The Centers for Medicare & Medicaid Services moved in February 2026 to suspend new-member enrollment and nearly all outside communications across 45 Medicare Advantage-Prescription Drug contracts run by Elevance Health, the insurer behind Anthem- and Wellpoint-branded Medicare Advantage plans in dozens of states. CMS said the action followed seven years in which Elevance refused to fix Medicare payment data that the company’s own reviewers had already identified as unsupported by patient records. The sanctions never actually took effect. By mid-July, CMS told Elevance the case was closed, a resolution the insurer separately disclosed to its own shareholders months later in a routine securities filing.
CMS Named 45 Contracts by Number in Its February Notice
The notice, dated February 27, 2026, came from John A. Scott, director of CMS’s Medicare Parts C and D Oversight and Enforcement Group, and was addressed to Aimee Dailey, Elevance’s president of Medicare programs. It imposed intermediate sanctions against 45 separate Medicare Advantage-Prescription Drug (MA-PD) contracts, each listed individually by its CMS contract number: 44 local plan contracts carrying the “H” prefix CMS assigns to Medicare Advantage plans, running from H0544 through H9525, plus one regional PPO contract, R5941. The sanctions combined two suspensions — one barring enrollment of new Medicare beneficiaries into any of the 45 contracts, the other barring Elevance from sending those beneficiaries marketing or other member communications — set to take effect March 31, 2026 unless Elevance corrected the underlying problem first. CMS grounded the action in what it called Elevance’s “substantial and persistent noncompliance with Medicare Advantage risk adjustment data submission requirements.”
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Seven Years of Encrypted Flash Drives Instead of CMS’s Own Systems
The dispute traced back to November 13, 2018, when Elevance sent CMS the first of seven letters, the last dated October 10, 2025, disclosing diagnosis codes the insurer’s own retrospective medical-record reviews had found were not supported by patients’ charts. Rather than submitting corrections through the Risk Adjustment Processing System, the Encounter Data Processing System, or the Risk Adjustment Overpayment Reporting module — the only channels CMS accepts — Elevance repeatedly sent the data on encrypted external USB flash drives, a method CMS says it explicitly rejected. CMS wrote back six times between 2019 and 2025 telling Elevance the flash drives did not satisfy its legal obligations; the agency’s October 16, 2024 letter told the company plainly that sending encrypted files did not satisfy its obligations under federal regulation. The disputed codes covered patient visits dating from 2015 through April 2023, spanning Medicare Advantage payment years 2016 through 2024, and mattered financially because an unsupported diagnosis code can raise the monthly payment an insurer collects for that patient under CMS’s risk-adjustment formula.
What a 45-Contract Enrollment Freeze Would Have Meant
Had the sanctions taken effect, existing Elevance members would have kept their coverage; the freeze applied only to new enrollment and to member communications, not to plans already in force. CMS wrote that the suspensions would remain in effect “until CMS is satisfied that the deficiencies upon which the determination was based have been corrected and are not likely to recur,” an open-ended timeline rather than a fixed one. The notice arrived roughly eight months before this year’s Medicare Open Enrollment period, the annual window in which a beneficiary covered by any of the 45 named contracts decides whether to keep an Elevance plan or move to a competing insurer for 2027. CMS also noted the sanction applied to every Medicare Advantage contract Elevance held at the time, leaving the door open for Elevance to argue in a rebuttal that specific contracts should be excluded if they were not implicated in the conduct described.
The Corrective Steps CMS Demanded Before Lifting the Threat
CMS’s notice laid out exactly what Elevance had to do to avoid the sanctions taking effect, broken out by how old the disputed data was. For contracts still active with dates of service inside the standard six-year lookback period, Elevance had to submit the corrections directly through RAPS or EDPS. For older data, or data tied to contracts Elevance no longer held, the company instead had to file a new overpayment report through the RAOR module, explaining why the original data was unavailable and providing an “auditable estimate” of the overpayment along with a description of how that estimate was derived. CMS separately ordered Elevance to stop submitting risk-adjustment data on encrypted external drives altogether, to build internal processes that catch and correct unsupported diagnosis codes within the 60-day window federal law requires, and to sign every future annual certification without modifying or attaching caveats to it.
CMS Told Elevance the Enforcement Process Is Closed
CMS’s notice gave Elevance until March 30, 2026 to submit a signed attestation, from its chief executive or another senior officer, confirming that every disputed diagnosis code had finally been corrected through the required systems, which would have kept the sanctions from taking effect at all. Elevance apparently missed that first deadline, since CMS’s enforcement file also shows an interim corrective-action update dated May 29, 2026. The matter closed five weeks after that: in a July 13, 2026 letter, again signed by Scott, CMS told Elevance it had completed all the corrective action steps as of July 9, 2026, and that the intermediate sanctions would not take effect because the enforcement process for the matter had been closed. Elevance’s own quarterly report to the Securities and Exchange Commission for the period ending June 30, 2026 records that same July 13 notification from CMS, confirming that the sanctions process ended without ever taking effect against the 45 contracts CMS had named five months earlier.
Checking a Medicare Advantage Contract Before October 15
Neither CMS’s sanction notice nor Elevance’s quarterly filing tells an individual Medicare Advantage member which of the insurer’s 45 named contracts covers their own plan, or how to weigh it against other options during Open Enrollment. A beneficiary deciding whether to stay in an Elevance-run plan or move to a different insurer is left to compare plan documents alone, with no CMS notice walking through the tradeoffs contract by contract.
The 2027 Medicare Open Enrollment Decision Kit is a 42-page decision kit with a cost calculator spreadsheet that compares plans on cost, drugs and doctors, a prescription-by-plan comparison, and a provider call script.
Look up the key dates on the Open Enrollment calendar in The 2027 Medicare Open Enrollment Decision Kit.
This article was researched and drafted with the assistance of AI and reviewed by an editor.
David M. Keller is a finance writer based in Columbus, Ohio, covering personal finance and consumer-focused economic topics. He earned his degree in journalism from Ohio University and began his career reporting on local business and economic trends for a regional media outlet. Since then, he has contributed to a variety of online publications, focusing on clear, practical coverage of topics such as cost of living, debt, and everyday financial decision-making.
