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Estimated Impact to MA Plan Rebates and Payments from the No UPCODE Act

December 3, 2025
Intelligence That Works

BRG professionals estimated the effects of the No UPCODE Act on Medicare Advantage (MA) plan payments and enrollment. We estimate the proposal would reduce per-member rebates by 43 to 58 percent and total payments to MA plans by 9 to 20 percent from 2027 to 2035. The proposal would also likely lead to higher out-of-pocket costs for patients seeking care and reduced supplemental benefits such as dental and vision coverage. Alternately, MA plans could continue to offer the same level of benefits, but enrollees would need to pay a new premium of approximately $2,663 per year, or $222 per month. BRG also estimates by 2035 nearly six million fewer beneficiaries would enroll in MA plans relative to baseline expectations for that year, a decrease of 12 percent. In 2035, MA plans would cover approximately 52 percent of the total Medicare population compared to the 51 percent covered by MA plans in 2025.

The research and analyses performed in preparing this paper were sponsored by Better Medicare Alliance.

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