CMS launches new WISeR program as insurers reduce PA — are you ready?
Prior Authorization, Population Health, and a Shifting Medicare Landscape
by Charles Baker, VP Compliance Solutions
Hello,
Prior authorization is at a crossroads. Beginning in 2026, CMS will launch its new WISeR program, adding technology-assisted PA requirements for select procedures in fee-for-service Medicare. At the same time, 29 major Medicare Advantage insurers have pledged to reduce their PA lists and streamline processes.
These diverging approaches are converging into a new reality; one that raises critical questions for health plans and providers.
Will tighter controls improve efficiency, or will they deepen inequities and delays in care? How should plans balance compliance with patient outcomes, administrative costs, and interoperability requirements?
At ATTAC, we help organizations navigate these challenges with strategies that protect revenue, reduce burden, and keep members at the center of care.
Policy Update: Mid-Year Supplemental Benefits Notices
On September 8, 2025, CMS issued an enforcement discretion memo pausing the mid-year notification requirement for Medicare Advantage plans under 42 CFR 422.111(l) and 422.2267(e)(42). This rule would have required plans to notify enrollees between June 30 and July 31 if they had not used a supplemental benefit. Enforcement is paused for contract year 2026 and beyond, although plans may voluntarily provide the notice. Evidence of Coverage and other required materials are not affected. (CMS, Mid-Year Notice Enforcement Discretion Memo, 2025.)
The notice was designed to prompt awareness of underutilized benefits such as OTC allowances, dental, vision, transportation, meals, and social supports. Research shows that these benefits are often underused, particularly by low-income and high-need populations. Pausing enforcement may reduce administrative burden for plans but also risks perpetuating awareness gaps among more vulnerable members.
As recent Kaiser Family Foundation research (August 2025) showed, one in four Medicare beneficiaries lived on less than $24,600 in 2024, and half lived on less than $43,200. With many supplemental benefits targeted toward services these enrollees may need, continuing underutilization of these benefits may lead to negative longer term health outcomes increasing plan costs.
Impacts for Health Plans
Most plans had already planned for the implementation of the notices and so the reduction in burden is expected to be moderate. However, impact to beneficiaries may be important consider. Plans may choose send the notice or employ other avenues to get the information into enrollee hands.
- Consider voluntary notices. Even though CMS is pausing enforcement, Plans can provide simple, plain-language reminders to members, especially those with dual status or LIS eligibility to enhance health
stability and outcomes
- Align with provider partners. Share data on supplemental benefit usage with health systems to coordinate outreach and maximize clinical value.
- Integrate benefit reminders into care management and other customer service functions. Use navigators or case managers to highlight supplemental benefits during high-touch interactions with vulnerable members.
FIELD NOTES
Stories from ATTAC’s client work
Smarter Provider Surveys, Stronger Networks, Improved Access to Care
When a national health plan needed more than just provider survey compliance, they turned to ATTAC. Our team transformed fragmented and unreliable access survey data into actionable insights — improving appointment availability, after-hours coverage, boosting compliance, and strengthening their provider network.
Results included:
20% average increase in provider compliance across each campaign
16% improvement in after-hours access
Streamlined reporting that satisfied state, federal and client requirements
Meet The Team: Provider Network Management
🚲 THROWBACK
Jocelyn's very first job was delivering community newsletters to her neighbors by bicycle.
At the heart of ATTAC’s Provider Access and Availability Survey (PAAS) work is our Provider Network Management team, led by Jocelyn Bayliss, SVP. Jocelyn brings deep expertise in network strategy development and contracting, compensation model design, and provider operations for all types of Medicare, Medicaid, and commercial programs.
Her team doesn’t just measure network access and availability, they help plans turn survey insights into actionable strategies that improve provider engagement, streamline operations, and strengthen compliance.
From helping clients across the nation develop and expand their provider networks to designing risk-sharing and Stars incentive models to supporting ACO operations, Jocelyn and her team ensure plans and providers have networks that meet regulatory standards and deliver real value to members.
We’re heading to Palm Desert for the California Association of Health Plans Annual Conference, Sept. 29 – Oct. 1. With deep experience supporting California health plans — from DSNP implementations to DMHC and DHCS audits — ATTAC knows what it takes to help plans succeed.
Connect with Charles Baker and Jennifer Eidam during the conference, or join us for breakfast on October 1, 7:30–8:30 AM. It’s the perfect way to start the final day of CAHP.
