
Is The Trump 2027 MA and Part D Rule Eliminating The EHO4all Reward For SY 2027 Actually Legal?
While many plans will not cry about the elimination of the Excellent Health Outcomes for All (EHO4all, the former Health Equity Index (HEI)) reward from Medicare Advantage Star Ratings, some plans have invested heavily to make the conversion to the new health equity improvement program. And the big question is whether the Trump administration is violating due process and the Administrative Procedure Act (APA) by eliminating the new reward as of SY 2027 with almost no notice. Here is some of my thinking on this: Some plans could challenge the provision and that would be legitimate. The HEI proposal went through full rulemaking back in 2023. Plans had sufficient notice to plan for the major change. They do not now. They relied on the sunset of the Reward Factor and conversion to the EHO4all Reward in their business decision-making. Federal courts recently cited adequate notice provisions under the APA to







