A transparency requirement in the contract year 2027 Medicare Advantage and Part D final rule means plans must publicly post the eligibility criteria they develop themselves for certain extra benefits, starting with next year’s plans. The rule, announced by CMS on April 2, 2026, applies to the special supplemental benefits that plans offer to chronically ill members, and the posting duty comes into force for coverage beginning January 1, 2027.
CMS did not change the proposal on the way to the final rule. The agency is requiring plans to post criteria that the plans wrote, not setting the criteria itself.
The posting requirement in CMS’s own words
The CMS fact sheet for the final rule, which carries rule numbers CMS-4208-F3 and CMS-4212-F, says the agency is clarifying eligibility requirements for these benefits and “increasing transparency by requiring plans to publicly post their plan-developed SSBCI eligibility criteria.” SSBCI stands for Special Supplemental Benefits for the Chronically Ill.
The phrase “plan-developed” is the key. Under the program, a plan designs the benefit and decides who qualifies, within limits set by federal regulation. What changes is visibility: the plan’s own test for who gets the benefit has to be public, rather than known only to the plan and the person who asks.
Finalised as proposed, applicable January 1, 2027
The provision was not rewritten in the final rule. The Federal Register document says CMS proposed to strengthen the administration of the benefits “by increasing transparency and clarifying eligibility requirements, including a requirement to make plan-developed SSBCI eligibility criteria publicly available,” and that it was “finalizing this provision as proposed.” The CMS fact sheet describes the posting requirement as codification of a proposal from the contract year 2026 rule.
The document is dated April 6, 2026 in the Federal Register, where it is cited as 91 FR 17384, four days after the CMS announcement. Two dates then appear in the rule and they are not the same. The regulations take effect on June 1, 2026, but the document states they are applicable to coverage beginning January 1, 2027. The posting requirement is therefore a contract year 2027 obligation: it is not in effect for this year’s plans, and it governs the plans that begin coverage next January. That is the sense in which the requirement arrives next year: the 2027 contract year begins on January 1, 2027, a little under three months after this article.
The timing also explains why the requirement surfaces now. Plans prepare their 2027 offerings during 2026, so a rule applicable to coverage beginning in January lands inside the same cycle in which they design benefits and set criteria. The fact sheets read here describe the rule and its start date but do not describe how any plan has responded.
What the rule does not do
The requirement is a posting duty. It does not give CMS approval over each plan’s criteria, it does not standardize them, and it does not say a person who appears to meet a posted test is guaranteed the benefit. The fact sheet’s wording covers criteria the plan develops, and the sources read for this article do not describe a federal template or a single national test for who qualifies.
It also reaches a specific group of benefits. The chronically ill supplemental benefits are a subset of the extras that Medicare Advantage plans advertise. The final rule does not turn every other plan perk into something with a posted eligibility test, which is why this report names the chronically ill benefits and not extra benefits in general.
Debit cards tighten in the same rule
The same section of the fact sheet addresses how plans administer supplemental benefits through debit cards. It says cards must be “electronically linked to plan-covered items and services through a real-time identification mechanism to verify eligibility of plan-covered benefits (products) at the point of sale” and “be limited to the specific plan year.” It also states that cannabis products illegal under state or federal law are not allowable as these benefits.
Those provisions are separate from the posting rule, but they share its contract year. Together they describe the final rule’s approach to special supplemental benefits: a public statement of who qualifies and a card system that checks purchases against what the plan covers.
When plan shoppers can see the 2027 offerings
The contract year 2027 plans are the ones on offer in the coming fall enrollment season. According to Medicare.gov, Open Enrollment runs October 15 to December 7, and coverage chosen in that window begins January 1 of the next year. The posting requirement applies to plans with coverage beginning on that January 1, 2027 date.
The fact sheets read for this article do not give a date by which the postings must appear before enrollment opens, and that detail is not reported here. What is documented is the obligation, its source, and its start: CMS’s April 2, 2026 final rule, finalized as proposed, applicable to coverage beginning January 1, 2027.
Extra benefits and the plan-written rules for who qualifies
A posted eligibility test tells a member what a plan says it will require for a chronically ill supplemental benefit. It does not say what that benefit is worth next to another plan’s offer, or how it sits beside premiums, drugs and doctors.
The 2027 Medicare Open Enrollment Decision Kit includes a section on pricing extra benefits and a cost calculator spreadsheet that compares plans on cost, drugs and doctors.
Check how the kit prices a plan’s extra benefits before enrolling →
Prepared with the help of AI and verified against the CMS fact sheet and Federal Register notice linked in the text.
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.
