The CMS deadline that looks like it needs no action — and the money hiding behind it.
Most CMS deadlines announce themselves. This one hides.
On August 12, 2026, CMS quietly sent a two-page reminder to Medicare Advantage plans about something called the Full Risk Option. It changes no policy. It introduces no new rule. And for many plans, the correct response is to do absolutely nothing — which is exactly why it's dangerous.
Because "do nothing" and "check nothing" are not the same thing. There's a September 18, 2026 deadline buried in here, and behind it sits a payment decision that, for the right contract, is worth real money.
Here's what it is, who it touches, and the ten-minute task that keeps it from biting you.
Reference: CMS memo, "2027 Full Risk Option Continuance for Part A-only Enrollees," August 12, 2026 — Shruti Rajan, Acting Director, Medicare Plan Payment Group
The quick map: 1 election · 1 deadline (Sept 18, 2026) · Part A-only enrollees · "no change" still means "go confirm"
The oddball group at the center of this: "Part A-only" enrollees
To pay a plan for a member, CMS builds a risk score — sicker member, higher score, higher payment. A good score needs a full year of the member's diagnoses to work from.
New members don't have that year yet. So CMS pays for them with a "new enrollee" score — a demographic estimate built from age, sex, and Medicaid status. No diagnoses, just a reasonable placeholder until real history accumulates.
Now meet the odd case this memo is about. Some members have had Part A (hospital coverage) for a full 12 months, but Part B (physician and outpatient coverage) for less than 12 months. CMS calls them "Part A-only" enrollees, and they've been treated as new enrollees for this purpose since all the way back in the CY 2006 payment rules.
But look closer and something interesting falls out. These members aren't really "new" in the usual sense — they've had a full year of Part A. Which means they've been generating hospital diagnoses the whole time. The demographic placeholder ignores all of it.
That's the opportunity. A member's real hospital diagnoses can add up to a higher, more accurate risk score than the age-and-sex estimate CMS uses by default.
The choice — and the three rules that govern it
CMS lets plans decide how it pays for all their Part A-only enrollees:
"New enrollee" score (the default) — the demographic estimate. Ignores the Part A diagnoses.
"Full risk" score — CMS uses the member's actual Part A hospital diagnoses instead.
Three rules shape how this works, and each one matters:
It's all-or-nothing, at the contract level. You can't hand-pick full risk for your sicker Part A-only members and leave the rest on the default. You choose one method, and it applies to every Part A-only enrollee in that contract. CMS is emphatic about the word "all."
It covers both Part C and Part D. One election, two risk scores — medical and drug. You don't get to split them.
You elect full risk when the diagnoses beat the estimate. The logic is simple: if you believe your Part A-only members' hospital diagnoses will produce a higher score than the demographic default, full risk pays you more accurately — and usually, more. For a contract whose Part A-only population runs sicker than an age-and-sex guess would suggest, staying on the default quietly leaves money on the table.
The trap: "no action required" is not "nothing to check"
Here's where plans get caught.
CMS says it plainly: organizations that already elected full risk and aren't making changes don't have to inform CMS. The election simply carries forward. Read quickly, that sounds like "this memo doesn't apply to me" — and the tab gets closed.
But the memo's actual advice is one step stronger. It tells plans to confirm the status of their election in HPMS — not assume it. And that distinction is the whole ballgame:
If your election is set the way you remember → confirming costs you ten minutes and you move on.
If it's set differently than you think → it carries forward wrong, silently, and you don't discover it until it surfaces in payment, long after the deadline to fix it has passed.
There's no alert for a wrong-but-valid election. It doesn't error out. It just pays you on the wrong basis all year. The only defense is to look.
What to actually do before September 18
If you're changing your election, or electing full risk for the first time: update it in HPMS on the "Update Part A/B Full Risk Option Election Data" screen, no later than September 18, 2026.
If you're keeping your election: you don't have to notify CMS — but log in and confirm it's correct anyway.
The HPMS path:
Home Page → Contract Management → Basic Contract Management → Select Contract ID → Part A/B Full Risk Option Data
Where to send questions:
How the HPMS screen works →
hpms@cms.hhs.govThe election itself, or the policy behind it →
riskadjustmentpolicy@cms.hhs.gov
The bottom line
This is a low-drama memo with a sharp little edge. Nothing changed — and that's precisely the risk, because a memo that requires no action is a memo that's easy to ignore.
But if your contract carries Part A-only enrollees, there's one question worth answering before September 18:
Are your Part A-only members' hospital diagnoses worth more than the demographic default?
If yes, and you're not already electing full risk, this is your window to fix that. If you already elect full risk, you're done — after you log in and confirm the election is actually set the way you believe it is.
The worst outcome here isn't missing the deadline. It's sailing past it, confident in an election you never looked at.