CMS has taken a series of enforcement actions against Medicare Advantage plans over the last two years, suspending enrollment and terminating contracts over issues ranging from network adequacy to financial solvency failures, forming a pattern of Medicare Advantage contract suspensions terminations spanning eight distinct cases.
Recent Medicare Advantage Contract Suspensions Terminations Tied to Financial Metrics
In September, CMS said it would suspend enrollment into an MA-PD plan offered by MMM Healthcare, an Elevance Health subsidiary in Puerto Rico, after the plan failed to meet the 85% minimum medical loss ratio for three consecutive contract years. The plan has no enrolled members, and Elevance said in a statement it would work with CMS to resolve the issue.
Wellcare of Missouri’s Similar MLR-Driven Sanction
In September 2024, CMS suspended enrollment into Wellcare of Missouri’s MA plan after the insurer failed to meet the same 85% minimum medical loss ratio requirement for three consecutive contract years, a sanction that carried into 2025. CMS lifted the suspension for 2026 enrollment after Wellcare reported its 2024 MLR exceeded the 85% threshold.
Medicare Advantage Contract Suspensions Terminations Tied to State Regulatory Action
In August, CMS suspended enrollment into two MA-PD plans from eternalHealth after the Massachusetts Division of Insurance placed the insurer under administrative supervision and required it to suspend new business until it meets certain state financial requirements. It’s the second time in less than two years that eternalHealth has faced CMS sanctions over state regulatory issues.
Aspirus Health Plan’s UCare-Driven Suspension
In February, CMS suspended enrollment into Aspirus Health Plan’s MA plans after the insurer’s third-party administrator, UCare, was placed into state rehabilitation by Minnesota regulators, leaving Aspirus unable to fulfill its federal contract requirement to accept new enrollees.
UCare’s Own Contract Termination Within This Medicare Advantage Contract Suspensions Terminations Pattern
In September 2025, CMS terminated UCare’s MA contracts after the insurer missed an execution deadline amid its wider business closure. This termination, paired with the earlier Aspirus suspension tied to the same underlying UCare rehabilitation, illustrates how a single insurer’s insolvency can cascade into enforcement actions affecting other companies dependent on it as a third-party administrator.
Gold Kidney Health Plan’s Executive and Financial Compliance Issues
In September 2025, CMS suspended enrollment into Gold Kidney Health Plan’s MA plan in Florida after state regulators found the insurer failed to obtain required approvals for certain executive appointments, significantly delayed mandatory filings, failed to provide required financial documents, and showed substantial gaps between projected and actual financial performance. CMS lifted the sanction in December after Florida regulators permitted new enrollments.
Medicare Advantage Contract Suspensions Terminations Tied to Network and Quality Failures
In May, CMS said it was suspending enrollment into Provider Partners Health Plans’ institutional special needs plan in Maryland, effective June 14, after the plan lost all contractual relationships with its long-term care facilities at the end of last year. The agency lifted the suspension in August after the insurer corrected the network deficiencies.
American Health Plan of Texas’s Quality-Driven Termination
In December, CMS terminated its MA contract with American Health Plan of Texas after the insurer failed to meet minimum quality standards for three consecutive years. The plan served about 495 beneficiaries through an I-SNP in Texas, one of the smaller plans affected among these eight enforcement actions.
What This Pattern of Medicare Advantage Contract Suspensions Terminations Reveals
Across these eight cases, the underlying causes span three broad categories: failure to meet minimum medical loss ratio or quality standards over multiple consecutive years, state-level regulatory action tied to financial solvency or executive governance issues, and network adequacy failures affecting vulnerable populations like special needs plan enrollees. This breadth suggests CMS enforcement extends across nearly every dimension of Medicare Advantage plan operation, from financial performance to network management to basic regulatory compliance.
Why Several Sanctions Were Ultimately Lifted
Notably, several of these sanctions, including those affecting Provider Partners, Gold Kidney Health Plan, and Wellcare of Missouri, were later lifted once the insurers corrected the underlying deficiencies, suggesting CMS’s enforcement approach often functions as a corrective mechanism rather than a permanent market exit for plans able to resolve the identified issues.
What This Medicare Advantage Contract Suspensions Terminations Pattern Means Going Forward
With enforcement actions spanning financial, regulatory, and network compliance issues across eight different insurers over two years, Medicare Advantage plans of all sizes should expect continued CMS scrutiny across these same core compliance areas. Given that several sanctions were successfully resolved once insurers corrected the underlying problems, plans facing similar enforcement actions may find a clear path back to good standing by addressing the specific deficiencies CMS identifies, as demonstrated by Provider Partners, Gold Kidney, and Wellcare’s successful resolutions.
What to Watch Going Forward
As CMS continues its pattern of Medicare Advantage enforcement, industry observers will likely watch how quickly MMM Healthcare and eternalHealth resolve their current sanctions, and whether additional plans face similar action tied to medical loss ratio compliance, network adequacy, or state-level regulatory issues in the coming months. Given the recurring role state insurance regulators have played in triggering several of these federal sanctions, this Medicare Advantage contract suspensions terminations pattern underscores how closely intertwined state and federal oversight have become in determining which Medicare Advantage plans remain viable participants in the program.
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