Lexology April 9, 2024
Sidley Austin LLP

The U.S. Centers for Medicare and Medicaid Services (CMS) published a final rule on April 4, 2024 that overhauls the regulations governing insurance agent and broker compensation rates and agreements for Medicare Advantage Plans (MAPs) and Medicare Part D Plans (PDPs). The final rule, which adopts the majority of the changes from the proposed rule that we previously discussed here, is intended to establish additional guardrails to protect beneficiaries and support competition within the industry. This final rule follows CMS’ action last April to revise the regulations governing marketing by MAPs, discussed here. The final rule will take effect on October 1, 2024, the start of the fiscal year 2025 plan year.

For many years, CMS has regulated and capped...

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