Medicare AEP for 2026 Plan Year: Strategic Insights for Insurance Marketers New to Medicare

IMC Board
Nov 17, 2025
19 min read

Updated: Mar 20

The current Medicare Annual Enrollment Period (AEP), which occurs from October 15 to December 7, effective January 1, 2026, represents a pivotal opportunity and a complex compliance landscape for insurance carriers, their distribution networks, and digital marketing teams.

With over 67 million Medicare beneficiaries in play and market dynamics shifting dramatically, understanding the performance metrics, regulatory requirements, and strategic opportunities of this enrollment period is essential for maximizing market share while maintaining strict compliance with the U.S. Centers for Medicare & Medicaid Services (CMS).

Market Performance and Enrollment Trends: Data-Driven Overview

The 2025 Open Enrollment period has revealed significant strategic shifts that will reshape carrier approaches and agent compensation models for years to come. Understanding these trends is critical for positioning your organization for sustainable growth in an increasingly competitive and regulated marketplace.

Current Enrollment Dynamics and Market Concentration

Medicare Advantage enrollment now encompasses 54% of all eligible Medicare beneficiaries: approximately 33 million people. However, the pace of growth has moderated substantially. Between 2024 and 2025, total Medicare Advantage enrollment grew by approximately 1.3 million beneficiaries or 4% compared to 7% growth the previous year.

This slowdown reflects several converging factors that carriers must navigate: increased regulatory scrutiny, margin pressures forcing benefit reductions, and heightened competition for profitable geographic markets. The implications for your sales and marketing strategy are profound; organic growth is becoming harder to achieve, making retention and strategic market selection increasingly important.

Market concentration remains high, with UnitedHealthcare and Humana together accounting for nearly half (47%) of all Medicare Advantage enrollments nationwide. UnitedHealthcare holds the largest market share in 42% of metropolitan statistical areas while Humana holds 22% of the market share in these areas.

For smaller and mid-sized carriers, this concentration creates both challenges and opportunities; while competing head-to-head with these giants is difficult, niche market strategies and superior local execution can yield significant results.

Geographic Market Shifts and Carrier Repositioning

For 2026, UnitedHealthcare is offering plans in 109 fewer counties, Humana in 194 fewer counties, and Aetna has also reduced its geographic footprint. These strategic withdrawals from unprofitable markets create opportunities for regional carriers and those with strong cost management capabilities.

UnitedHealthcare grew its membership from 9.5 million to 9.9 million people. Humana lost the most during open enrollment, falling from 6.2 million to 5.8 million enrollees.

The average Medicare beneficiary now has access to 42 Medicare Advantage plans in their area, similar to 2023 and 2024 levels. However, geographic variation is substantial.

Nearly one-third (32%) of Medicare beneficiaries have access to more than 50 Medicare Advantage plans, but others face limited choices. Understanding local market dynamics and plan density in your target counties is essential for effective resource allocation and marketing spend optimization.

Special Needs Plans: Growth Segment

One of the most significant opportunities in 2025 is the Special Needs Plans (SNPs) segment. Nearly 7.3 million Medicare beneficiaries are enrolled in SNPs, accounting for 21% of all Medicare Advantage enrollees vs. just 14% in 2020.

For carriers with capabilities in care coordination for dual-eligible populations, chronic condition management, or institutional care, this represents a high-growth, high-margin opportunity that deserves increased investment in both product development and agent training.

Regulatory Compliance: CMS Marketing and Communication Requirements

The regulatory environment for Medicare marketing has become significantly more stringent, with CMS implementing sweeping changes designed to protect beneficiaries from misleading information and aggressive sales tactics. For carriers, agents, and digital marketing teams, compliance cannot be optional; violations can result in plan sanctions, loss of market access, and significant financial penalties.

Third-Party Marketing Organization (TPMO) Requirements

As TPMOs, agents and brokers need to follow specific rules including adding required disclaimers to all marketing materials and ensuring that only CMS-approved content is used when marketing Medicare plans. This includes all printed, digital, and spoken content that promotes specific Medicare Advantage, Part D, or other Medicare-related plans.

CMS has prohibited contract terms between Medicare Advantage organizations/Part D sponsors and TPMOs that may directly or indirectly create an incentive to inhibit an agent or broker's ability to objectively assess and recommend the plan that's best suited to a potential enrollee's needs. Examples of impermissible contract terms include provisions offering volume-based bonuses for enrollment into certain plans.

Personal beneficiary data collected by a TPMO for marketing or enrolling individuals into a Medicare Advantage or Part D plan may only be shared with another TPMO when prior express written consent is given by the individual. This data-sharing restriction has significant implications for lead-generation vendors, call centers, and digital marketing campaigns that rely on shared prospect databases.

Marketing Material Submission and Approval Process

Medicare Advantage Organizations, Part D Sponsors, agents, and other TPMOs must submit materials that market any Medicare Advantage, Part D, or Cost plan benefits including widely available benefits (e.g., dental, vision, and hearing, premium reduction, and cost savings) to CMS for approval before use.

Submission requirements include:

Plan-specific materials requiring CMS review—Any material that promotes specific plans, explains coverage details, references plan names or logos, mentions enrollment processes, discusses supplemental benefits, or compares plans. These materials require submission through the Health Plan Management System (HPMS) and typically require 45 days for CMS review.
CMS-accepted materials—Materials intended to attract or appeal to potential enrollees that contain enough detail to entice additional information requests. These may qualify for a faster "CMS-accepted" status, but still require carrier approval.
Materials NOT requiring submission—Generic educational content with no plan-specific information, unaltered CMS-created materials, announcements of the Annual Enrollment Period dates alone (October 15 - December 7) with no additional marketing content.

Digital Marketing Compliance Challenges

With the increasing use of digital platforms, 2025 guidelines place greater emphasis on CMS-approved content for websites and social media. Unsolicited contact through digital means remains prohibited, and email marketing requires prior consent with an opt-out option.

For digital marketing teams, this creates specific challenges:

Website content—If an agent wants to reference any Medicare Advantage plan information or the insurance company logo on their website, the agent must work with the specific insurance company to obtain their prior approval and properly file with CMS if necessary. Generic educational content is permitted, but plan-specific information requires prior approval and submission.
Social media advertising—All social media content promoting specific plans must be CMS-approved. Dynamic ad creative that changes based on user behavior or A/B testing requires separate approval for each variation.
Search engine optimization (SEO) and content marketing—Educational blog posts, videos, and downloadable resources must carefully avoid crossing the line from education to plan-specific marketing without proper approvals.
Retargeting and lookalike audiences—CMS restrictions on beneficiary data sharing mean that retargeting pixels and lookalike audience building may violate data-sharing prohibitions if not structured properly with explicit consent.

Prohibited Marketing Practices

CMS has identified many instances in which beneficiaries received confusing, misleading, and/or inaccurate information, leading to strict new prohibitions:

Misleading advertisements—Ads that don't mention a specific plan or use the Medicare name or logo in a misleading way
Geographic misrepresentation—Marketing benefits in a service area where those benefits are unavailable
Unsupported superlatives—Use of words like "best" and "most" in marketing unless the material provides documentation to support the statement based on data from the current or prior year
Generalized savings claims—Agents can't market generalized savings when the actual savings are specific to the individual
Cold-calling—Unsolicited contact remains strictly prohibited without documented prior consent

Agent Compensation Structure and Commission Optimization

Understanding the 2025 commission structure is essential for carriers designing competitive compensation plans and for agents optimizing their product mix and sales strategies. Recent legal challenges have significantly impacted the compensation landscape, creating both uncertainty and opportunity.

2025 Commission Rates and Fair Market Value

Following legal challenges to CMS's 2025 Final Rule, CMS issued updated figures for Medicare Advantage and Part D broker commissions on July 18, 2024, superseding the original June 28, 2024 memo.

Medicare Advantage commission rates for 2025 are:

California and New Jersey—Initial commissions $780 per member per year; renewal commissions $390 per member per year
Connecticut, Pennsylvania, and Washington, DC—Initial commissions $705 per member per year; renewal commissions $353 per member per year
All other states—Initial commissions $626 per member per year; renewal commissions $313 per member per year
Puerto Rico and U.S. Virgin Islands—Initial commissions $428 per member per year; renewal commissions $214 per member per year

Part D commission rates increased for 2025:

Initial commissions increased from $100 per member per year to $109 per member per year, a 9% increase; renewal commissions increased from $50 per member per year to $55 per member per year, a 10% increase

Administrative Payments and the Legal Landscape

CMS removed the one-time administrative increases of $100 to initial enrollments and $50 to renewals that were previously planned. However, CMS reinstated the regulatory framework (i.e., 42 C.F.R. 422.2274[e]) which allows for "payments other than compensation (administrative payments)."

This means that payments for services other than enrollment (e.g., training, customer service, agent recruitment, operational overhead, or assistance with completion of health risk assessments) are permitted while the lawsuits are resolved.

This creates strategic opportunities for carriers to structure competitive compensation packages that include:

Training and certification reimbursements within fair market value (FMV) guidelines
Technology and customer relationship management (CRM) platform support
Marketing materials and lead-generation support
Back-office administrative assistance
Ongoing education and compliance support

The key is ensuring that these payments are for legitimate services and properly documented to withstand CMS scrutiny.

Commission Strategy Implications

The standardized commission structure creates both constraints and opportunities that require strategic thinking from all market participants. For carriers designing compensation plans, the following strategic considerations are essential:

Competitive positioning—With commission caps standardized at FMV, differentiation must come through administrative support, lead quality, technology platforms, and brand strength rather than above-FMV commission payments.
Product mix optimization—The significantly higher commissions for Medicare Advantage vs. Part D (i.e., $626 vs. $109 for initial enrollments in most states) create natural incentives for agents to focus on Medicare Advantage plans. Carriers should ensure their Part D standalone products remain competitive and consider bundling strategies.
Retention focus—With renewal commissions at 50% of initial commissions, economics strongly favor retention over constant churn. Carriers should invest heavily in member satisfaction, network adequacy, and benefit competitiveness to reduce voluntary disenrollment.
Geographic strategies—The wide variation in commission rates by state (e.g., from $428 in Puerto Rico to $780 in California and New Jersey) should inform geographic expansion and market prioritization decisions.

Independent agents and field marketing organizations (FMOs) face a fundamentally different landscape than in previous years, requiring adaptation and strategic repositioning. For agents and FMOs navigating this new environment, here are strategies that will prove essential:

Volume vs. quality—With CMS prohibiting volume-based bonuses and enrollment incentives that may bias recommendations, successful agents must focus on quality enrollments, proper plan-beneficiary matching, and high retention rates.
Technology investment—With reduced administrative payments, agents must become more efficient through technology adoption; CRM systems, automated appointment scheduling, e-signature platforms, and compliance documentation tools are essential.
Specialization advantages—Agents who develop expertise in complex products like SNPs, dual-eligible coverage, or specific chronic condition populations can command premium support from carriers while delivering superior beneficiary outcomes.

Key Changes Impacting 2026 Coverage and Sales Strategy

Understanding the benefit and cost changes for 2026 is essential for effective sales conversations, agent training, and competitive positioning. These changes will directly impact beneficiary decision-making and plan switching behavior during the current enrollment period.

Prescription Drug Coverage Evolution

The Part D program continues its transformation under the Inflation Reduction Act (IRA), with several changes that agents must communicate effectively:

Out-of-pocket cap increase—The out-of-pocket cap on prescription drug costs is increasing from $2,000 in 2025 to $2,100 in 2026. While this represents a $100 increase, it still provides catastrophic protection that's a major selling point, especially for beneficiaries with expensive chronic medications.
Maximum deductible—The maximum Part D deductible is rising from $590 in 2025 to $615 in 2026. However, many plans offer lower deductibles or $0 deductibles; it's an important differentiator in plan comparison discussions.
Medicare Prescription Payment Plan—This program, which allows beneficiaries to spread their out-of-pocket prescription drug costs into monthly payments rather than paying everything upfront at the pharmacy, will feature automatic renewal in 2026. If a beneficiary participated in 2025, they'll be automatically reenrolled for 2026 unless they opt out or change plans. This is an excellent retention tool for carriers and a key benefit to emphasize with cost-conscious beneficiaries.

Negotiated Drug Prices: Significant Selling Point

For the first time, Medicare has negotiated lower prices for 10 high-cost prescription drugs. The medications include Eliquis, Jardiance, Farxiga, Januvia, Xarelto, Entresto, Enbrel, Imbruvica, Stelara, and Fiasp/NovoLog. These negotiated prices are expected to save Medicare enrollees approximately $1.5 billion in 2026.

For beneficiaries taking any of these medications, this represents substantial savings regardless of which plan they choose. However, formulary placement and prior authorization requirements still vary by plan, creating opportunities for competitive differentiation. Agents should proactively identify prospects taking these medications and demonstrate how specific plans maximize these negotiated savings.

Premium and Cost Projections

Here's a breakdown of the key premium and cost changes that will shape the 2026 marketplace.

Part B premium increases—The standard Medicare Part B premium is projected to increase significantly for 2026, with estimates suggesting approximately 12% growth to around $206.50 per month, up from $185 in 2025. This increase adds nearly $2,500 to annual Medicare costs for most beneficiaries, making the value proposition of $0 premium Medicare Advantage plans even more compelling.
Part D premium decreases—While CMS projects that the average monthly premium across Medicare Advantage plans will drop from $16.40 this year to $14 in 2026, that analysis includes group Medicare Advantage and SNPs. For the general enrollment Medicare Advantage population, average monthly premiums weighted by enrollment are actually increasing by $2.84 or almost 22% compared to 2025. This creates a complex messaging challenge: while stand-alone Part D premiums are decreasing, integrated Medicare Advantage-Part D premiums are increasing for many plans. Carriers and agents need to be prepared to explain this dynamic clearly and honestly while emphasizing total cost of care, not just monthly premiums.
Part A deductible—The Part A deductible, which applies if a beneficiary is admitted to a hospital, is projected to increase to $1,676 in 2026, reinforcing the value of Medicare Advantage plans with reduced or eliminated hospital copays.

Benefit Reductions and Cost-Sharing Increases

Large insurers are saddling consumers with higher costs through less obvious means including by raising deductibles and out-of-pocket maximums. Carriers are trimming certain benefits, with Aetna, Elevance and UnitedHealthcare materially cutting allowances to cover certain over-the-counter (OTC) health and wellness items for non-SNPs while UnitedHealthcare and Humana cut the OTC benefits for special needs plans.

Maximum out-of-pocket costs in Medicare Advantage plans have climbed 40% over just five years, rising from $6,700 in 2020 to $9,350 in 2025 for in-network services. This trend is likely to continue in 2026, creating both compliance and competitive challenges.

Agents need to be thoroughly trained in how to discuss benefit reductions and cost increases honestly while positioning their plans competitively. The days of emphasizing only supplemental benefits while downplaying cost-sharing increases are over; CMS scrutiny of misleading marketing means that transparency is both legally required and strategically necessary.

Digital Marketing Strategies for Open Enrollment Success

For digital marketing teams supporting Medicare Advantage enrollment, the 2025 landscape requires a sophisticated, compliance-first approach that balances performance marketing objectives with strict CMS requirements.

Compliant Lead Generation

Traditional Medicare lead-generation strategies face significant headwinds due to data-sharing restrictions and anti-steering provisions. Successful digital marketing programs need to adapt.

Consent-based lead capture—Every digital lead-capture form must include clear, prominent disclosure of how beneficiary data will be used and shared. The third-party marketing organization (TPMO) needs to obtain written consent through a transparent and prominently placed disclosure from the individual to share the information and be contacted for marketing purposes.
First-party data strategies—Given restrictions on purchasing and reselling beneficiary data, carriers and large FMOs have significant advantages in building proprietary first-party data assets through educational content, Medicare 101 webinars, prescription drug cost estimators, and other value-added tools that generate organic interest.
Channel optimization—With cold-calling prohibited and data-sharing restricted, successful lead generation increasingly relies on organic SEO for beneficiaries actively researching Medicare options, paid search with careful attention to compliance in ad copy, educational content marketing that builds trust and generates inbound inquiries, compliant email nurture campaigns for existing databases with proper consent, and Medicare 101 educational seminars (in-person and virtual) with proper scope of appointment protocols.

Content Marketing and SEO Strategy

Educational content remains one of the most effective and compliant ways to reach Medicare beneficiaries during open enrollment. Key strategies include:

Keyword targeting—Focus on educational, comparison, and "near-decision" search terms (e.g. "Medicare Advantage vs Original Medicare," "Medicare open enrollment checklist," "Medicare drug cost calculator," and "[City/County] Medicare plans"). Avoid overly promotional terms that trigger high CMS scrutiny. Content types with high performance include: Medicare terminology glossaries and educational guides, prescription drug cost estimator tools, plan comparison worksheets and decision guides, "What's changing for 2026" summary content, Medicare Advantage vs. Medigap comparison content, and provider and pharmacy network search tools.
Local SEO—With geographic market concentration and county-specific plan availability, local optimization is critical. You'll need to create location-specific landing pages for each county you serve, optimize Google Business Profile (GBP) listings, and develop local content addressing specific community health care concerns.

Paid Media Strategies

Each paid media channel presents unique opportunities and compliance challenges that require tailored strategies for success.

Search engine marketing—Google Ads remains highly effective for Medicare marketing, but requires strict adherence to CMS guidelines. All ad copy must be generic (i.e., no plan-specific claims without proper approval). Landing pages must clearly disclose carrier/agent affiliation. Opt-in mechanisms need to include proper consent language. Call tracking and conversion pixels must comply with data-sharing rules.
Display and video advertising—Display and video campaigns (e.g., Google Display Network, YouTube, programmatic, streaming TV) can build awareness but face significant compliance challenges. All creatives must be CMS-approved before use. Retargeting is risky given data-sharing restrictions. Frequency capping is essential to avoid perception of "aggressive marketing." Attribution modeling must account for multitouch journeys without violating data-sharing rules.
Social media advertising—Facebook, Instagram, and LinkedIn advertising can be effective for reaching Medicare-eligible audiences, but requires extreme care. All ad creative and landing pages must be CMS-approved. Targeting parameters should avoid health-status based targeting. Lead generation forms must include proper consent disclosures. Community management needs to follow the Health Insurance Portability and Accountability Act (HIPAA) and CMS communication guidelines.

Marketing Analytics and Attribution

The compliance landscape significantly complicates marketing attribution and return on investment (ROI) measurement:

Consented data collection only—All analytics tracking including pixels, cookies, and form submissions must comply with data-sharing restrictions. This means obtaining proper consent before placing prospects in marketing automation systems or sharing data with third parties.
Attribution modeling challenges—Multitouch attribution models that were standard practice in other industries face significant hurdles in Medicare marketing due to data restrictions. Successful programs rely more heavily on last-click attribution with proper consent at conversion, marketing mix modeling, and incrementality testing at the aggregate level, survey-based attribution (e.g., "How did you hear about us?"), and channel-specific tracking numbers and landing pages.
Performance optimization—Focus key performance indicators (KPIs) on quality metrics, not just volume: conversion rate from lead to appointment to enrollment, cost per compliant lead with proper consent, agent satisfaction with lead quality, plan-beneficiary matching accuracy, and 90-day retention rates (early disenrollment indicator).

Strategic Recommendations for Carriers, Agents, and Marketers

Based on current market dynamics, regulatory trends, and enrollment performance, here are strategic recommendations for maximizing success in the 2025 enrollment period and positioning for long-term sustainable growth.

For Insurance Carriers

Insurance carriers face unprecedented pressure to balance growth objectives with profitability requirements while navigating intensified regulatory scrutiny. The following strategic priorities will separate market leaders from struggling competitors in the years ahead.

Prioritize retention over acquisition in established markets—With growth slowing industrywide and acquisition costs rising, investing in member satisfaction, network adequacy, and benefit competitiveness to retain existing members delivers better ROI than aggressive acquisition strategies.
Selective geographic expansion—Rather than broad national footprints, focus on markets where you can achieve top-three market share, establish strong provider networks at competitive rates, and deliver a superior member experience. Major carriers are exiting hundreds of unprofitable counties, but these represent opportunities for regional carriers with lower cost structures and strong local presence.
Invest in SNPs—With SNP enrollment growing 50% faster than general Medicare Advantage enrollment, developing or expanding C-SNP, D-SNP, and I-SNP products creates access to higher-margin, higher-retention populations with less aggressive competition.
Agent support infrastructure—With administrative payments limited and commission structures standardized, differentiate your distribution strategy through superior agent support (e.g., best-in-class training, CRM tools, compliant marketing materials, lead-generation programs, and responsive contracting and servicing). The carriers that make agents most successful will win agent mindshare and market share.
Data and analytics capabilities—Invest heavily in predictive modeling for member retention risk, network adequacy optimization, benefit design testing, and agent performance analytics. In an increasingly competitive, lower-margin environment, data-driven decision-making is essential.
Compliance program maturity—CMS issued a final rule following thousands of complaints about confusing, misleading, and inaccurate information provided to beneficiaries. Enforcement is increasing so you need to build compliance into your culture, not just your compliance department. Regular secret shopping, systematic TPMO monitoring, and zero-tolerance policies for violations will protect your market access.

For Independent Agents and FMOs

Independent agents and FMOs need to fundamentally rethink their business models to succeed in an environment defined by standardized commissions, anti-steering provisions, and heightened compliance expectations. The strategies that drove success in previous years won't be enough; adaptation is essential for survival and growth.

Quality over quantity—With CMS prohibiting volume-based bonuses and antisteering provisions in place, economics favor agents who enroll fewer beneficiaries in better-matched plans vs. high-volume enrollment with poor persistence. Focus on needs-based selling, thorough plan comparison, and ensuring that beneficiaries understand what they're enrolling in.
Technology adoption is nonnegotiable—Paper applications, manual data entry, and phone-tree servicing are competitive disadvantages. Invest in CRM systems, e-signature platforms, compliance documentation tools, and digital marketing presence. The most efficient agents will thrive; inefficient agents will struggle as administrative support payments decline.
Specialization advantages—Become the expert in underserved niches: dual-eligible populations, specific chronic conditions like chronic obstructive pulmonary disease (COPD), diabetes, and congestive heart failure (CHF), veteran populations transitioning to Medicare, or specific ethnic communities. Deep expertise commands carrier support and generates referral business.
Continuous education—The regulatory environment changes constantly. Agents who invest in ongoing education, stay current on compliance requirements, and proactively adapt their practices will maintain carrier appointments and avoid costly violations.
Build your own brand—Dependence on purchased leads is becoming less sustainable given data-sharing restrictions and lead cost inflation. Invest in your own digital presence including website, local SEO, educational content, social media presence, and referral generation systems that produce organic inbound leads.
Documentation obsession—Keep clear records and retain all scope of appointment (SOA) forms, event registrations, and call logs for at least 10 years. CMS audits are increasing, and proper documentation is your only defense (be warned: if it isn't documented, it didn't happen).

For Digital Marketing Teams

Digital marketing teams supporting Medicare enrollment need to reimagine their approach to succeed within strict compliance frameworks while still delivering measurable business results. The traditional performance marketing playbook requires significant adaptation for the Medicare market's unique regulatory environment.

Compliance-first mindset—Every campaign, creative, landing page, and email must be developed with compliance approval as a gating factor, not an afterthought. Build relationships with your compliance team, learn CMS requirements thoroughly, and design campaigns that are both effective and compliant.
Measurement framework evolution—Accept that Medicare marketing attribution will be less precise than other categories due to data restrictions. Develop measurement frameworks that rely on aggregate performance indicators, incrementality testing, and consented data collection rather than comprehensive cross-channel attribution.
Content marketing investment—With paid media becoming more expensive and restricted, organic content marketing delivers increasingly attractive ROI. Invest in comprehensive educational content, SEO, and value-added tools that generate inbound interest from beneficiaries actively researching their Medicare options.
Local market focus—Medicare is fundamentally a local business so plan availability, provider networks, and competitive dynamics vary dramatically by county. Successful digital marketing programs are increasingly local rather than national, with customized creative, landing pages, and messaging for each market.
Creative testing within compliance constraints—Just because CMS approval is required doesn't mean that all approved creatives perform equally. Develop systematic testing frameworks to identify high-performing messaging, offers, and creative approaches within the universe of compliant options.

Looking Ahead: Market Evolution and Strategic Planning

The Medicare Advantage market stands at an inflection point. After two decades of consistent growth driven by a growth-at-all-costs mentality, the industry is shifting toward selective growth, margin improvement, and operational efficiency.

Major Medicare Advantage insurers face significant financial pressure, with UnitedHealthcare seeing operating income fall 5% year over year, Elevance down 10%, and Humana plummeting 51%. CVS's insurance business, Aetna, actually lost $984 million in 2024 compared to $3.9 billion profit in 2023.

These financial pressures are driving strategic repositioning across the industry, and geographic exits, benefit reductions, premium increases, and enrollment growth expectations are being revised downward. For market participants, this creates both challenges and opportunities:

Large national carriers—The strategic priority is margin improvement through benefit optimization, medical cost management, risk adjustment accuracy, and selective market participation. Geographic footprint consolidation will continue, with exits from low-margin markets and doubling down on profitable regions.
Regional and mid-size carriers—Market exits by national carriers create opportunities to gain share in abandoned markets, especially for carriers with strong local provider relationships, lower overhead cost structures, and community brand recognition.
Agents and marketers—Market volatility creates opportunity as hundreds of thousands of beneficiaries will need to find new plans due to carriers exiting markets or closing specific products. Agents who can navigate these transitions and help displaced members to find appropriate alternatives will generate significant enrollment volume.
For the industry overall—Regulatory scrutiny will continue to intensify. CMS is committed to protecting beneficiaries from misleading marketing, aggressive sales tactics, and anticompetitive practices. The enforcement environment will be more aggressive than at any time since Medicare Advantage's modern inception.

Taking Action During the Current Enrollment Period

As we move through the 2025 Annual Enrollment Period toward the December 7 deadline, carriers, agents, and marketers should prioritize the following action items:

For carriers:

Monitor enrollment performance daily by plan, market, and distribution channel
Provide real-time feedback to agents on common beneficiary objections and competitive positioning
Ensure that compliance monitoring of TPMO marketing activities is active and responsive
Prepare retention strategies for members in discontinued plans or exited markets
Analyze early enrollment patterns to inform 2027 benefit design and market strategy

For agents:

Maximize enrollment volume in the final weeks while maintaining quality and compliance
Document every enrollment thoroughly with proper SOA forms and beneficiary acknowledgment
Prioritize retention outreach to existing book of business before year-end
Schedule January follow-up appointments with new enrollees to ensure smooth coverage activation
Begin preparation for the Medicare Advantage Open Enrollment Period: January 1 - March 31, 2026

For digital marketers:

Optimize media spend toward the highest-performing channels and campaigns based on November performance data
Ensure that all tracking and attribution systems are properly capturing consented data
Prepare "last chance to enroll" messaging for early December push
Develop post-enrollment content strategy for existing member engagement
Begin planning for Q1 2026 campaigns targeting the Medicare Advantage Open Enrollment Period

Sources:

Informa: Healthcare Dive: Medicare Advantage growth slows as UnitedHealthcare nabs members, Humana sheds lives
Informa: Healthcare Dive: UnitedHealthcare, Humana, Aetna scale back Medicare Advantage plans for 2026
KFF: Medicare Advantage in 2025: Enrollment Update and Key Trends
Medicare Rights Center: Amid Fall Open Enrollment, New Insights on the Medicare Advantage Landscape in 2025
PSM Brokerage: Medicare Communication & Marketing Guidelines – Agent Compliance Guide
Ritter Insurance Marketing: FAQs & Guidelines on Compliant Medicare Marketing Materials
Ritter Insurance Marketing: 2025 Maximum Broker Commissions for Medicare Advantage & Medicare Part D
Sidley Austin LLP: CMS Finalizes New Medicare Marketing Requirements
U.S. Centers for Medicare & Medicaid Services (CMS): Contract Year 2025 Medicare Advantage and Part D Final Rule
U.S. Centers for Medicare & Medicaid Services (CMS): Medicare Marketing Guidelines
U.S. Centers for Medicare & Medicaid Services (CMS): Part D Final Rule (CMS-4205-F)

Further Thoughts

Medicare AEP for the 2026 plan year, effective January 1, 2026, reflects an industry in transition—from growth-at-all-costs to sustainable margins, from agent-driven distribution to multi-channel marketing, and from light-touch regulation to intensive CMS oversight. Success in this environment requires strategic clarity, operational excellence, and unwavering commitment to compliance.

For carriers, the winners will be those who can balance enrollment growth with margin discipline, build superior agent and member experiences, and navigate the increasingly complex regulatory landscape. For agents, success requires efficiency, specialization, and quality over quantity. For marketers, compliance-first approaches, content marketing investment, and sophisticated local market strategies are essential.

The December 7 deadline represents not just the close of this enrollment period, but a strategic inflection point for the Medicare Advantage industry. Organizations that adapt to these new realities—more selective growth, margin-focused operations, and compliance-driven culture—will thrive. Those that cling to historical approaches will struggle.

The opportunity remains enormous: 67 million Medicare beneficiaries, growing by 10,000 per day, with Medicare Advantage penetration continuing to increase. But capturing this opportunity requires strategic sophistication, operational discipline, and ethical commitment to putting beneficiary interests first, and not just because CMS requires it, but because it's the only sustainable path forward.