2026 Medicare Broker Compensation Rates, Training, and Testing Requirements
Relevant to: PDP, Marketing Guidance, PACE
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
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Introduction
The Centers for Medicare & Medicaid Services has released crucial details regarding the 2026 Compensation Plans for agents and brokers. These updates reveal the approved compensation rates, referral fees, and essential submission requirements to ensure compliance. Organizations are instructed to file these rates in the Health Plan Management System by July 25, 2025, with an emphasis on accurate reporting and adherence to training and testing guidelines.
Key Dates and Deadlines
- Date of Memorandum: June 18, 2025
- U.S. District Court Order Date: July 3, 2024
- Last Day for CMS Data Submission: July 25, 2025, by 11:59 pm EST
- HPMS Data Submission Period: June 2, 2025, to July 25, 2025
- Public Availability of CY 2026 Compensation Information: Prior to the annual election period for CY 2026
PACE Compliance
This memo pertains to the PACE programs in the context of changes to regulations affecting Medicare Advantage and Medicare Prescription Drug Benefit Programs as described in the CY 2025 Final Rule. The district court’s stay on the CY 2025 Final Rule means that the amended sections affecting PACE, specifically parts of 42 C.F.R. § 422.2274 and § 423.2274, will not be in effect for CY 2026, at least until the litigation is resolved.
PACE organizations should note that the regulatory language effective before the CY 2025 Final Rule remains applicable for CY 2026. Therefore, compliance with the regulations as they stood prior to the Final Rule is required.
PACE providers must adhere to the following key points:
– Maintain compensation rates for agents and brokers at or below the fair market value (FMV) as stated in the regulations prior to the override. This affects both initial enrollment compensation and renewal compensation.
– Report to CMS whether employed, captive, or independent agents or brokers will be used, along with the compensation rates, by the specified deadline.
– Ensure that all agents and brokers undergo training and testing annually, achieving a score of 85% or higher on the testing component, with training covering the requisite Medicare parts and plan-specific information.
– Use the CMS-provided guidelines for training and testing to ensure quality and compliance as per Medicare’s requirements and encourage augmentation with relevant additional topics.
Keeping meticulous records to demonstrate adherence to these standards and making timely submissions to the Health Plan Management System are crucial for compliance.
Required Actions
1. Submit the agent and broker compensation data for CY 2026 in the HPMS Marketing Module between June 2 and July 25, 2025, by 11:59 pm EST. Ensure the submission is complete with attestation from the CEO, COO, or CFO. No changes can be made after this deadline.
2. Train and test all agents and brokers selling Medicare products to meet the requirement of achieving an 85% or higher score based on the guidelines provided by CMS for the contract year 2026.
3. Review CMS’s minimum training and testing guidelines before developing any organization-specific training and testing programs for agents and brokers to ensure all required elements are covered.
FAQs
- “What are the agent and broker compensation rates for Contract Year 2026?”
- “How are the fair market value amounts for initial and renewal compensations calculated?”
- “What are the submission requirements for agent and broker compensations in CY 2026?”
- “When and where can organizations submit their agent/broker information to CMS for 2026?”
- “What is the testing requirement for agents and brokers under 42 C.F.R. §§ 422.2274(b)(2) and 423.2274(b)(2)?”
- “Where can organizations find CMS’s training and testing guidelines for CY 2026?”
