Nearly 47,000 comments hit regulators. Most weren’t written by seniors — they were engineered by insurers and their front groups.
When the federal government opened a public comment period earlier this year on Medicare Advantage payment rates for 2027, which were far lower than what private health insurers had expected from the Trump administration, something remarkable happened. Comments poured in at a record-breaking pace — nearly 47,000 in all, an all-time high for a Medicare rate notice.
Regulators took notice. A senior CMS official, perhaps trying to lighten the mood, joked that the flood of input might be “another innovation related to AI.”
It was a good line. But the reality was less amusing.
According to an analysis earlier this month by KFF Health News, about 82% of the more than 16,400 publicly available comments were identical to a letter that appeared on the website of a secretive advocacy group called Medicare Advantage Majority — a “dark money” organization that does not reveal its funders, other than to say it is “dedicated to protecting and strengthening Medicare Advantage” and is “powered by hundreds of thousands of local advocates nationwide.”
The letter warned that without higher reimbursements, seniors would face higher costs and fewer benefits. It was signed by thousands of people who almost certainly believed they were speaking for themselves. They were speaking for the industry.
The extent of the deception ran deeper than form letters. KFF Health News found at least one case that illustrates the tactic’s recklessness. Corenia Branham, a 90-year-old widow and cancer survivor in West Virginia, said she never submitted any comment to CMS — yet four form letters appeared online under her name. Branham, who isn’t even on Medicare Advantage, was unambiguous about her views: “I wouldn’t recommend it to nobody.” A spokesperson for Medicare Advantage Majority claimed she had responded to an ad on Facebook. Whether she understood that doing so would put her name on federal regulatory comments is another matter entirely.
Alongside the comment flood, insurers and MA associations funded research, launched ads, rounded up signatures, and met with government officials, submitting a barrage of comments arguing the proposed rule would be disastrous for payers and the seniors they serve. The Better Medicare Alliance, backed by the nation’s largest health insurers, led the charge. So did AHIP, the industry’s primary lobbying group. (And don’t believe for a minute that Medicare Advantage Majority wasn’t funded by the industry, too. In my old career in the insurance business I used to work with Washington propaganda shops to help set up front groups like that.)
The advertising blitz was impossible to miss if you spent any time in Washington. If you visited Washington’s Union Station in recent months and checked the monitor listing train departure times, you would be hard pressed to miss the large electronic billboards around them from an organization called the Coalition for Medicare Choices, another front group, featuring worried-looking seniors warning against cuts to Medicare Advantage. Despite billing itself as a grassroots organization, the Coalition for Medicare Choices was founded out of the same offices as AHIP. The Better Medicare Alliance — whose membership includes UnitedHealth, Humana, and Aetna — ran its own paid media campaign. The group spent over $13.5 million on ads, while yet another dark-money group added $2 million more.
What looked like a nationwide groundswell of concerned seniors was, in large part, a carefully coordinated pressure campaign designed to move our tax dollars — tens of billions of them – to insurance conglomerates that operate private Medicare Advantage plans.
This playbook is not new. It has a name: astroturfing. The term was coined in 1985 by Texas Senator Lloyd Bentsen, who described a “mountain of cards and letters” sent to his office demanding his support for a bill favorable to the insurance industry. “A fellow from Texas can tell the difference between grass roots and AstroTurf,” Bentsen famously said. “This is generated mail.”
Forty years later, the insurance industry is still running the same play — only now with the tools of the internet, AI-assisted drafting, Facebook ads, and front groups bearing names designed to sound like patient advocates.
I know this tactic well. I helped write the playbook.
For years, as a senior executive at one of the country’s largest health insurers, I watched — and participated in — campaigns that manufactured the appearance of public support for industry-friendly policies. The goal was always the same: to make regulators and lawmakers believe that ordinary Americans were rising up in defense of private insurance, when in fact it was the industry pulling the strings. We called it grassroots outreach. It was anything but.
Shooting the Messenger: The Campaign to Discredit MedPAC
Flooding the CMS comment docket with form letters was only one front in the industry’s pressure campaign. Another target was the independent agency whose numbers made the strongest case for reform: the Medicare Payment Advisory Commission, better known as MedPAC.
MedPAC is a nonpartisan congressional advisory body with no financial stake in the outcome of Medicare policy. As we reported earlier, MedPAC’s January 2026 status report estimated that Medicare Advantage overpayments are projected to be $76 billion — or 14% more — above what spending would be in traditional Medicare for the same beneficiaries this year. That finding was politically inconvenient for the industry, so the industry set about undermining it.
The Wall Street Journal published an op-ed calling MedPAC’s methodology into question, with the editorial board going so far as to call for MedPAC to be defunded. Industry-backed lobbying groups like the Better Medicare Alliance and the Healthcare Leadership Council – an outfit formed by Humana founder David Jones and other top industry executives in the late 1980s to shape federal policy – amplified the editorial and supported legislation that would dictate how MedPAC’s staff can conduct research.
HENRY KOTULA 