Medicare Advantage Service Area Expansion: February Is the Finish Line

For contract year 2027, CMS's dates were: Notice of Intent to Apply (NOIA) deadline January 23, 2026; completed applications due February 11, 2026; bids due June 2, 2026; contracts executed in September 2026. CMS has not yet posted the CY2028 application. The CMS-funded Integrated Care Resource Center lists November 11, 2026 as the CY2028 NOIA date to ensure HPMS access, so confirm that with CMS. The part that matters most for network teams: since CY2024, the network has to pass inside the application itself. February is the finish line of the build, not the start.

Plans that start recruiting after they file the NOIA are already late. Here is the calendar we would work to instead.

The CY2027 dates, and what each one gates

Every date in this table comes from the CY2027 Medicare Advantage Part C application, which notes that "All dates listed above are subject to change." The right-hand column is our read on what each date means for the people building the network.

Date	CMS milestone	What it means for the network team
Nov 18, 2025	Recommended date to submit the NOIA to ensure HPMS access	The build should be well underway. Nobody should be picking counties now.
Dec 1, 2025	CMS User ID form due	Get the people who will upload HSD tables their access now, not in February.
Jan 7, 2026	Final applications posted	Reread the network sections. Attestation language can move.
Jan 23, 2026	NOIA deadline	CMS "will not accept applications from organizations that fail to submit a timely NOIA."
Feb 11, 2026	Completed applications due	HSD tables for the requested service area go in. The network is judged from here.
June 2, 2026	Bids due	The county list is now priced. Late county changes ripple into the bid.
Sept 2026	CMS executes contracts	Every letter of intent should be turning into a signed contract.
Mid-Oct 2026	Annual election period begins for CY2027	Members start choosing you based on the network you built.

Two more dates from the same application are worth knowing. If CMS denies an application, a hearing request must be received within 15 calendar days of the denial notice, and the application said a favorable determination was needed by about September 1, 2026 (a tentative date) to contract for January 1, 2027. The Integrated Care Resource Center's key dates calendar expected qualification determinations for CY2027 applicants in late May 2026.

CY2028: what is known, and what isn't

As of September 30, 2026, CMS has not posted a CY2028 application or NOIA memo on its Medicare Advantage application page. The Integrated Care Resource Center, a CMS-funded technical assistance center, says CMS releases the CY2028 NOIA in mid-October 2026 and lists November 11, 2026 as the CY2028 NOIA deadline to ensure access to HPMS. Treat that as a solid planning date, not a regulatory one, and check it against CMS's memo when it posts.

We won't print a CY2028 application due date, because CMS hasn't published one. If the cycle looks like CY2027, it lands in February 2027. And if you are reading this in the fall of 2026 with an expansion in mind, you are already inside the window where the build should be running.

Why February is the finish line

Under 42 CFR 422.116(a)(2)(ii), "beginning with contract year 2024," applicants for a new or expanding service area must demonstrate compliance with the network adequacy standards as part of the application, and CMS "may deny an application" based on its network evaluation. The application's attestation 3.6.8 asks for a network meeting 422.116 "for each county in the requested service area during the entire contract year," ready for operations on January 1. The HSD tables you upload in HPMS are the proof.

The stakes are asymmetric. MedPAC's June 2024 report says CMS has never imposed intermediate sanctions or civil money penalties for network adequacy noncompliance, and then adds: "However, new applications have been denied on this basis." An operating contract with a gap faces possible compliance or enforcement action. An applicant with a gap can lose the county.

So work the arithmetic backward. If the tables have to pass in February, every provider on them has to be under a signed contract or a mutually signed letter of intent by late January. That means the outreach that produced them started months earlier, because the hard specialties in rural counties do not close in a few weeks. In our experience, the counties that fail in an application actually failed the previous summer, when nobody had yet called the handful of specialists inside the standard. And the first call is rarely the one that works; why providers don't answer recruiting outreach is its own problem with its own fixes.

Three HSD rounds and a ten-day last chance

After you file, the network review runs in three HSD upload rounds: the initial submission with the application, the response to CMS's deficiency notice, and the response to the Notice of Intent to Deny (NOID). Each upload goes back through the automated criteria check.

The third round is the last. The CY2027 application says applicants must meet 422.116 "no later than the Applicant's final upload opportunity, which is in response to CMS' NOID communication." The NOID response window is set in regulation: the applicant must respond "within 10 days from the intent to deny" under 42 CFR 422.502(c)(2)(ii).

Ten days.

That is enough time to fix a mistyped address, add a provider whose contract was already signed, or finish an exception you had mostly built. It is not enough time to recruit a cardiothoracic surgeon. Some plans treat the deficiency and NOID rounds as a recruiting extension, and we think it is one of the most expensive habits in this work, because the only things that close in ten days are things you started in the spring. If you are counting on an exception to cover a gap in these rounds, read how exception requests actually get approved first. MedPAC reports CMS denied 58% of them in 2021.

Letters of intent: a bridge that ends on January 1

Letters of intent are the main reason a spring start still works. Under 422.116(d)(7), applicants may use LOIs "signed by both the MA organization ... and the provider or facility" in place of signed contracts at the time of application and during the review. Applicants must tell CMS they are using LOIs and provide copies on request.

The December 2024 guidance simplified the mechanics. Applicants attest to LOI use in the application and mark "Y" in the LOI column of the HSD table, then remove the "Y" once the contract is fully executed. The December 2023 guidance had required a one-page LOI PDF per NPI with both signatures, plus a group-level matrix, zipped to 500 MB or less. That requirement is gone. Easier paperwork doesn't change what an LOI is, though.

The same paragraph of the regulation gives applicants a 10-percentage-point credit for the pending service area "at the time of application and for the duration of the application review." Two cautions. The credit applies to the percentage-of-beneficiaries test (85% or 90%, depending on county type), not to the minimum provider count. And at the start of the contract year, both the credit and the LOIs end, and the plan must have signed contracts.

This is where we see builds quietly go wrong. An LOI is a promise to negotiate, and the provider on the other side knows your deadline as well as you do. A network that passes in February on LOIs plus a 10-point credit can fall short on January 1 on signed contracts alone, and it will be tested again soon: applicants that used LOIs go through the triennial network review in their first operational year, per the guidance, and the guidance says contracts due for triennial review are prompted to upload in mid-June. Run LOI conversion as its own workstream with its own owner, starting the day each LOI is signed. Open the credentialing file the same day; how long credentialing takes explains why that clock runs longer than most calendars allow.

A working calendar, backward from the application due date

This is the calendar we would run for an expansion, laid against the CY2027 cycle because its dates are published. Rows marked CMS are CMS dates. Rows marked "our rule of thumb" are practitioner judgment, not CMS requirements. Shift the whole thing forward a year for CY2028 once CMS posts its dates.

When (CY2027 cycle)	Months before Feb 11	What happens	Basis
March to April 2025	10 to 11	Choose candidate counties. Pull the current HSD Reference File and Provider Supply file. Score your existing contracted network against each county's minimum counts and time and distance standards.	Our rule of thumb
May 2025	9	Turn the scores into a gap list by county and specialty. Flag the slow ones early, such as cardiac surgery programs, psychiatry and outpatient behavioral health.	Our rule of thumb
June 2025	8	Have the county list and target providers by June, with a named owner on every gap.	Our rule of thumb
July to September 2025	5 to 7	Outreach and contracting, hardest specialties first. Sign LOIs where contracts won't close in time. Start credentialing as soon as a provider says yes.	Our rule of thumb
October 2025	4	Full internal re-score. Decide which counties you are really filing. Start exception evidence only for gaps that are genuine supply problems.	Our rule of thumb
Nov 18, 2025	About 3	Recommended NOIA submission date to ensure HPMS access	CMS
Dec 1, 2025	About 2	CMS User ID form due	CMS
December 2025	2	Re-score when a new HSD Reference File posts (the 2026 file carries an update date of December 17, 2025). Clean every provider name and address.	Our rule of thumb; file date from CMS
Jan 7, 2026	1	Final applications posted	CMS
Jan 23, 2026	Under 1	NOIA deadline	CMS
Late January 2026	Under 1	Freeze the HSD tables. Every row is a signed contract or a mutually signed LOI marked "Y".	Our rule of thumb
Feb 11, 2026	0	Completed application due, HSD tables uploaded	CMS
After filing	After	Deficiency response, then NOID response within 10 days	CY2027 application; 42 CFR 422.502(c)(2)(ii)
Late May 2026	After	Qualification determinations expected	ICRC (secondary source)
June 2, 2026	After	Bids due	CMS
September 2026	After	CMS executes contracts. Chase every open LOI to signature.	CMS; our rule of thumb for the LOI push
Jan 1, 2027	After	LOIs and the 10-point credit end. Signed contracts only.	42 CFR 422.116(d)(7)
During 2027	After	Triennial network review for applicants that used LOIs	CMS December 2024 guidance

The one row we would defend hardest is June. Everything after it is execution. Everything before it is choosing.

Where the calendar actually slips

Three places, in our experience. None of them is the application form.

Silence after the first call. Recruiting timelines don't slip in one dramatic moment. They slip a week at a time, every time a follow-up doesn't happen because the recruiter was chasing a different county.

The standard moves under you. CMS publishes a new HSD Reference File every year, and the changes are not cosmetic. The 2026 Reference File lists 6,862 county and specialty criteria changes from 2025: 4,549 customizations, 1,506 returns to base criteria and 807 county designation changes. A county that passed on last year's file can fail on this year's, so a summer pass is provisional. If your organization already holds a contract ID, the guidance says you can upload to NMM "at any time" to test compliance, and it describes an informal Consultation upload ahead of formal reviews. Use them.

Data that doesn't match. The guidance says providers must be listed at the office where they see patients for consultations, and names and addresses must be submitted identically each time. On builds we've run, the roster is usually where it breaks: the contract says one suite, credentialing says another and the HSD table gets a third. The fix starts at intake, which is why we keep a list of what to collect when onboarding a provider. If your internal numbers look fine and CMS's don't, here is the usual reason.

Start the next build when this one files

A service area expansion is a network build with a CMS deadline at the end, not an application with some recruiting in the middle. Count back from February, put a name on every gap by June, and the NOID window becomes what it should be: ten quiet days of cleanup instead of ten days of phone calls to people who have already said no.

Blueprint is the CRM network teams run that build in: recruiting pipeline, automated follow-up, credentialing status and adequacy scoring on the same provider records. Distance is straight-line today, so a pass shows as unconfirmed until it's measured on roads. You can try the recruit what-if on sample data at the network map, or run your plan through the free build scorecard.