Readiness Checklist – Your Roadmap to 2026 Compliance

The CMS Readiness Checklist is more than a compliance requirement—it’s your blueprint for success in 2026. This tool ensures your organization is prepared to meet updated regulations, deliver accurate benefits, and maintain operational integrity. It covers critical areas such as benefit administration, contracting, customer service, and system readiness, all of which impact member experience and CMS confidence in your plan.

Readiness is not just about checking boxes; it’s about building a proactive culture that prioritizes accuracy and transparency. Plans should validate IT systems for enrollment and claims, confirm language access and accessibility standards, and engage cross-functional teams to align on IRA implementation and network adequacy. Documenting readiness and reporting barriers to CMS early can prevent negative beneficiary impacts.

Readiness checklist best practices include using CMS’s checklist to track compliance, conducting mock assessments, and engaging cross-functional teams.  BluePeak recommends the following actions:

• Plan Sponsors assign a responsible party to each requirement on the Readiness Checklist.
• Plan Sponsors should also give responsible parties a reasonable amount of time to confirm their organization is either already compliant or will be compliant with each requirement by January 1, 2026. Given the demands of this busy season, having this request come directly from a Senior Plan Executive will help ensure it receives the appropriate priority.
• Using the checklist, ask if your Plan is compliant with each requirement?
  • If yes: Require the assigned responsible party to document evidence of compliance; and attest that the Plan is compliant with the requirement.
  • If No: Require the assigned responsible party to document a Corrective Action Plan to bring the Plan into compliance with the requirement; Commit to a timeframe for achieving compliance with the requirement.
• The compliance department should track the Corrective Action Plan through to completion and determine how and when to report anticipated non-compliance to the Plan’s CMS Account Manager.