Managing the Mess That CMS Made of the Medicare Advantage Models for AEP 2026

Each year, the Centers for Medicare & Medicaid Services (CMS) release updated model documents that Medicare Advantage Organizations (MAOs) must use to prepare the Annual Notice of Change (ANOC), and Evidence of Coverage (EOC) documents for their plans. These models define the standardized content, formatting, and layouts that need to be updated in these complex documents. MAOs must deliver these documents to members ahead of the Annual Enrollment Period (AEP), which begins October 15.

The model documents for AEP 2026, released on June 16, introduce the most extensive changes in more than five years, impacting not just language but the structure, formatting, and flow of the documents themselves. To make matters worse, CMS released the model documents weeks later than usual. With the September 30th deadline fast approaching, MAOs are under intense pressure to incorporate these sweeping changes on time.

5-10X the Changes of Prior Years

CMS updates model documents to help standardize requirements for plan offerings and, in some cases, to make plan documents more accessible, navigable, and easier for members to understand. For AEP 2026, extensive changes were made affecting nearly all aspects of the ANOC and EOC templates.

Fonts, table layouts, and styling conventions have been adjusted, ostensibly to improve readability. Chapter groupings have shifted, and section and subsection headers have been revised, changing where topics appear and how they’re organized. Some complex passages have been rewritten in plain language, though the application is inconsistent and far from comprehensive. CMS also added new standardized language around insulin pricing and OTC benefit delivery methods, increasing the amount of content MAOs must manage.

Just how extensive are these changes? According to Messagepoint’s internal analysis, EOCs will require at least 6,000 changes, with more complex plan types like DSNPs needing over 12,000. Even the shorter ANOC documents require between 1,000 and 2,000 revisions, ranging from cost-sharing language updates to changes in blue instructional text and eligibility-related clarifications. It’s a volume of change that’s hard to absorb, especially given the timing.

Updating Plan Materials Isn’t Always Easy

Incorporating these changes has been challenging for many MAOs, particularly those relying on manual processes or outdated communication management tools.

Using these outdated methods, teams have had to analyze the new model language and manually apply thousands of individual changes across all document variations—a process that’s slow, error-prone, and resource-intensive. They’ve also had to painstakingly review each set of plan documents line by line to confirm the changes were made correctly. Many organizations have managed this process by emailing PDFs and tracking progress in sprawling spreadsheets, which adds further inefficiency and risk, while making version control a major challenge. A single mistake can trigger multiple rounds of revision, restarting the process from scratch.

This inefficiency quickly cascades downstream. MAOs have less time to incorporate plan data into documents and ensure alignment with their PBP submissions, increasing the risk of inaccurate information being communicated to members. QA windows shrink, making it more likely that errors slip through and reducing the opportunity to gather valuable input from compliance, legal, and marketing stakeholders. Timelines for translation and 508C remediation are also compressed, forcing teams into a last-minute scramble and driving up costs for those that outsource these processes.

Why Automation Is Critical

For Messagepoint customers, the transition to the new AEP 2026 models has been faster, smoother, and far less stressful.

From the moment CMS released the updated models, we’ve been in continuous communication with our Medicare Advantage clients—clarifying what’s new, outlining what’s required, and helping each organization build an implementation plan tailored to its timelines and workflows. As a result, our clients are well ahead of where most MAOs are. Many have completed their migration to the new models, and all are on a clear path to finalizing their documents with time to spare. It underscores the value of having a partner with deep expertise in Medicare Advantage and the operational realities of preparing these materials.

That support is backed by the Healthcare Touchpoint Exchange, our purpose-built platform designed to automate and streamline this process. As part of their Messagepoint subscription, customers are provided with a prebuilt starting point that includes the latest CMS model content and layouts. Instead of manually interpreting and applying each update, they can simply synchronize their prior-year documents with the updated models in the Exchange. Client-specific customizations, including BlueText content, are preserved during this process, avoiding the need to reapply updates manually.

From there, plan data is automatically pulled in using the CMS Plan Benefit Package (PBP) as the single source of truth, ensuring alignment with CMS submissions and eliminating manual data entry. Additional non-PBP plan details, such as contact information and D-SNP plan information, are captured through an intuitive, step-by-step question-and-answer process, enabling accurate and compliant documents for all plans to be seamlessly generated.

The platform’s fully integrated QA module streamlines review and remediation with task tracking, side-by-side document comparison, and a full audit trail. Translation capabilities are also built in, allowing MAOs to begin translating content in parallel with English updates. AI-powered translation and accuracy checks further automate the process, helping teams complete alternate language versions faster and with less manual effort.

Expect Further Change and Disruption this AEP

While MAOs are still working through this year’s model updates, another disruption is likely on the horizon. CMS is expected to issue its annual late-summer memo in August or September and, based on the AEP 2026 models, MAOs should be prepared for similarly broad changes. For organizations without automation, this could trigger hundreds of downstream edits and rework, derailing an already strained process at the worst possible time.

Messagepoint customers are largely insulated from that risk. Their documents are built using a content-centric approach, where shared components are centrally managed and automatically reused across plans. Whether the memo introduces a handful of edits or a sweeping set of updates, the changes can be applied once and instantly flow across all affected materials.

Preparing for the New Normal

This year has made one thing clear: CMS is fully willing to introduce significant changes on short notice. For MAOs, adapting to this “new normal” means rethinking the tools and approaches they use to manage their AEP materials. It’s time to adopt a modern solution with built-in automation and find a partner who has the expertise to guide you through every AEP cycle, no matter how complex.