When do you have to tell CMS you’re applying?
Two deadlines about three weeks apart, both in HPMS. For CY2027 the Notice of Intent to Apply was due January 23, 2026 and the application was due February 11, 2026.
The NOIA is free and non-binding — but without it you cannot file an application at all. Expect the same shape for CY2028, in January and February 2027.
What this stage actually is
The NOIA is CMS’s headcount. It costs nothing and commits you to nothing, and skipping it forfeits the year. The application is the real test: network adequacy, licensure, compliance programme, and — for SNPs — a Model of Care.
What you must do
- File the NOIA in HPMS by the deadline. If there is any chance you will apply, file it.
- Submit the Part C application (and the Part D application if MAPD) with all attestations and uploads.
- Submit network adequacy evidence through the HPMS Network Management Module against CMS time-and-distance and minimum-provider-count standards, for every county and every specialty type. CMS has revised the network adequacy application process in recent cycles — verify current-cycle standards rather than reusing last year’s.
- Provide the compliance programme description and evidence of state licensure.
- SNPs only: submit the Model of Care. For CY2027, initial and renewal MOC submissions were due the Friday before the first Monday in June.
- Staff the cure window. CMS deficiency notices carry short response deadlines through the spring.
Key dates
| What | When | Date status |
|---|---|---|
| Applications posted | Jan 7, 2026 → ~Jan 2027 | published → projected |
| NOIA due | Jan 23, 2026 → ~Jan 2027 | published → projected |
| Application due | Feb 11, 2026 → ~Feb 2027 | published → projected |
| Model of Care due (SNPs) | Friday before the first Monday in June — Jun 4, 2027 | statutory pattern |
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
- MA (Part C) and Part D application packages, posted annually
- Medicare Managed Care Manual, Chapter 11
- HPMS Network Management Module
- NCQA Model of Care review process (SNPs)
Common mistakes
- Missing the NOIA. The cheapest possible way to lose a year.
- Discovering network gaps at submission. Exceptions exist; they are not guaranteed. Test adequacy before you finalise the county list.
- Under-resourcing the deficiency response. Cure windows are short and CMS does not extend them for staffing reasons.
Tips for success
- File the NOIA for more counties than you expect to serve. You can narrow later; you cannot easily widen.
- Run adequacy testing on the candidate county list in the autumn, not in February.
- Keep a single source of truth for the service-area county list — it flows into the bid, the PBP, Plan Finder and marketing.
The data you need for this stage
- Fastest-growing counties — screen candidates on runway, not size
- Compare markets — finalise the county list before the application locks it
So what / Now what
The application fixes your service area for the entire contract year. Every downstream decision — bid, benefit design, network spend, marketing footprint — inherits the county list you file in February.
- Screen and lock your counties now: compare candidate markets.
- Diarise the NOIA date the moment CMS posts the CY2028 cycle.
- Run network adequacy testing on the candidate list before it becomes the filed list.
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.
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