses in states with high local PPO penetration — including North Dakota, South Dakota, Montana, Wyoming, and Minnesota, where support for supplemental benefits would fall 70% or more — with particularly steep impacts on rural seniors who already face barriers to accessing care.

These projected reductions come at a time when Medicare Advantage beneficiaries are already navigating the effects of recent regulatory and funding changes. The analysis highlights how large-scale shifts to risk adjustment can alter the care environment for seniors with complex needs — particularly those in rural and underserved communities — and may disrupt progress toward more coordinated, value-based care.

As policymakers evaluate the No UPCODE Act, BRG’s findings offer important insight into how changes to Medicare payment rules shape the experience of more than 35 million people who choose Medicare Advantage. Better Medicare Alliance welcomes continued dialogue with Congress and the Administration to ensure any future reforms strengthen program stability and support high-quality care for seniors and people with disabilities.

Read BRG’s full analysis here.

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Better Medicare Alliance is a community of hundreds of thousands of grassroots beneficiaries and 200+ ally organizations working to improve health care through a strong Medicare Advantage. Learn more at bettermedicarealliance.org.