What Happens When a Medicare Advantage Plan Is Non-Renewed?

When a Medicare Advantage plan is non-renewed, the plan ends on December 31 and the member must choose new coverage for January 1. Members who do nothing can be left in Original Medicare without drug coverage, so these clients need a licensed agent’s attention before the year ends. A non-renewal is different from a benefit cut: the plan no longer exists in the member’s area, either because the carrier terminated the contract or because it reduced its service area.

CMS describes this situation in its 2027 Medicare Advantage and Part D enrollment and disenrollment guidance: plans must give each affected enrollee the effective date of the termination, non-renewal or service area reduction, along with a description of alternatives for getting benefits under Medicare. The required notice time frames sit in 42 CFR sections 422.506 through 422.512 and 423.507 through 423.509.

If a client asks, “Why did my plan send me a non-renewal letter?” the honest answer is that the carrier made a business decision about that plan and county. If a client asks, “Do I lose Medicare?” the answer is no. Medicare eligibility is unchanged; only that private plan is ending.

How Big Are the 2027 Plan Exits?

The numbers are large enough that most Medicare brokers will have affected clients. Reporting from Bloomberg, carried by outlets including the Detroit News and Yahoo Finance, says UnitedHealth confirmed plans covering about 390,000 members are shutting down. Humana said it will cut plans covering about 600,000 people. Combined with reductions at other carriers, at least one million seniors will be forced to switch plans, according to that reporting. These figures come from company statements and press reports, not from CMS, so use them for context rather than quoting them to clients as official counts.

This is the next chapter of a story we have followed all season, from Molina’s Medicare Advantage exit in Connecticut, Mississippi and Nevada to the broader wave of Medicare Advantage benefit cuts for 2027. Insurers point to rising medical costs, higher utilization and payment pressure. CMS finalized a 2.48% average payment increase for 2027, but carriers are still prioritizing margin over growth, as analysts told reporters.

Key Dates Every Broker Needs

The Non-Renewal Special Enrollment Period

The CMS 2027 guidance states that the non-renewal SEP is for an individual whose plan or contract is non-renewed effective January 1, including a termination or a service area reduction. It begins December 8 of the contract year and ends the last day of the following February. The same guidance gives the effective dates for requests received in each period:

According to the CMS text, the SEP allows an eligible person to enroll in a Medicare Advantage and/or Part D plan. Medicare.gov also lists the Special Enrollment Periods that apply when a plan ends. For a client who enrolls in January or February, the gap between December 31 and the new effective date is real, which is why we recommend acting during AEP, from October 15 through December 7, whenever the client is ready.

Why acting during AEP beats waiting

• No coverage gap. An AEP election made by December 7 takes effect January 1, while a January request under the SEP starts February 1.
• Drug coverage continuity. A client who goes without creditable drug coverage can face a Part D late enrollment penalty later. Check the rules on Medicare.gov and document the discussion.
• Fewer surprises. Drug lists, networks and provider directories can be reviewed calmly in October rather than during the holidays.

Two Paths for a Displaced Client

Every displaced client has two broad choices. Your role is to explain both fairly, ask the right questions and document the client’s decision, not to steer toward the product that pays more.

Our Medicare Advantage vs. Medicare Supplement guide walks through this decision in more depth, and the Medigap high-deductible Plan G guide covers the 2027 high-deductible amount of $3,050 for clients who consider that option. Our Medicare Advantage benefit cuts for 2027 article explains why even renewed plans may look different next year.

Medigap Guaranteed Issue: The 63-Day Rule

A client whose Medicare Advantage plan is leaving Medicare or no longer serving the area may qualify for a Medigap guaranteed issue right if the client switches to Original Medicare. Medicare.gov explains that situations where an insurance company cannot deny a Medigap policy are called guaranteed issue rights or Medigap protections. It also notes that state law may provide additional rights, so check with the state Department of Insurance.

Per Medicare.gov guidance, a client can generally apply as early as 60 days before the Medicare Advantage coverage ends, or by the date in the plan termination notice, and no later than 63 days after it ends. Clients who move to another Medicare Advantage plan do not get a Medigap guaranteed issue right from that move.

It is illegal for anyone to sell a Medigap policy to a person in a Medicare Advantage plan unless the person is switching back to Original Medicare, per Medicare.gov. Ask that the Medigap policy start when the Medicare Advantage coverage ends.

Compliance and Compensation Guardrails

Scope of Appointment

CMS marketing changes effective October 1, 2026 removed the 48-hour wait between collecting a Scope of Appointment and the appointment. A Scope of Appointment is still required, in writing, before the personal marketing appointment, and same-day collection is allowed. Review our Scope of Appointment rules breakdown and make sure every non-renewal call documents the scope the client actually agreed to discuss.

Disclaimers and recording

Use the required Third-Party Marketing Organization disclaimer before benefits are discussed, follow call recording requirements, and never describe a plan as endorsed by Medicare or CMS. Do not tell a client that a carrier’s exit means a competitor’s plan is better without objective, plan-specific facts.

Compensation is not a recommendation

Carriers are changing compensation for 2027. Reporting says Aetna will not pay commission on new enrollments in 123 Medicare Advantage plans across 33 states, and brokers report Humana is doing something similar on a large number of plans. Whether a move from a non-renewed plan pays initial or renewal compensation depends on the carrier’s rules and your contract. Confirm in writing before you enroll, but let the client’s doctors, drugs, budget and preferences drive the recommendation. Never mention commission as a reason to choose a plan, and document why the chosen plan fits the client.

A 30-Day Outreach Workflow

1. Week 1: Identify. Export clients on discontinued plans. Match each to the carrier’s 2027 plan status and note the date on the non-renewal letter.
2. Week 1: Reach out. Send a short, consent-aware message offering a review. Do not promise specific plans, savings or benefits.
3. Week 2: Document the Scope of Appointment. Capture the products to be discussed, in writing, before the appointment begins.
4. Week 2: Gather facts. Doctors, hospitals, prescriptions, pharmacy, budget, Medicaid or Extra Help status and whether the client wants Original Medicare.
5. Weeks 3 and 4: Compare and enroll. Walk through at least the available MA options and, when relevant, the Original Medicare path. Enroll by December 7 where the client is ready.
6. December: Follow up. Confirm effective dates, ID cards, drug fills and Medigap applications that fall under the 63-day window.

If your carrier certifications are not complete, check the 2027 carrier certification dates and our AHIP 2027 certification guide so you are ready to enroll when the client is.

Common Broker Mistakes

• Waiting for December 8. The SEP is a safety net, not a plan. Enrolling during AEP avoids a coverage gap.
• Assuming a same-carrier move is automatic. A carrier may map members to a new plan, but the client still has choices. Confirm what the carrier offers and still review alternatives.
• Forgetting drug coverage. A client who returns to Original Medicare also needs a Part D plan decision.
• Missing the Medigap timeline. Count 63 days from the date coverage ends, not from the date of the letter.
• Quoting news numbers as official. Use the client’s own notice and CMS or carrier documents.
• Letting compensation shape the recommendation. It creates compliance risk and weakens client trust.

How Non-Renewal Season Builds a Stronger Book

A client who is helped calmly through a plan exit is far more likely to stay with the agent who helped, year after year, which is the foundation of residual income as a Medicare broker. Brokers who explain the rules clearly in October will earn the referrals that carry into 2028.

How Affordable Care Agents Supports Medicare Brokers

Affordable Care Agents is a national FMO, IMO and insurance brokerage that gives licensed professionals the structure to handle seasons like this one. For brokers managing plan exits this AEP, that includes:

• Carrier contracting across Medicare Advantage, Medicare Supplement, Part D and ancillary lines so you can serve a client’s whole situation
• AHIP 2027 discount certification through the OIM partnership so you are certified before you start selling
• Compliance education on CMS marketing rules, Scope of Appointment and TPMO disclosures
• Back-office and enrollment support during the busiest weeks of the year
• Training and coaching for new and experienced agents building a durable Medicare book

Frequently Asked Questions