What the KFF Analysis Actually Found
If your Medicare Advantage plan is being terminated in 2025, you are not alone — and according to a new analysis from KFF (Kaiser Family Foundation), most affected beneficiaries have meaningful options heading into 2026. The report examined plan termination data filed with the Centers for Medicare and Medicaid Services and found that the large majority of impacted enrollees live in counties where three or more Medicare Advantage plans will remain available after their current plan exits the market.
That finding offers genuine reassurance, but the headline figure obscures real disparities. Beneficiaries in rural counties, low-density markets, and certain Southern and Midwestern states face a narrower field of replacement plans — in some cases, only one or two alternatives. For those enrollees, the practical meaning of robust options is considerably thinner than the national average suggests.
Why Plans Are Exiting the Market in 2025
Medicare Advantage plan terminations occur every year, but the scale in 2025 reflects a convergence of financial pressures that insurers did not fully anticipate when setting their 2024 and 2025 bids. CMS revised its risk adjustment methodology in recent years, reducing payments to plans that had historically over-coded patient diagnoses. At the same time, medical cost trends — particularly for post-acute care, outpatient procedures, and specialty drugs — accelerated faster than actuarial projections.
Under CMS rules codified in 42 CFR Part 422, insurers must notify CMS of plan non-renewals by a specified deadline, and CMS must notify affected enrollees no later than 90 days before the plan's termination date. Enrollees who receive that notice are automatically granted a Special Enrollment Period to select replacement coverage.
Your Enrollment Rights When a Plan Is Terminated
The Special Enrollment Period for Plan Terminations
When a Medicare Advantage plan is terminated or non-renewed, affected members receive a Special Enrollment Period that allows them to enroll in a new Medicare Advantage plan or return to Original Medicare Parts A and B. This window typically begins 60 days before the plan's termination date and extends 60 days after — a roughly four-month period to act.
This Special Enrollment Period is separate from the Annual Enrollment Period, which runs October 15 through December 7 each year, and the Medicare Advantage Open Enrollment Period, which runs January 1 through March 31. Enrolling before the termination date is strongly recommended so that new coverage begins without interruption. If you miss your Special Enrollment Period window and no other qualifying life event applies, you will need to wait for one of those standard periods.
Medigap Guaranteed Issue Rights
Beneficiaries who return to Original Medicare after an involuntary plan termination may qualify for guaranteed issue rights for a Medigap, or Medicare Supplement, policy. Under federal law, insurers cannot deny coverage or charge higher premiums based on pre-existing conditions during this window. The guaranteed issue period is typically 63 days from the date you lose Medicare Advantage coverage. Some states extend additional protections beyond the federal baseline.
Missing this 63-day window can have lasting financial consequences. Once it closes, insurers in most states may subject applicants to medical underwriting, which can make Medigap coverage unaffordable or unavailable for people with chronic conditions. Before your Special Enrollment Period expires, contact your State Health Insurance Assistance Program — a free, unbiased counseling service available in every state — to confirm your specific rights and deadlines.
What to Look for in a Replacement Plan
Not all Medicare Advantage plans are equivalent, even when premiums appear similar. When evaluating 2026 options, focus on these concrete factors.
Provider network: Confirm that your primary care physician, specialists, and preferred hospital are listed as in-network under the new plan's current provider directory. Networks change annually, and a provider who was covered under your terminated plan may not be covered under a replacement.
Drug formulary: If you take maintenance medications, verify each drug's tier placement and any prior authorization or step therapy requirements under the new plan's Part D formulary. A lower premium can be offset by significantly higher drug costs if your medications are placed on a higher tier.
Star ratings: CMS publishes annual Star Ratings on a one-to-five scale for every Medicare Advantage plan. Plans rated four stars or higher generally perform better on care coordination, member experience, and chronic disease management metrics. These ratings are available on Medicare.gov.
Supplemental benefits: Dental, vision, hearing, and transportation benefits vary widely across plans. Do not assume a replacement plan offers the same supplemental coverage as your terminated plan. Review the Evidence of Coverage document for each plan you consider.
Out-of-pocket maximum: Federal rules cap the annual out-of-pocket maximum for Medicare Advantage plans, but the specific limit varies by plan. Verify the actual figure for each 2026 plan you are considering, particularly if you have ongoing specialist care or anticipate hospitalizations.
Chronic Disease Patients Face Additional Transition Risks
For the estimated 60 to 70 percent of Medicare Advantage enrollees who have two or more chronic conditions, a plan termination is more than an administrative inconvenience. Chronic Care Management — the CMS-reimbursed care coordination program billed under CPT codes 99490, 99439, and 99491 — is typically coordinated through a patient's primary care practice rather than the insurance plan itself. However, if a plan termination prompts a change in primary care provider due to network differences, Chronic Care Management continuity can be disrupted, creating gaps in medication reconciliation, care planning, and specialist communication.
Patients enrolled in Chronic Care Management programs should notify their care coordinator immediately upon receiving a plan termination notice. The care team can help ensure that care plans, medication lists, and specialist referrals are documented and transferable regardless of which replacement plan the patient ultimately selects.
Patients receiving care at value-based primary care practices — including federally qualified health centers and practices operating under CMS's ACO REACH or Primary Care First models — should confirm that any replacement plan has a network agreement with their care site before enrolling. A plan that does not contract with your current practice may require you to establish care with a new provider, which can delay chronic disease management and interrupt established therapeutic relationships.
How to Compare Plans Before Your Deadline
The Medicare Plan Finder tool at Medicare.gov is the most reliable starting point for comparing 2026 options. Enter your ZIP code, current medications, and preferred providers to generate a side-by-side comparison of available plans, including premiums, estimated annual drug costs, and Star Ratings. The tool is updated annually with current plan data.
For personalized guidance, call 1-800-MEDICARE at 1-800-633-4227 or contact your local State Health Insurance Assistance Program counselor. These services are free, do not involve sales pressure, and can help you evaluate plan-specific details that the Plan Finder tool may not fully capture, such as prior authorization burdens or network adequacy for your specific conditions.
The Broader Market Picture
Despite the 2025 terminations, Medicare Advantage enrollment nationally continues to grow. As of early 2025, more than 33 million Medicare beneficiaries — roughly half of all Medicare enrollees — are in Medicare Advantage plans. CMS projects that plan availability will remain stable in most metropolitan markets for 2026, even accounting for the exits.
The KFF analysis is a useful corrective to worst-case narratives: most people losing their plans will find comparable or better alternatives. The risk is concentrated among specific populations — rural residents, dual-eligible beneficiaries who qualify for both Medicare and Medicaid, and people with complex chronic conditions who depend on tightly coordinated care networks.
If you fall into one of those groups, the standard advice to simply pick another plan understates the real work required. Start early, use free counseling resources, verify provider and drug coverage before enrolling, and do not allow your Special Enrollment Period to expire without making an active, informed choice.
