Every fall, the healthcare industry focuses on the Annual Election Period (AEP), competing fiercely for new Medicare Advantage members. But what happens after enrollment is just as critical. But here’s the reality: AEP success is not guaranteed beyond the first 90 days without a strong premium billing system
In fact, CMS’s 2025 Enrollment & Disenrollment Guidance makes it clear: plans are required to process disenrollments “up to 90 days retroactively” for members who fail to pay premiums. A scenario most often driven by billing errors or payment disputes.1
In plain terms: Billing problems are one of the leading causes behind early involuntary disenrollments. Each lost member is not just dropped revenue - it’s also a negative mark against satisfaction scores and ultimately your CMS Star Ratings.
This is where modern premium billing healthcare solutions move from being a “back-end tool” to a frontline member retention strategy.
For more in-depth analysis on optimizing health plan operations, explore our latest Mirra Healthcare Insights.
The Real Cost of Billing Failures in AEP

When billing systems fail during the AEP surge, the ripple effect damages every layer of a health plan in the following ways:
1. Member Trust Collapses
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A wrong invoice or delayed reconciliation immediately undermines member assurance. What began as a confident enrollment decision can quickly spiral into regret and a call to CMS to file a complaint.
2. Complaint Volume Impacts Star Ratings
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CMS specifically tracks complaints about billing/payment disputes. In 2025, CMS will continue double-weighting member complaints and experience measures in Star Ratings reporting.2
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That means every billing dispute doesn’t just upset one member; it directly damages your ratings and future enrollment potential.
3. Operational Costs Escalate
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An incorrect bill = a member call. But many calls don’t stop at first contact; they escalate into formal grievances. According to Deloitte’s 2024 call center operations study, each escalated member call costs health plans between $8 and $12 to resolve.
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For a 50,000‑member Medicare Advantage plan, even a 2% billing error rate could translate into $500,000+ in wasted servicing costs during AEP alone.
By ignoring billing failures, health plans pay twice: first in lost members and lower ratings, and second in avoidable service expenses.
Why Legacy Billing Systems Break Under AEP Pressure

Most legacy billing solutions or manual processes outsourced to TPAs aren’t designed for the AEP enrollment surge.
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Volume overwhelm - Thousands of new members require initial premium invoices within tight CMS timelines. Manual processes break down fast under this load.
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Reconciliation delays - Most Medicare Advantage plans still rely on manual premium reconciliation. McKinsey estimates that nearly 30% of total U.S. healthcare admin spending is wasted on inefficiencies like this, AHA citing McKinsey.3 During AEP, tens of staff hours are lost each week, and bottlenecks occur right when volumes peak.
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Transparency gaps - Billing disputes often start when members don’t understand what they’re being charged or when payments don’t reflect correctly in their accounts. Without self-service access, complaints flood call centers.
The result:
❌ Early disenrollments within 90 days.
❌ Lower Star Ratings due to CMS complaint logs.
❌ Escalation costs that eat into plan margins.
Simply put, plans trying to manage AEP with outdated billing systems risk bleeding both trust and money.
Rising premium volatility has already put cost pressures front and center. As we discussed in our analysis of ACA Rate Hikes: What They Teach Us About Premium Billing for TPAs & Health Plans, plans that can’t streamline billing risk compounding financial strain while undermining member trust.
How Mirra’s Premium Billing System Solves the AEP Pain Points
To overcome these challenges, Mirra Healthcare transforms premium billing from a liability into a strategic advantage. Our premium billing system is engineered specifically for health plans to thrive during AEP, eliminating manual friction, protecting Star Ratings, and reducing cost.
Here’s how:
1. Error Prevention, Not Just Error Fixing
Mirra automates reconciliation and premium posting, so invoices go out accurately the first time, reducing mismatched balances and avoidable disputes.
2. Member Transparency and Trust
We deliver clear, CMS-compliant statements and multiple payment options. This clarity means fewer member questions and faster payment resolution.
3. Operational Cost Avoidance
By eliminating errors, Mirra cuts escalations at the source. That means fewer $8–$12 grievance calls and thousands saved per AEP cycle in servicing costs.
4. Reducing CMS Complaints
Since billing disputes feed into CMS complaint logs, lowering errors helps health plans avoid grievances that negatively impact CMS Star Ratings.
5. TPA Premium Billing Optimization
Mirra’s platform integrates seamlessly to modernize TPA premium billing workflows for payers that rely on third-party administrators - ensuring consistency and compliance across entities.
Industry benchmarks suggest that reducing even a small percentage of billing disputes can save plans hundreds of thousands in call center and servicing costs per AEP cycle. Mirra helps achieve those savings by preventing errors before they reach members.
For health plans seeking a holistic solution to navigate the complexities of the MA market, Mirra offers a complete Medicare Advantage in a Box suite, including robust premium billing.

How Does a Premium Billing System Protect CMS Star Ratings?

Every billing error risks becoming a CMS grievance, and those grievances now weigh heavily in Star Ratings calculations.
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Complaints about billing and payment disputes are logged as grievances with CMS.
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For 2025, CMS continues to give double weight to member complaints and experience in Star Ratings (CMS Part C Reporting 2025).
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Even a slight increase in complaints can drag down scores, limit bonus payments, and weaken your marketing edge in AEP.

Conclusion
Your AEP strategy cannot stop at enrollment. The strength of your premium billing system determines whether members stay, complain, or disenroll within the first 90 days.
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Outdated or manual billing = lost revenue, wasted operational dollars, and lower CMS Star Ratings.
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A modern, automated system = fewer complaints, stronger retention, and protected bonus payments.
In 2025, premium billing healthcare is not a back‑office task but a frontline member retention strategy.
Protect your enrollments and Star Ratings this AEP.
Talk to Mirra Healthcare about our premium billing solutions today. Designed to eliminate errors, reduce servicing costs, and modernize TPA premium billing for compliance and growth.
Reference:
1. CMS: Medicare Advantage and Part D Enrollment and Disenrollment Guidance Updated: 2024
3. AHA: Mobile Data for Operational Efficiency in Health Care: A Path Forward