Medicare 2026 Non-Renewal & Service Area Reduction Guide

Relevant to: PDP, PACE, Part D

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.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Click here to read the complete memo from CMS.

Introduction

The Centers for Medicare & Medicaid Services has launched the Contract Year 2026 Non-Renewal and Service Area Reduction Module in the Health Plan Management System. This module is designed for Medicare Advantage organizations, Part D sponsors, and Cost Plans to request a non-renewal or service area reduction. Available starting April 21, 2025, all submissions must be completed by June 2, 2025. Organizations must ensure their submissions are authorized by their designated signatory.

Key Dates and Deadlines

  • Date: April 21, 2025 – Release of the Contract Year 2026 Non-Renewal/Service Area Reduction Module in HPMS
  • June 2, 2025 – Deadline for submitting NR/SAR requests
  • April 11, 2025 – Reference date for the instructions memorandum regarding Plan Electronic Signature Access in HPMS

PACE Compliance

This memo is relevant to PACE programs because it outlines a different process for Programs of All-Inclusive Care for the Elderly (PACE) when submitting Non-Renewal or Service Area Reduction (NR/SAR) requests. Unlike Medicare Advantage Organizations and other plans, PACE Organizations cannot use the Health Plan Management System (HPMS) to submit these requests. Instead, they are required to submit NR/SAR requests on their organization’s letterhead in a PDF format through the following link: https://pace.lmi.org/.

PACE Organizations must ensure that they comply with these specific submission requirements, as failing to do so might result in their NR/SAR requests not being processed. Attention to detail in following this alternative process is crucial for maintaining compliance.

Required Actions

The Centers for Medicare & Medicaid Services (CMS) has announced the release of the Contract Year 2026 Non-Renewal/Service Area Reduction (NR/SAR) module in the Health Plan Management System (HPMS) for Medicare Advantage Organizations (MAOs), Part D sponsors (PDPs), and Cost Plans to submit requests.

1. Submit NR or SAR Requests: Begin submissions on April 21, 2025, and ensure all are received by CMS before June 2, 2025. Navigate to HPMS -> Contract Management -> Non-Renewals/Service Area Reductions -> Submit Non-Renewal or SAR Request. Indicate your request type: Non-Renewal, Full SAR, Individual to EGWP SAR, or SNP SAR.

2. Modify Plan Service Area: For any SAR request involving a removal from a CY 2026 plan service area, navigate to HPMS -> Plan Bids -> Bid Submission -> CY2026 -> Manage Plans -> Set-up Plans to modify the service area before submitting.

3. Authorization Process: Ensure that NR/SAR requests are authorized by the designated CEO/COO/CFO using HPMS. Navigate to Contract Management -> Non-Renewals/Service Area Reductions -> Authorize -> Non-Renewal/SAR Requests for authorization. Check the April 11, 2025, memorandum for details on electronic signature access.

PACE Organizations should use a different process for NR/SAR requests and submit using their organization’s letterhead in PDF format at https://pace.lmi.org/. For inquiries, contact HPMS Help Desk at hpms@cms.hhs.gov or 1-800-220-2028.

FAQs

  • “What is the NR/SAR module in HPMS?”
  • “How can organizations submit a request for Non-Renewal or Service Area Reduction?”
  • “When is the deadline for submitting NR/SAR requests for CY 2026?”
  • “What are the types of SAR requests allowed?”
  • “How do PACE Organizations submit NR/SAR requests?”

Click here to read the complete memo from CMS.

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