What CMS did
In a June 17, 2026 HPMS memo titled "Update to 2027 Quality Bonus Payment Determinations," CMS said it had voluntarily recalculated the Quality Bonus Payment ratings using only data collected under 42 U.S.C. 1395w-22(e) as of November 1, 2003. In practice that means Part C measures built on HEDIS, CAHPS and HOS data, and nothing else.
Both memos sit behind an HPMS login, so we cannot link them here. CMS publishes its Star Ratings and QBP methodology, along with each year's ratings data, on its public Part C and D performance data page, which is where the recalculated figures will surface for anyone without portal access.
A July 21, 2026 HPMS memo then published the result and told plans what CMS was going to display. MA contracts whose 2027 QBP rating increased in a way that moved their benchmark or rebate amount got a time-limited opportunity to resubmit their CY2027 bids, including bid pricing tools, plan benefit packages and formularies. That window is closed.
Those three figures are quoted directly from the July 21 memo: the QBP ratings "stayed the same for 61 percent of contracts, increased for 9 percent of contracts, and decreased for 30 percent of contracts."
The asymmetry is the story
CMS updated the overall rating displayed in HPMS and on Medicare Plan Finder to match the recalculated 2027 QBP rating on or about July 22, 2026, and the memo is explicit that it did so "for only those contracts that had an increase in their QBP rating." The updated 2026 Star Ratings Data Tables and the CY2026 Landscape files went up the same day, on the same basis.
So a third of the field moved down on payment and the public display does not show it. CMS made that choice deliberately. A footnote in the memo adds a wrinkle underneath it: if an impacted contract decided not to resubmit its CY2027 bid, its overall rating is not updated in HPMS, on Plan Finder, or on cms.gov. Two contracts with identical recalculated ratings can therefore display differently, depending on whether each one resubmitted.
If you are benchmarking competitors off Plan Finder this month, that is the caveat. The displayed overall rating is currently a mix of recalculated ratings for some contracts and prior ratings for others.
QBP rating versus displayed Star Rating, in short
These two numbers look identical on a slide and do different jobs. The recalculation only touched the first one.
| QBP rating | Displayed Star Ratings | |
|---|---|---|
| What it is | The rating used to determine the quality bonus payment, which sets the benchmark and the rebate percentage | The measure-level, domain, and Part C and Part D summary ratings published for beneficiaries |
| Who reads it | CMS payment systems, your finance and actuarial team | Beneficiaries on Plan Finder, and CMS for non-payment programs |
| Changed in this recalculation | Yes, for 39% of contracts, up or down | No. CMS made no changes to measure-level, domain or summary ratings. |
| What it still drives | Benchmark, rebate, and the CY2027 bid | Low-performing icons, past-performance evaluation for Part C and Part D applications, and contract terminations |
| What was updated on Plan Finder | The overall rating display, for increases only | Nothing |
The practical consequence: a contract whose QBP rating fell has a real payment problem and no change at all in its low-performing exposure or its application posture. A contract whose QBP rating rose gets a better benchmark, and nothing moved on its public quality display.
What a Stars or finance team should check
The bid resubmission window has closed, so this is a reconciliation exercise rather than a fire drill. Four things to confirm before the 2027 Star Ratings publish in October.
- Confirm which of your contracts moved, and in which direction. The recalculation was contract by contract. A parent organization can easily have contracts in all three buckets, and finance needs the direction per contract to true up the CY2027 revenue model.
- Pull the refreshed files. The updated 2026 Star Ratings Data Tables sit on the CMS Part C and D performance data page and the CY2026 Landscape files on the prescription drug coverage page, both posted on or about July 22, 2026.
- If a contract landed at 5 stars overall, start the SEP motion now. Contracts at 5 stars overall in the updated ratings can market the continuous enrollment special election period. Updated 2026 Star Ratings marketing templates are in HPMS, and CMS states that previously approved marketing materials do not need to be resubmitted if the only revision is updating the Star Rating. That is a real permission most teams will not know they have, and it is worth using before the October ratings reset the field.
- Do not read a QBP decrease as a low-performing signal. The measure-level and summary ratings that feed the low-performing icon did not change. If your Stars narrative for the board leans on the recalculation, keep the two numbers separate or the conversation will go sideways.
What did not change
CMS was direct about the scope: "The recalculation only impacts the rating that is used for payment purposes; thus, we are not making any changes to the measure-level, domain, and Part C and D summary ratings on MPF or www.cms.gov." The memo goes on to say CMS will continue to use the existing measure-level, domain and summary ratings for non-payment programmatic purposes, naming Plan Finder display including low-performing icons, past-performance evaluations for Part C and Part D applications, and contract terminations.
Your cut points, your triple-weighted measures and your 2027 glide path are all unaffected. The work that moves the displayed rating is the same work it was in June.
Where this sits in the CY2027 calendar
The recalculation landed in the middle of the busiest stretch of the contract year. Rebate reallocation for CY2027 ran July 28 to August 6, 2026, the voluntary de minimis intent window ran August 7 to 11, and final actuarial certification is due August 12, 2026 at 11:59 p.m. PDT. The 2027 Part C and D Star Ratings go live on medicare.gov in early to mid October 2026, and the Annual Election Period opens October 15.
Every one of those dates, with the owner and the consequence attached, is in the CY2027 operating calendar. For what changes in the ratings themselves next cycle, see the 2027 Medicare Star Ratings changes.
A note on sourcing
Everything above comes from the July 21, 2026 HPMS memo "Availability of Updated 2026 Star Ratings Data on Medicare Plan Finder and cms.gov," which was retrieved from the official CMS weekly memo packet for July 20 to 24, 2026 and read in full. The underlying June 17, 2026 memo, "Update to 2027 Quality Bonus Payment Determinations," sits in an earlier weekly packet and was not read directly. If you need the methodological or legal rationale for the recalculation rather than its result, pull that memo from HPMS. Questions on the ratings go to PartCandDStarRatings@cms.hhs.gov.