AMCP Comment Letter on CMS's Advance Notice of Methodological Changes for Calendar Year (CY) 2026 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies

The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare & Medicaid Services (CMS) for the opportunity to provide comments in response to the “Medicare and Medicaid Programs; CY 2026 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program” (Proposed Rule), issued on July 16, 2025.

On September 9, 2025, the Make America Healthy Again (MAHA) Commission released the “Make Our Children Healthy Again (MOCHA) Strategy,” which follows an earlier report that assessed key drivers of childhood chronic disease, including poor diet, chemical exposure, lack of physical activity and chronic stress, and overmedicalization. Executive Order 14212, signed by President Trump on February 13, tasks the commission with providing government-wide recommendations on policy and strategy to address the identified contributing causes and end the childhood chronic disease crisis.

On August 28, Chairman Crapo announced that Secretary Kennedy would testify before the Senate Finance Committee to preview the Trump administration’s 2026 health care agenda, including the Make America Healthy Again (MAHA) initiative.