Can your organization actually run a Medicare Advantage plan?
Four things have to be true before anything else: you can hold a state risk-bearing licence in every county you want to serve, you can fund 12–18 months of build before a dollar of premium arrives, you can contract or already own an adequate network, and you have a compliance function that will survive a CMS readiness review.
Work on all four starts now, because they must all be finished before a February application.
What this stage actually is
This is the stage with no CMS deadline and the highest failure rate. Nobody rejects you here — you simply arrive at the application unable to file. State licensure alone commonly runs 6–12 months, which means a CY2028 application in February 2027 requires licensure work underway in 2026.
What you must do
- Confirm the contracting entity. CMS requires the applicant to be a state-licensed risk-bearing organization in every state in the service area, or to qualify for a waiver.
- Model capital. State risk-based capital requirements plus working capital for the pre-revenue period. Model a scenario where year-one enrollment lands at 50% of target.
- Choose the product. MA-only, MAPD, D-SNP, C-SNP or I-SNP. A D-SNP additionally requires a State Medicaid Agency Contract, which runs on the state’s timeline, not CMS’s. Start that conversation first.
- Test the four capability gates — network, care management, claims and enrollment operations (built or vendored), compliance.
- Get into HPMS. User IDs, connectivity and role setup take weeks and gate everything downstream.
- Build the market thesis — target counties, penetration runway, incumbent set, benefit position.
Key dates
| What | When | Date status |
|---|---|---|
| State licensure filing | 6–12 months before application | plan backward |
| D-SNP State Medicaid Agency Contract | State-determined | varies |
| HPMS access request | ≥ 8 weeks before NOIA | practice |
About the dates on this page. CY2027 dates are published CMS facts. CY2028 dates marked statutory are fixed by regulation. Dates marked projected are the pattern from the CY2026 and CY2027 cycles — CMS has not published them yet, and we relabel them the day it does. How we label data and dates →
CMS forms, systems and references
- Medicare Managed Care Manual, Chapter 11 — MA application procedures and contract requirements
- 42 CFR Part 422 Subpart K — contract requirements
- CMS Medicare Advantage application page and HPMS
Common mistakes
- Assuming next year is available. It usually isn’t. Confirm which contract year you are actually building for before you brief a board.
- Treating the D-SNP State Medicaid Agency Contract as a CMS-timeline item. It is the most common cause of a D-SNP entrant slipping a year.
- Leaving HPMS access to the last month. It is a prerequisite, not an administrative detail.
Tips for success
- Name a single regulatory programme manager now. Every downstream deadline has a short cure window and needs one owner.
- Choose counties on runway and network feasibility together — a county you cannot staff adequately comes off the list regardless of its growth.
- Decide your right to win explicitly. Provider-sponsored plans win on network and care model; D-SNPs win on Medicaid alignment. Neither wins on benefit richness against a national carrier’s scale.
The data you need for this stage
- MA penetration by state — where the runway is
- Dual-eligible density — D-SNP viability
- Plan benchmarking — who you’d be competing against, and whether their stars are falling
So what / Now what
This stage has no deadline, which is exactly why it slips. Every date in stages 2 through 5 is fixed; this is the only stage where you control the clock, and it is the one that determines whether you make the rest of them.
- Start the readiness checklist and assign every item an owner and a date.
- Screen candidate counties in Market intelligence before anything locks.
- If you are considering a D-SNP, open the State Medicaid Agency Contract conversation this quarter.
Provenance — sources and date status
- Source files
- Medicare Managed Care Manual, Chapter 11; CY2027 MA and Part D Final Rule; CY2027 Rate Announcement; CY2027 Part D Bidding Instructions
- Vintage
- CY2027 cycle published; CY2028 cycle not yet posted by CMS
- Last updated
- July 24, 2026
- Refresh cadence
- At each CMS cycle milestone (application posting, Advance Notice, Rate Announcement, final rule)
- Method
- CY2027 dates are transcribed from CMS materials. CY2028 dates are either statutory (bid = first Monday in June; Rate Announcement = first Monday in April; ANOC receipt = Sep 30; marketing start = Oct 1; AEP = Oct 15–Dec 7) or projected from the CY2026 and CY2027 cycle pattern.
- Known limitations
- Projected dates are not CMS commitments and must be confirmed against the CMS application page and HPMS memos when the CY2028 cycle opens. Network adequacy standards and application procedures change between cycles — verify current-cycle instructions rather than reusing prior-year guidance.
Stage 2: Notice of Intent to Apply and application → · All seven stages