Medicare AEP 2027: Plan Changes, Higher Cost Limits, Enrollment Caps and Broker Compensation

Farzin Espahani

Strategic Advisor, Insurance Growth, Medicare Distribution, and Compliance

LinkedIn

Millions of Medicare Advantage members face changes to their plans, costs and coverage in 2027. Some plans are disappearing from their counties. Some continuing plans are increasing medical out-of-pocket limits and prescription drug deductibles. In certain markets, enrollment capacity will also limit which plans remain available.

The Centers for Medicare & Medicaid Services (CMS) projects lower average Medicare Advantage premiums for 2027. That can coexist with higher costs for people who need care, fewer general-enrollment options and substantial movement between plans.

The Annual Enrollment Period (AEP) runs from October 15 through December 7, 2026, for coverage beginning January 1, 2027. This review brings together the changes in plan availability, member disruption, medical and prescription costs, enrollment caps, Special Needs Plans and broker compensation. ^[1]

1. Plan availability: General-enrollment options are shrinking

A comparison of CMS’s September 2026 landscape files shows a decline in general-enrollment Medicare Advantage plans that include prescription drug coverage (MA-PD). Growth in certain Special Needs Plans partly offsets that contraction in the overall market.

Source: VHealth calculations from CMS landscape files. An offering is a unique contract, plan and segment combination, counted once across counties. Categories overlap and should not be added together. The PPO row includes plans with and without drug coverage and excludes Special Needs Plans. ^[2]

Analysis credit: Julia Friedman for the general-enrollment MA-PD comparison and Michael Cho for the plan-type trends. VHealth independently recalculated the table using the definitions above. ^[17][19]

Carrier strategies are diverging

Within general-enrollment MA-PD, several large carriers reduced their offerings while Devoted expanded.

Source: VHealth calculations; same general-enrollment MA-PD definition as above. ^[2]

Analysis credit: Julia Friedman. VHealth expanded the carrier comparison and independently recalculated the figures from CMS files. ^[17]

These counts show where organizations are expanding or contracting. They do not establish why a carrier changed its portfolio, or whether competing changes occurred in the same counties. Across the county entries in our comparison for the 50 states and District of Columbia, 62.2% had fewer MA offerings for 2027. That is a measure of counties, without weighting for population or enrollment. ^[2]

2. Member disruption: Approximately 5.27 million face a change in plan availability

Matching September 2026 enrollment to the landscape identifies approximately 5.27 million members, or 17.7% of the 29.86 million matched members, whose current contract-and-plan combination does not appear in their county in the 2027 file. ^[2][3]

These are current members associated with changes in plan availability. They are not a confirmed count of people required to make an active replacement election. Small enrollment cells suppressed by CMS are excluded, and plan crosswalks have not been applied. ^[2][3]

Analysis credit: Ben Tenner, with related member-disruption commentary from Calvin Bagley. VHealth independently reproduced the approximately 5.27 million total, 17.7% share and 25.0% PPO share. The 4.44 million and 832,000 breakdown is VHealth’s calculation. ^[15][18]

The next step is to determine what happens to each member. A crosswalk links an existing plan to its approved destination for the following year. A missing identifier may reflect a consolidation or another approved transition. It does not, by itself, prove that a member must find coverage independently.

The public CMS crosswalk page did not yet list the 2027 file when this review was completed. Until that information and carrier notices are reconciled, the 5.27 million figure is best used to prioritize member review. ^[4]

For a terminating MA plan, eligible members who do not enter replacement MA coverage generally return to Original Medicare. Prescription drug coverage needs separate attention. Describing everyone in an affected plan as becoming uninsured would be inaccurate. ^[5]

For providers, a transition can create work around network participation, eligibility, scheduled care and authorization requirements. Confirming the destination plan before January can reduce avoidable delays at the point of care.

3. Premiums: The national average and the continuing member experience differ

CMS’s projections cover the overall market. A comparison that holds current enrollment and continuing plan-and-county combinations constant asks what changes for those existing members.

CMS national premium projections

These are different premium measures. The Part D component should not be added to the MA average. A $0 plan premium also does not eliminate a beneficiary’s Part B premium obligation. ^[1][2]

Published premiums in continuing plans

Source: VHealth calculations using September 2026 enrollment as a fixed weight in both years. Published plan premiums are shown before individual low-income assistance; they are not necessarily the amount a D-SNP member pays. ^[2][3]

Analysis credit: Ben Tenner’s comparison of continuing-plan premiums. The figures shown are VHealth’s independent calculations and may differ from the original post because of matching and classification choices. ^[15]

The aggregate premium is influenced by the mix of plans and members. A lower national average does not establish that the premium fell in every continuing HMO or PPO plan. Member communications should show the person’s own change in dollars.

4. Medical costs: Higher out-of-pocket limits increase exposure

The maximum permitted in-network medical maximum out-of-pocket (MOOP) limit rises from $9,250 in 2026 to $9,850 in 2027, an increase of $600, or 6.5%. Plans may offer lower limits. ^[6]

Our continuing-plan comparison also shows higher average medical limits and drug deductibles.

Source: VHealth calculations using fixed September 2026 enrollment weights. Values rounded; percentage changes use unrounded amounts. Medical values use the landscape’s in-network MOOP field; for private fee-for-service plans, CMS identifies that field as a combined limit. ^[2][3]

Analysis credit: Ben Tenner and Michael Cho for highlighting increases in medical limits and drug deductibles. Table figures are VHealth’s independent calculations under the methodology above. ^[15][19]

In the full 2027 MA landscape, 1,555 plan segments, or 28.2%, list the $9,850 limit. That percentage describes offerings, not the share of members expected to reach the limit. ^[2]

MOOP is a ceiling on applicable covered medical cost sharing. It is not a forecast of annual spending, and it does not include every expense a beneficiary could incur. Premiums and Part D drug costs need separate consideration. PPO members should also review the plan’s combined in-network and out-of-network limit.

A person expecting hospital care, treatment from specialists or rehabilitation needs a comparison using those services. An unchanged premium can accompany materially higher exposure during a year of significant illness.

5. Prescription drugs: The deductible and annual threshold both rise

CMS’s final 2027 rate announcement confirms the following standard Part D parameters. ^[7]

The last two rows are VHealth calculations, including Special Needs Plans. They describe plan segments, without enrollment weighting. ^[2]

Analysis credit: Michael Cho for the Part D cost and deductible trends. The first two rows use CMS’s published standard parameters; VHealth independently calculated the last two rows. ^[7][19]

In 2027, 2,348 of 5,165 MA offerings with drug coverage, or 45.5%, list the full $700 deductible. Some plans exempt particular drug tiers from their deductible. A listed $700 deductible therefore does not mean every prescription requires the member to satisfy $700 first. ^[2]

The $2,400 threshold applies to covered Part D drugs under the program’s out-of-pocket accounting rules. It is separate from the medical MOOP and excludes premiums. Extra Help changes the costs paid by eligible beneficiaries, so standard parameters should not be quoted as their expected personal expense. ^[7][8]

CMS is ending the voluntary Part D Premium Stabilization Demonstration after 2026. Its projected $36 average stand-alone premium for 2027 still represents a modest national increase, but a member’s own plan can move differently. ^[1][9]

The Medicare Prescription Payment Plan remains relevant for people facing large early-year drug bills. It spreads payments across the calendar year; it does not reduce the total drug cost. Compare the complete medication list, dosages and pharmacies, then discuss assistance and payment options. ^[10]

6. Enrollment caps: Check availability through submission

The 2027 landscape identifies approved capacity limits across 60 contract-and-plan identifiers covering 65 plan segments, offered by 15 parent organizations in 11 states. Listed limits range from 410 to 56,345 members. The 65 segments should not be treated as 65 independent pools of capacity. ^[2]

Source: VHealth calculations from the accepted-capacity fields in the 2027 landscape. ^[2]

Analysis credit: Jared Strock for identifying caps across 11 states and 15 parent organizations, and Michael Cho for highlighting the 65 capped segments. The state counts and distinction between 60 plan identifiers and 65 segments are VHealth’s independent calculations. ^[16][19]

CMS’s enrollment guidance requires a capped plan to accept valid requests in the order received until its approved limit is reached. Requests received after that point are denied for capacity, and the plan stays closed until space becomes available. Capacity restrictions apply to prospective applicants across the plan; they do not authorize medical underwriting of general-enrollment MA applicants. ^[5]

A capacity closure also differs from a carrier stopping commissions or removing a plan from a particular sales channel. Agencies need separate fields for enrollment availability, channel access and compensation. Combining them under a single “unavailable” label can give members incomplete information.

A current enrollment count is not a reliable measure of January capacity remaining. Pending applications, disenrollments and approved member transitions can change the position. Confirm availability when advising the member and when submitting, retain the carrier receipt, and follow through to the enrollment decision.

7. Special Needs Plans: Growth makes eligibility and Medicaid coordination more important

C-SNP offerings increase 34.2%, while D-SNP offerings decline 2.8%. Within D-SNPs, 699 of 1,052 segments, or 66.4%, are designated coordination-only in the landscape. The integration designation describes how Medicare and Medicaid coverage are coordinated; it is not a quality rating. ^[2]

Beginning in 2027, affected D-SNPs with affiliated Medicaid managed care organizations generally may newly enroll only people already enrolled in, or in the process of enrolling in, the affiliated Medicaid plan. The rule has defined scope and exceptions. It does not impose an identical new eligibility rule on every D-SNP. Existing unaligned members can generally remain until 2030 under the federal transition rules. ^[11]

A D-SNP review should establish the person’s Medicaid eligibility category, Medicaid plan and applicable state alignment rules before recommending coverage. A C-SNP review should verify the qualifying condition and the plan’s confirmation requirements.

Cost comparisons require the same care. Although 872 D-SNP segments, or 82.9%, list a $9,850 medical MOOP, that amount is not necessarily the member’s personal liability. Extra Help addresses Part D costs. Medicaid assistance and Qualified Medicare Beneficiary (QMB) protections address different obligations. Medicare providers may not bill QMB members for Medicare Part A or Part B deductibles, coinsurance or copayments. ^[2][8][12]

8. Broker compensation: Higher maximums do not guarantee payment

CMS’s June 1, 2026 memorandum sets these maximum independent agent and broker compensation amounts for 2027. ^[13]

These limits do not guarantee that a carrier pays a commission on every plan. Initial and renewal compensation also follow different enrollment-cycle rules; switching plans does not automatically qualify as an initial-year sale.

CMS is requesting additional voluntary reporting of zero-compensation plans and actual compensation by plan benefit package. The memo says those voluntary fields can be updated during the year and will not be published on the CMS website. As of this review, the public compensation download page still listed 2026 as its latest annual file. A definitive national count of non-commissionable 2027 plans cannot be established from that file. ^[13][14]

For agencies, more member reviews combined with fewer compensated placements can create a service-capacity problem. Confirm initial payments, renewals, transition treatment and channel access in writing. Maintain a clear referral or assistance path when the agency cannot support enrollment in an appropriate plan.

CMS also cautions plans against making enrollment forms difficult to obtain or using decision tools that obstruct access to available plan selections. A compensation decision should not be confused with a formal enrollment closure. ^[13]

9. Givebacks and supplemental benefits: Verify the benefit behind the name

More plans are using giveback language. A search of plan names in the CMS files finds 408 MA segments containing “giveback” in 2026 and 578 in 2027, an increase of 170. This is a naming indicator, not a complete count of plans offering a Part B premium reduction. Plans may offer the benefit without using that word. ^[2]

For each plan, verify the actual Part B reduction, the member’s eligibility to receive it, and the rest of the benefit design. A larger giveback can coexist with changes to medical cost sharing, networks or drug coverage.

Dental allowances, over-the-counter benefits, benefit-card eligibility and service copayments also require plan-level documents. The initial landscape does not support a conclusion that those benefits improved or deteriorated for every member. Review the 2027 Summary of Benefits, Evidence of Coverage, formulary and provider directory before making that claim.

Preparing for October 15 and January 1

Three coordinated steps would address much of the avoidable disruption.

The 2027 files identify where to begin. Plans and agencies should prioritize members whose current coverage disappears from their county, then review cost changes for those remaining in their plans. Providers should prepare for patients arriving with new coverage and unresolved questions. Progress should be measured by confirmed coverage and completed care reviews, with a named owner for every unresolved case.