Medicare’s annual period to make changes to Medicare Advantage and Part D plans is underway. Other enrollment opportunities are also discussed below.
Annual Election Period (AEP, aka Open Enrollment, Fall Enrollment)
The Medicare Annual Coordinated Election Period (AEP) – the period during which individuals with Medicare can make certain coverage choices for the coming year – began this week on October 15 and runs through December 7th. During this time, people can enroll in, switch, or get out of Medicare Advantage (MA) and Part D prescription drug plans. They can also retain, or leave an MA plan, and enroll in traditional Medicare. Elections made during the period will be effective January 1st.
The Medicare Plan Finder is an online tool that people can use to compare MA and Part D plan options. To find free and unbiased Medicare counseling from your local State Health Insurance Assistance Program (SHIP) – which may be called something different in your state – go to https://www.shiphelp.org/.
Medicare Advantage Open Enrollment Period (MA-OEP)
People who begin 2026 enrolled in an MA plan have an additional opportunity to switch MA plans or disenroll from an MA plan and return to traditional Medicare with a Part D plan during the first 3 months of the calendar year. This enrollment opportunity, called the Medicare Advantage Open Enrollment Period (MA-OEP), is not available to individuals who are in traditional Medicare and enrolled in a stand-alone Part D plan.
Special Enrollment Periods (SEPs)
In addition, there are certain rights to use a Special Enrollment Period (SEP) to change or get out of a plan in certain circumstances. There are a number of SEPs, including when someone receives inaccurate or misleading information from the Medicare Plan Finder, customer service representatives at 1-800-MEDICARE, or an MA or Part D plan (or its agents). For a full list of available SEPs for both Medicare Advantage and Part D, see, e.g., the CY 2026 Part C & D Enrollment and Disenrollment Guidance available here.
As we noted in a recent CMA Alert, there will be a temporary SEP available for beneficiaries who make choices based on incorrect MA provider directory information in the Medicare Plan Finder.
Medigap Access
If enrolled in a Medicare Advantage Plan there are certain instances in which an enrollee may be able to make the switch to traditional Medicare and have the ability to enroll in a Medigap plan with guaranteed issue (GI) rights. For example, if an enrollee’s MA plan terminates, even if there are other plans available in the area through the same plan sponsor, an MA enrollee is eligible for an SEP and may switch to traditional Medicare and enroll in Medigap on a GI basis.
see: CMS NAIC Q and A And Follow-Ups:
10. The consumer is notified that the MA plan they had in 2024 will no longer be available in 2025 and the consumer has been cross-walked to another MA plan offered by the carrier. If the new plan has a tighter network and the consumer does not want that plan, can they switch back to traditional Medicare and enroll in Medigap on a GI basis?
Yes, this is considered a plan nonrenewal. Crosswalked beneficiaries whose plan or contract is non-renewed (i.e., termination or service area reduction) effective January 1st are eligible for an SEP and may switch to another MA plan OR switch to traditional Medicare and enroll in Medigap on a GI basis. The SEP is available from December 8th through the end of February of the following year.)
October 16, 2025 – D. Lipschutz