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significant differences between the EGWP and non-EGWP market. More specifically, while the majority of plans in the EGWP market are PPO plans, the non-EGWP market is predominantly HMO plans. EGWP individual market bid-to-benchmark ratios are calculated separately for HMO and PPO plan types by quartile. Unlike the HMO/PPO difference between EGWPs and non-EGWPs, there is no data to suggest that a similar difference exists between EGWPs and non-EGWPs regarding negative margin plans upon which CMS can judge the reasonableness of adjusting the bid-to-benchmark ratios to account for negative margin plans. Comment: A few commenters expressed support for the continuation of the policy permitting EGWPs to buy down Part B premiums. Response: CMS appreciates the support. Comment: A few commenters suggested adjusting current rate setting to capture differences in the use of HMO and PPO plans between the EGWP and non-EGWP markets. Commenters stated that it would be more accurate for CMS to segment the benchmark calculation by HMO and PPO products and adjust the bid-to-benchmark ratio for the differing products accordingly. Response: CMS appreciates this suggestion; however, CMS is continuing to apply current methodology for paying EGWPs in CY 2026. Consistent with how CMS has developed EGWP payments since 2019, the CY 2026 EGWP payment methodology takes into account the prevalence of HMO and PPO enrollment in the EGWP market by calculating CY 2026 individual market bid-to-benchmark ratios separately for HMO and PPO plan types by quartile. CMS then takes into account the prevalence of HMO and PPO enrollment in the EGWP market to combine the ratios by quartile. This methodology is more consistent with the county rates for individual market plans, which are also not calculated separately for HMO and PPO plan types. Comment: A few commenters encouraged facilitating greater access to EGWPs in rural markets. Commenters noted that implementing additional flexibilities around telehealth for provider network requirements could address factors that inhibit the formation of direct contract networks and enable more EGWPs to be offered in rural markets. Response: CMS notes this comment is unrelated to our proposals in the CY 2026 Advance Notice. CMS interprets this comment to be an issue related to service areas and network adequacy considerations, rather than EGWP payment policy. Therefore, this comment is outside the scope of this document. Of note, to enable employers/unions to offer coordinated care plans to all their Medicare-eligible members wherever they reside, CMS has waived certain service area requirements for EGWPs; CMS encourages readers to review Chapter 9 of the Medicare Managed Care Manual for more information on EGWP waivers. Comment: A few commenters stated that CMS should work with membership organizations such as the U.S. Chamber of Commerce to enable professional or group associations to pool membership to enroll in EGWPs.