CMS CY2026 ANOC/EOC Model Updates: What Health Plans Need to Know
CMS made key updates and issued 12 corrections to 2026 ANOC/EOC models. Learn what changed and how health plans can adapt workflows and reduce risk ahead of the next cycle.
By Kelly Altmann Vice President, Member Communications, CODY®, an Imagenet company and Al Valenti, Vice President, CodySoft®, CODY®, an Imagenet company
The Centers for Medicare and Medicaid Services (CMS) released its updated model materials for Contract Year (CY) 2026, including revised templates for the Annual Notice of Change (ANOC) and Evidence of Coverage (EOC). These updates introduce notable modifications to formatting, language, and regulatory references—many of which will require direct action from health plans. From layout adjustments and plain-language mandates to revised guidance around prescription plans and Low-Income Subsidy (LIS) content, the changes reflect CMS’s continued push toward greater clarity, accessibility, and member-centric communication.
Alongside the model release, CMS issued a corrections memo on July 28 that included 12 updates, some of which aligned with revisions previously flagged by Imagenet thought leaders.
In this blog, we break down the most impactful updates, explain how they affect operations, and highlight strategic steps health plans can take now to prepare.
What’s New in CY2026 ANOC/EOC Guidance
CMS’s updated model materials reflect several enhancements aimed at improving clarity, compliance, and member comprehension:
Expanded use of plain language and direct links: Templates now incorporate hyperlinks to provider directories and plan tools, supporting more digital-forward, accessible communication.
Updated benefit and co-pay descriptions: The models include revised language for Medicare Prescription Payment Plans, LIS eligibility and benefits, and cost-sharing charts.
Streamlined language and shorter documents: CMS has refined content to be more concise and digestible, thus reducing redundancy and improving navigation.
Removed outdated references: Legacy terms such as Value-Based Insurance Design (VBID) have been removed or revised to reduce confusion and align with current program standards.
Enhanced formatting and clarity: Updates to benefit charts, glossary terms, and layout support better readability and consistency across documents.
For a detailed look at these model materials, visit the CMS Medicare Marketing Guidelines & Model Documents page.
CMS Issues Early Corrections Memo with Key Revisions
Just one month after releasing the CY2026 model templates, CMS published a corrections memo detailing 12 updates across the ANOC, EOC, and LIS Rider models. Notable revisions include:
Colorectal cancer screening row of the Medical Benefits Chart: Removed barium enema language and added bullet with additional covered screening tests.
Clarified cost-sharing for chronic pain services: Language now specifies that member costs can vary by service type.
Vision row of the Exclusions chart: Updated language to reflect that the benefit is covered under specific conditions.
Reinstated reference to separate Medicare drug plans after an earlier removal was deemed an error.
Clarified catastrophic coverage for Part D drugs: Added the previously omitted word “nothing” to reflect correct member cost-sharing.
A full list of changes is available in the CMS corrections memo.
The Imagenet team is pleased to see CMS adopt several updates that were proactively identified through our internal review process. Our corrections framework flags areas potentially needing adjustments which helps clients stay ahead by minimizing last-minute changes that are typically needed as a result of the CMS corrections memo.
Updates That Demand Operational Attention
These updates may not represent a complete overhaul, but they’re meaningful. Health plans must be prepared to implement them across document workflows, while simultaneously updating compliance protocols, and managing vendor communications and relationships.
Key areas of operational impact include:
1. Template and Workflow Adjustments
Even subtle content or layout changes require updates to how benefit data maps into member-facing materials. CMS logic, formatting engines, and internal review checklists must be refreshed accordingly.
2. Compliance and Member Experience
Precise alignment with CMS templates isn’t just important for regulatory approval; it helps reduce confusion and improve the member experience. Deviations can increase audit risk or delay material approval.
3. Technology and Vendor Readiness
The expanded use of links, footnotes, and formatting nuances calls for more than manual intervention. Plans must ensure their systems—and vendor partners—can accommodate these requirements efficiently.
Strategic Opportunities for Health Plans
Rather than treating the 2026 updates as a checklist exercise, forward-thinking health plans can use this moment to improve how materials are produced, approved, and delivered. Leveraging anticipatory processes ensures clients stay one step ahead—avoiding rework, reducing audit risk, and positioning materials for faster approval.
Recommended actions include:
Audit PBP data workflows: Ensure alignment between source files and CMS expectations.
Modernize document composition: Adopt automation tools that reduce human error and speed up turnaround.
Evaluate translation and 508 protocols: Confirm updates are applied consistently across languages and accessible formats.
Consolidate vendors and governance: Streamline oversight and handoffs for more efficient, compliant outcomes.
Strengthen version control and audit trails: Build repeatable workflows that meet compliance and operational standards year after year.
A Timely Reminder to Modernize Your Approach
The CY2026 ANOC/EOC model updates reinforce CMS’s commitment to clear, accessible, and member-friendly communication. But for health plans, the challenge lies in translating those expectations into efficient, compliant operations—at scale.
Now is the time to assess whether your internal systems and external partnerships are equipped to meet evolving CMS requirements. Acting early helps reduce risk, avoid rework, and create space for more strategic focus heading into 2027.
Imagenet helps health plans navigate change with confidence.
Powered by CODY®, Imagenet’s Member Communications & Reconciliation suite combines deep regulatory expertise with proven technologies. Those include our Plan Benefit Package Module®, Collateral Management Module®, and Print & Fulfillment services, which streamline execution, ensure compliance, and elevate the member experience.
Want to see how your current process stacks up, or explore ways to optimize before next year’s deadlines?
Kelly Altmann is a healthcare communications and strategy expert with over 20 years of experience supporting leading health plans, including Medicare and Medicaid. She brings deep expertise across marketing, compliance, product development, and tech-enabled services. With a strong focus on process improvement and execution, Kelly has a proven track record in MCO consulting and vendor management—delivering scalable, compliant solutions that drive member engagement and operational efficiency.
Al Valenti is a healthcare and technology leader with extensive experience in Medicare, Medicaid, and Marketplace communications. His background spans product development, implementation, training, and client support, with a focus on technical sales and business analysis for MCOs. Al excels at translating complex technical solutions into strategic value, bridging the gap between healthcare and technology to drive innovation, streamline operations, and deliver results across cross-functional teams.