---
title: "Revenue Opportunity: Significant Non-Par Medicare Advantage Volume 2018-2022"
description: The Kaiser Family Foundation (KFF) annually publishes its Medicare Advantage First Look series, which highlights that many U.S. counties have limited or no contracted Medicare Advantage Organizations (MAOs).
image: https://public.govdataservices.com/hubfs/Doctor%20working%20with%20digital%20tablet%20and%20laptop%20computer%20in%20medical%20workspace%20office%20and%20overcast%20exposure%20effect.jpeg
---

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[Chris Cusimano](https://public.govdataservices.com/the-scoop/author/chris-cusimano) Mar 24, 2025, 8:59:09 AM 2 min read

# Revenue Opportunity: Significant Non-Par Medicare Advantage Volume 2018-2022

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The Kaiser Family Foundation (KFF) annually publishes its *Medicare Advantage First Look* series, which highlights that many U.S. counties have limited or no contracted Medicare Advantage Organizations (MAOs). Since 2023, *Becker’s Hospital Review* has regularly updated an article detailing hospital terminations of MA contracts. Whether hospitals were never contracted with certain MAOs or had contracts terminated, they are classified as “non-contracted.”

Non-contracted providers, including those serving Medicare beneficiaries through MAOs, Cost plans, and PACE organizations, are legally entitled to receive payment for Part A and Part B services at least equal to what would be paid under Original Medicare. This requirement was reaffirmed by CMS in a December 20, 2022 letter to all MAOs, following the Supreme Court's ruling that the ASP-22.5% payment formula used to reimburse 340B hospitals from 2018 to 2022 was illegal.

For 340B hospitals that were non-contracted between 2018 and 2022, it is widely believed they were underpaid for outpatient drugs by MAOs compared to Original Medicare reimbursement, which may be considered unlawful.

However, the KFF source data does not specify which counties have no MA contracts, and the *Becker’s Hospital Review* article indicates that there is limited data available regarding which hospitals are non-contracted with specific MA plans.

If your hospital was non-contracted with an MA plan between 2018 and 2022, we encourage you to contact GDS for a complimentary estimate of potential underpayments. GDS is currently quantifying underpayment amounts for many clients and assisting them with strategies for recovering lost revenue based on the actions taken by other organizations.

![avatar](https://public.govdataservices.com/hs-fs/hubfs/chriscusimano.jpg?width=290&name=chriscusimano.jpg)

#### [Chris Cusimano](https://public.govdataservices.com/the-scoop/author/chris-cusimano)

## RELATED ARTICLES

### [Chris Cusimano Jun 10, 2026, 10:43:33 AM 3 min read Medicare Advantage 340B Underpayment Settlements: What the Public Record Reveals One of the largest reimbursement issues affecting 340B hospitals today remains largely invisible to the public. Start Reading](https://public.govdataservices.com/the-scoop/medicare-advantage-340b-underpayment-settlements-what-the-public-record-reveals)

### [Chris Cusimano Aug 5, 2026, 10:14:12 AM 1 min read CMS FFY 2027 Inpatient PPS Final Rule CMS has released the FFY 2027 Medicare Inpatient Prospective Payment System (IPPS) Final Rule and CMS is placing greater ... Start Reading](https://public.govdataservices.com/the-scoop/cms-ffy-2027-inpatient-pps-final-rule)

### [Chris Cusimano Dec 12, 2024, 1:06:06 PM 3 min read Examining Medicare DSH Qualification and 340b Status Post Medicaid Redetermination The resumption of Medicaid redeterminations is having a substantial impact on Medicare DSH and 340B hospitals. Hospitals are at ... Start Reading](https://public.govdataservices.com/the-scoop/examining-medicare-dsh-qualification-and-340b-status-post-medicaid-redetermination)

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