The Center for Medicare and Medicaid Services (CMS) on December 16, 2025 answered LeadingAge’s questions about the implementation and timing of a new Medicare Advantage (MA) data collection initiative.

In its memorandum, the agency explains its decision to roll out the data collection first as a voluntary pilot in 2026 and then to all plans sometime in the future.

The initiative, originally finalized by CMS, with approval from the Office of Management and Budget (OMB), in September 2025,  required all MA plans to report service-level data regarding their initial determinations and appeals related to both coverage (including prior authorizations) and claims payment decisions. However, the agency did not specify the implementation year, leaving the date as “effective January 1, 20XX”.

CMS suggests in its recent announcement that the voluntary pilot is basically designed to test the data collection with a “select number of MA plans” beginning in late 2026 and make tweaks and improvements before a full-scale implementation. While there are merits to testing, LeadingAge and other provider organizations question whether this is another step in the agency’s rolling back MA requirements that support MA plan compliance with and accountability for following Medicare regulations. It raises the question if it will ever be fully implemented.

Back in 2024 prior to the data collection effort finalization, CMS sought stakeholder input and recommendations on the data elements that should be collected. LeadingAge offered comments and recommendations for improving the data to be collected and many of them were included in the finalized initiative. The service level data collection was an important policy victory following many years of advocacy.

CMS indicated in its May 2025 Federal Register notice that this data collection, “would provide key data to CMS on the utilization of benefits, enhance audit activities to ensure plans are operating in accordance with CMS guidelines and ensure appropriate access to covered services and benefits.”

LeadingAge shares that belief that this data, if collected across all MA plans, could provide a comprehensive picture of their prior authorization and payment denial patterns identifying areas for future reforms to MA plan practices. CMS’s December memorandum offers no opportunity for public comment. Nonetheless we will continue to advocate for full implementation of this initiative across all plans.