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setting such separate rates, CMS has established an approach for paying MA organizations for enrollees with ESRD that directly use the rates, rather than bids. As such, the ESRD rates are intended to be the payment rate for Medicare-covered services for enrollees with ESRD, and the ESRD subsidy cannot be paid under the rates used in the bids to determine payment for non- ESRD beneficiaries. Therefore, the ESRD subsidy that is permitted in plan bids for non-ESRD beneficiaries will remain as a mandatory supplemental benefit. MA plans do not bid on ESRD beneficiaries. At this time, CMS does not find it necessary to require that MA plans submit a separate A/B bid for beneficiaries with ESRD. Regarding the commenters’ request that CMS eliminate the ESRD BPT filing requirement, please refer to the final CY 2026 MA bid pricing tool instructions for more information, which will be released in spring 2025. Section I. MA EGWPs Comment: Several commenters expressed their support for EGWPs as an important healthcare option. A few commenters expressed support for the continuation of the current payment methodology for CY 2026, and most commenters expressed appreciation for the inclusion of the preliminary bid-to-benchmark ratios for EGWPs in the Advance Notice to facilitate more accurate benefit and premium information for employers and beneficiaries. Response: CMS appreciates the support. Comment: A commenter requested that CMS provide updated bid-to-benchmark ratios based on February enrollment data in advance of the Rate Announcement release to reduce operational pressures on MA plans with short windows for the negotiation and finalization of bids. Response: CMS appreciates this recommendation. In response to feedback from the industry, CMS began publishing preliminary bid-to-benchmark ratios for EGWPs based on January enrollment data with the CY 2023 Advance Notice. Due to timing and operational constraints, CMS was unable to provide bid-to-benchmark ratios based on February enrollment data in advance of the release of the Rate Announcement. Comment: Some commenters recommended CMS exclude negative margin plans from the calculation of estimated bid-to-benchmark ratios for EGWPs to avoid undermining the availability of supplemental benefits and limiting EGWPs’ ability to expand. Response: As CMS has stated in past Rate Announcements,8 CMS does not believe that there is a reasonable rationale to exclude these plans from the calculation of the bid-to-benchmark ratios because the ratios are intended to be representative of the market. Negative margin plans are included in the non-EGWP market as well, so the bids of such plans are included when the bid- to-benchmark ratios are developed. CMS does adjust for factors which would otherwise result in

8 Please see the CY 2025 Rate Announcement (https://www.cms.gov/files/document/2025-announcement.pdf), CY 2024 Rate Announcement (https://www.cms.gov/files/document/2024-announcement-pdf.pdf), and CY 2023 Rate Announcement (https://www.cms.gov/files/document/2023-announcement.pdf).