February 11, 2026
National Kidney Foundation (NKF) submitted comments on proposed 2027 Medicare Advantage and Part D changes that could affect people with chronic kidney disease, ESRD, and kidney transplants. Key issues include prescription drug affordability, quality ratings, plan flexibility, and protecting access to dialysis and transplant care. Learn what these updates could mean for kidney patients and their families.
Table of Contents
- Medicare Advantage and Medicare Part D
- Medicare Part D Changes Could Lower CKD Prescription Drug Costs
- Clear, Plain-Language Medicare Information
- Protecting Meaningful Quality Measures in Medicare Advantage Plans
- Greater Flexibility to Change Medicare Plans When Problems Arise
- Looking Ahead: What These Medicare Changes Mean
- Raise Your Voice
Medicare Advantage and Medicare Part D
Medicare Advantage and Medicare Part D play a major role in how many people with kidney disease get their care and medications. For patients living with chronic kidney disease (CKD), end-stage renal disease (ESRD), or a kidney transplant, plan design choices, like drug coverage, provider networks, and out-of-pocket costs, can have a big impact on daily life.
Medicare Part D Changes Could Lower CKD Prescription Drug Costs
NKF supports several proposed changes to Medicare Part D that aim to lower prescription drug costs for people living with chronic kidney disease (CKD), end-stage renal disease (ESRD), and kidney transplants.
The Centers for Medicare & Medicaid Services (CMS) has proposed:
- Eliminating the Medicare Part D coverage gap
- Reducing annual out-of-pocket spending limits
- Removing cost-sharing in the catastrophic phase of coverage
For kidney patients who rely on life-sustaining medications, including immunosuppressants after transplant and drugs that manage complications of CKD, these reforms could make prescription costs more predictable and affordable.
NKF also urged CMS to closely monitor how Medicare Advantage and Part D plans respond to these changes. There is concern that some plans could offset new costs by narrowing drug formularies, adding utilization management tools, or restricting pharmacy networks.
For transplant recipients and people on dialysis, even short delays in medication access can lead to serious health complications. Affordability reforms must not come at the expense of access to medically necessary drugs.
Clear, Plain-Language Medicare Information
Changes to Medicare drug coverage and benefits can be confusing, especially for people managing complex chronic conditions like kidney disease.
NKF emphasized the need for:
- Clear, plain-language communication
- Timely notices about coverage changes
- Culturally and linguistically appropriate information
If Medicare beneficiaries do not understand how their Medicare Advantage or Part D coverage is changing, they may delay refilling prescriptions or skip medications entirely, increasing the risk of hospitalization or transplant complications.
Clear communication helps patients compare plans, understand their out-of-pocket costs, and make informed decisions about their kidney care coverage.
Protecting Meaningful Quality Measures in Medicare Advantage Plans
NKF supports CMS efforts to strengthen Medicare Advantage quality ratings so they reflect outcomes that truly matter to patients, not just administrative processes.
However, we raised concerns about removing certain quality measures that are especially important for people with CKD, ESRD, and complex medical needs.
In particular, measures related to:
- Care coordination in Special Needs Plans (SNPs)
- Member experience and patient satisfaction
These indicators help kidney patients determine whether a Medicare Advantage plan can effectively coordinate dialysis care, transplant services, specialist visits, and medication management.
Removing these measures could make it harder for beneficiaries to compare Medicare plans and select one that supports high-quality kidney disease care.
Greater Flexibility to Change Medicare Plans When Problems Arise
NKF supports proposals that would give Medicare beneficiaries more flexibility to switch plans outside of the annual enrollment period.
This flexibility is especially important for people with end-stage renal disease (ESRD) who may discover mid-year that their Medicare Advantage plan does not adequately cover:
- Their dialysis provider
- Their transplant center
- Specialized kidney services
The ability to change plans when access issues arise can protect continuity of care, prevent treatment disruptions, and reduce financial strain.
Looking Ahead: What These Medicare Changes Mean
Medicare Advantage and Medicare Part D can provide important benefits for people living with kidney disease — but only if drug coverage, quality ratings, and plan rules work in real-world patient situations.
NKF will continue advocating for Medicare policies that promote:
- Affordable prescription drug coverage
- Transparent plan information
- Strong quality standards
- Reliable access to dialysis and transplant care
We'll also continue fighting to protect access to high-quality kidney care remains at the center of Medicare reform discussions.









