About 40 Medicare Advantage contracts exit the market or reduce their service areas in a typical plan year. The counties affected are not random: they cluster around rural areas where carrier enrollment is thin, markets where medical cost trends have outpaced premium growth, and service areas where a carrier is consolidating its book. The brokers with the most clients in those counties rarely hear about it from CMS first. They hear about it in October when clients start forwarding their non-renewal notices.
Key Takeaways
- CMS requires MA plan sponsors to notify CMS of a non-renewal decision by June 1 for the contract year ending December 31. CMS publishes the affected counties on Medicare Plan Finder. Brokers who check in July have 90 days before the September 30 client notice goes out.
- The plan exit SEP begins October 1 and runs through February 28 or 29 of the following year. It allows affected enrollees to switch to any MA plan or Part D plan available in their county, or return to Original Medicare.
- Clients who take no action by December 31 are defaulted to Original Medicare without Part D coverage. A 63-day gap without creditable drug coverage triggers the permanent Part D late enrollment penalty of 1 percent of the national base beneficiary premium per month of uncovered period.
- Carrier crosswalks offer automatic enrollment into a replacement plan. If the departing carrier identifies a replacement in the same county, clients are mailed a crosswalk notice. The client must actively opt out of the crosswalk if they want a different plan. Passive acceptance means enrollment in the carrier's chosen replacement.
- Brokers cannot technically sell through a client's non-renewal SEP without a compliant Scope of Appointment. The SOA must reflect the plan types the broker intends to discuss. A non-renewal client who calls the broker about their notice triggers the SOA requirement just as any scheduled appointment would.
The CMS notification timeline: why July matters more than October
CMS requires MA plan sponsors to notify CMS of a non-renewal decision by June 1 for the contract year ending the following December 31. CMS then reviews and posts information on affected contracts through Medicare Plan Finder and direct communications to affected counties. By July, a broker who checks the Plan Finder for their primary counties can identify non-renewing contracts before any client notices go out.
The September 30 client notice deadline is CMS's requirement that plan sponsors send non-renewal notices to all enrolled members. That notice kicks off the plan exit Special Enrollment Period effective October 1. A broker who waits for clients to forward that notice is starting the conversation 90 days late.
For brokers using tools like Quotit for plan comparison, the non-renewing plans will typically drop out of available plan results as the plan year progresses. But the proactive check happens upstream: pull the CMS Plan Finder data in July, before the plan disappears from quoting tools, and before AEP prep consumes the calendar.
How the non-renewal SEP works in practice
The plan exit SEP begins October 1 and runs through February 28 or 29 of the following year. The SEP allows affected enrollees to switch to any Medicare Advantage or Part D plan available in their county, or return to Original Medicare. It is not restricted to plans from the same carrier or plans that are similar to the departing plan.
For clients who want a January 1 effective date, enrollment must be completed by December 31. An enrollment submitted between January 1 and February 28 under the non-renewal SEP produces a February 1 effective date. That one-month gap matters for clients on maintenance medications, who will have no Part D coverage in January unless the crosswalk handled their transition automatically.
The standard AEP enrollment window runs October 15 through December 7 and covers the same January 1 effective date. During the overlap period (October 15 through December 7), an affected client can use either the AEP or the non-renewal SEP. Practically, the SEP is more useful because it extends past AEP's December 7 close date, giving laggard clients through February to act.
| Timing | Broker action | Why it matters |
|---|---|---|
| July | Check CMS Plan Finder for non-renewal filings | CMS publishes non-renewing contracts after the June 1 filing deadline. Filter by the counties where your book is concentrated. Build a list of affected clients before the September 30 notice goes out. |
| August | Segment the affected client list | Separate clients who will receive a crosswalk offer from those in counties with no replacement plan. The crosswalk clients need a review of the replacement plan's network and formulary. The no-crosswalk clients are in Original Medicare on January 1 without proactive action. |
| September (before Oct 1) | Collect Scopes of Appointment and schedule calls | Get SOAs signed before the first plan year conversation. Do not wait until clients call you after receiving the September 30 notice. The brokers who proactively reach out in September have first-mover advantage on the non-renewal SEP. |
| October 1 to December 7 | Run enrollment conversations | Use the non-renewal SEP and AEP simultaneously. Present the full county-level plan options, including whether the client should accept the crosswalk or switch to a different carrier. For clients who want to return to Original Medicare, confirm Medigap underwriting availability in their state. |
| December 7 to December 31 | Confirm crosswalk opt-outs and pending enrollments | Any client who did not make a selection by December 7 (AEP close) has until December 31 to enroll under the non-renewal SEP for a January 1 effective date. After December 31, the next available enrollment is January 1 through February 28 with a February 1 effective date, leaving a one-month coverage gap. |
| February (SEP tail) | Catch the passive-acceptance clients | Some clients accepted their crosswalk plan without reviewing it. The non-renewal SEP remains open through February. A client who received and accepted a crosswalk but is unhappy with the replacement plan's formulary or network can still use the remaining SEP window to switch. |
Timing assumes a December 31 plan year end. The non-renewal SEP extends to February 28 or 29 depending on whether the following year is a leap year.
Carrier crosswalks: what a client actually receives
When the departing carrier operates a replacement plan in the same county, CMS may approve a crosswalk. The carrier mails a crosswalk notice that looks like an enrollment confirmation: it describes the replacement plan's name, premium, benefits summary, and formulary highlights. If the client takes no action by December 31, they are automatically enrolled in the replacement plan for January 1.
Crosswalk plans are chosen by the carrier, not by CMS and not by the client. The replacement plan may have a different network, a different formulary tier structure, a higher or lower premium, and different cost-sharing than the departing plan. A client who accepts a crosswalk passively may end up in a plan that does not cover their primary care physician or that places their maintenance medications at a higher formulary tier. Reviewing the crosswalk plan's details before December 31 is the critical broker step, not just confirming that a crosswalk exists.
The passive-acceptance trap and how to catch it
The non-renewal SEP runs through February, which is a useful backstop for clients who did not engage before January 1. A client who accepted a crosswalk plan without reviewing it and is now unhappy in February can still use the remaining non-renewal SEP to switch to any plan available in their county. That February enrollment produces a February 1 effective date, not January 1, so the client was in the crosswalk plan for January.
Example: A client in a rural Texas county whose departing carrier offers a crosswalk into a replacement MA-PD plan with a $42 monthly premium. The client's oncologist is not in the replacement plan's network. The client accepts the crosswalk passively because the letter looks like a renewal confirmation. On January 15, the client calls to make an appointment and discovers the network issue. The broker who catches this before February 28 can still move the client to an in-network plan under the non-renewal SEP. The broker who waits until March has no SEP available, and the client has limited options until AEP.
Illustrative example. Actual plan availability, premiums, and network composition vary by county and plan year.
The Part D gap: what happens to drug coverage
Most Medicare Advantage plans are MA-PD plans, meaning Part D drug coverage is embedded in the plan. When the MA-PD plan exits, the embedded drug coverage exits with it. A client who takes no action by December 31 ends up in Original Medicare without any Part D coverage, unless the crosswalk enrolled them in a plan that includes Part D.
The permanent Part D late enrollment penalty accrues when a client goes 63 or more continuous days without creditable drug coverage after losing their prior coverage. For a client whose MA-PD plan ended December 31 and who has not enrolled in a new Part D plan, the 63-day clock starts January 1. By March 4, the penalty is accruing. For 2026, the national base beneficiary premium is $36.78. Twelve months of uncovered period adds approximately $4.41 per month to every future Part D premium permanently.
The non-renewal SEP extends through February, which keeps the penalty clock from fully accruing for clients who move quickly in January. But a client who waits until late February to enroll will have incurred 30 to 60 days of uncovered period by the time their new plan takes effect. Document the enrollment date carefully.
Medigap access after returning to Original Medicare
A client who uses the non-renewal SEP to return to Original Medicare has a special situation regarding Medigap. In most states, returning from MA to Original Medicare outside of a guaranteed issue right means going through full medical underwriting for a Medigap policy. The non-renewal SEP does not automatically trigger a Medigap guaranteed issue right in most states.
However, some states with birthday-rule provisions or their own guaranteed issue rights may provide an opening. A broker who is moving a client from MA back to Original Medicare should check the client's state-specific Medigap rules before that conversation. The Medicare Advantage exit is not the same as a guaranteed issue event under federal rules in most circumstances.
The Medicare Advantage 5-star SEP is a separate tool for clients who want to switch to a 5-star rated plan year-round, independent of any non-renewal event. If the client's county has a 5-star plan available, they can use the 5-star SEP even after the non-renewal SEP has been used.
Medicare Advantage plan non-renewal: common questions
What brokers need to know about the non-renewal SEP, crosswalks, and the Part D gap.
When does the Medicare Advantage plan exit SEP start and end?
The non-renewal SEP begins October 1 of the plan year that is ending and runs through February 28 or 29 of the following calendar year. For a plan that exits effective December 31, 2026, the SEP window runs from October 1, 2026, through February 28, 2027. A client can use this SEP in addition to the standard AEP window, which runs October 15 through December 7. Most plan changes made during either window take effect January 1 of the following year, but the non-renewal SEP also allows for enrollment between January 1 and the end of February, which can produce a February 1 effective date.
What happens to a client who does nothing after receiving a non-renewal notice?
A client who takes no action by December 31 is defaulted into Original Medicare Parts A and B. They do not retain any Part D drug coverage unless the departing carrier arranged a crosswalk into a new MA-PD or PDP plan. If the client ends up in Original Medicare without Part D coverage and does not enroll in a Part D plan within 63 days, they begin accruing the permanent Part D late enrollment penalty. The penalty is 1 percent of the national base beneficiary premium multiplied by the number of uncovered months, added permanently to their Part D premium whenever they do enroll. For 2026, the national base beneficiary premium is $36.78. A 12-month gap costs roughly $4.41 per month added to every future Part D premium for life.
What is a carrier crosswalk and does the client have to accept it?
A crosswalk is a CMS-approved mechanism that allows a departing plan sponsor to automatically enroll affected members into a replacement plan offered by the same carrier in the same county, if one exists. CMS must approve the replacement plan as an acceptable crosswalk. The client receives written notice of the crosswalk with full details of the replacement plan's premium, benefits, and formulary. The client is not required to accept the crosswalk. They can opt out by December 31 and select any other plan available during the non-renewal SEP. Brokers should review the crosswalk plan's benefits carefully before recommending a client accept it passively, because the replacement plan may have a different network, formulary, or premium than the departing plan.
How does the plan non-renewal SEP interact with the AEP enrollment window?
AEP runs October 15 through December 7, with coverage effective January 1. The non-renewal SEP begins October 1 and extends through February of the following year. During the overlapping period (October 15 through December 7), a client with a non-renewal notice can use either the AEP or the SEP to enroll. The practical difference is that the SEP extends past AEP's December 7 close date, giving the client through February to make a decision. However, a January 1 effective date requires enrollment by December 31. Enrollments completed in January or February under the non-renewal SEP carry a February 1 effective date, leaving the client briefly in Original Medicare for the month of January. That brief gap matters most for clients who take maintenance medications, because they lack Part D coverage for January.
What documentation does a broker need to work a non-renewal client through their SEP?
The broker needs a signed Scope of Appointment documenting the plan types to be discussed before the appointment occurs. The SOA requirement applies regardless of whether the client initiated the call after receiving a non-renewal notice. For telephonic appointments, the broker must document the date, time, plan types discussed, and beneficiary name. The documentation must be retained for 10 years. Beyond the SOA, the broker should retain a copy of the client's non-renewal notice to document the SEP eligibility basis, particularly if the enrollment is processed outside of AEP. CMS or the carrier may request documentation supporting the SEP enrollment if an audit occurs.
