Medicare Supplements (Medigap)
Quick Reference Guide

Medigap (Medicare Supplement Insurance) is sold by private insurance companies and is specifically designed to work alongside Original Medicare. These policies help pay for out-of-pocket costs that Original Medicare does not cover, such as the Part A inpatient deductible of $1,736 per benefit period, the Part B deductible of $283/year, and daily coinsurance for extended hospital stays. In 2026, there are 10 standardized Medigap plans (A, B, C, D, F, G, K, L, M, N) available in most states, each offering a defined set of benefits regulated by federal and state law. Approximately 13.5 million Americans carry a Medigap policy.

Medigap enrollment peaked at roughly 14 million in 2020 and has seen a slight decline since then, primarily due to the growth of Medicare Advantage (MA). As of 2024, Mark Farrah Associates reported 13.541 million enrollees. In 2026, the number may increase as 2.7–2.9 million Medicare Advantage members are expected to lose their plans due to insurer exits from markets, potentially boosting Medigap enrollments. Among those on traditional Medicare who are 65+, about 46% carry a Medigap policy, per KFF 2022 data.

Medigap and Medicare Advantage are fundamentally different products. Medigap works alongside Original Medicare (Parts A and B) to pay deductibles, coinsurance, and copays — such as the $1,736 Part A deductible and $283 Part B deductible in 2026. Medicare Advantage replaces Original Medicare, offering managed care (HMO/PPO) plans with network restrictions, often $0 premiums, but with its own out-of-pocket maximums as high as $8,300. You cannot have both Medigap and Medicare Advantage at the same time — Medigap only works with Original Medicare. Medigap typically costs $100–$300/month but provides low, predictable out-of-pocket exposure.

Federal law standardizes Medigap plans so that each plan letter offers the same core benefits regardless of which insurance company sells it. In 2026, the 10 standardized plans are A, B, C, D, F, G, K, L, M, and N. Plans F and G also have high-deductible versions with a $2,950 deductible before full benefits kick in. Note that Plans C and F are no longer available to individuals who became newly eligible for Medicare on or after January 1, 2020, due to MACRA. The three non-standardized states are Massachusetts, Minnesota, and Wisconsin, which have their own plan structures.

Since January 1, 2006, new Medigap policies are prohibited by federal law from including prescription drug coverage. Older Medigap policies sold before 2006 that included drug coverage are grandfathered, but these are extremely rare. Beneficiaries with Medigap who need prescription drug coverage must enroll in a standalone Medicare Part D Prescription Drug Plan (PDP). Failing to enroll in Part D when first eligible may result in a late enrollment penalty — 1% of the national base premium per month of late enrollment, added permanently to premiums.

Medigap Plan A covers four core benefits: (1) Part A inpatient hospital coinsurance and coverage for up to 365 additional days after Medicare hospital benefits are exhausted; (2) Part B coinsurance or copayment (typically 20% of Medicare-approved amounts); (3) The first 3 pints of blood used in a medical procedure; (4) Part A hospice care coinsurance/copayment. Plan A does NOT cover the Part A deductible ($1,736 per benefit period in 2026), the Part B deductible ($283/year), SNF coinsurance ($217/day for days 21-100), excess charges, or foreign travel emergencies. Because of its limited coverage, Plan A is rarely the best choice for most beneficiaries.

Plan A and Plan B are nearly identical, with one critical difference: Plan B adds coverage of the Medicare Part A inpatient deductible. In 2026, that deductible is $1,736 per benefit period, and it resets every time a beneficiary goes 60 consecutive days without a hospital or SNF stay. For a client with multiple hospitalizations in a year, Plan B's protection against repeated $1,736 deductibles can be substantial. Both Plan A and Plan B cover Part B coinsurance, Part A coinsurance (including 365 extra hospital days), blood (3 pints), and hospice coinsurance. Neither covers the Part B deductible ($283), SNF coinsurance, excess charges, or foreign travel.

Federal law requires any insurance company that sells Medigap to offer Plan A (and Plan C for pre-2020 eligibles, or Plan D for post-2020 eligibles). During the Medigap Open Enrollment Period — the 6 months starting when a beneficiary has Part B and is 65+ — all 10 plan letters must be accepted without medical underwriting by carriers that sell those plans. Additionally, in federal guaranteed issue situations (such as MA plan exit from service area, loss of employer coverage), Plan A is always one of the guaranteed-issue options available. For post-2020 Medicare-eligible individuals, the guaranteed issue plans are A, B, D, G, HD-G, K, and L.

Plan A is one of the lower-cost Medigap plans due to its limited benefits, though it's not always the cheapest. Premium estimates for a 65-year-old non-smoker in 2026 generally range from $100 to $200/month depending on the state and carrier. For comparison, Plan G (the most comprehensive plan for new enrollees) typically costs $130–$190/month, making the cost difference between Plan A and G often small enough to justify upgrading. Plan A premiums also vary based on the pricing method used by the insurer — attained-age, issue-age, or community-rated — and tobacco use status.

Medicare Part A covers skilled nursing facility care, but only under specific conditions: a qualifying 3-day hospital inpatient stay, admission to an SNF within 30 days, and admission for a skilled care need (not just custodial care). For days 1–20 in the SNF, Medicare pays 100%; for days 21–100, the beneficiary pays $217/day in 2026 — this is the SNF coinsurance. Plan A does NOT cover this coinsurance. Plans C, D, F, G, K (50%), L (75%), M, and N all cover SNF coinsurance. A 30-day SNF stay in 2026 would result in $2,170 in SNF coinsurance expense for a Plan A holder (10 days × $217).

Medigap Plan G is the most comprehensive plan available to new Medicare enrollees in 2026. It covers all major Medicare cost-sharing gaps except the Part B annual deductible. Specific benefits: (1) Part A hospital coinsurance and all hospital costs up to 365 additional days after Medicare benefits are exhausted; (2) 100% of Part B coinsurance/copayment; (3) First 3 pints of blood per year; (4) Part A hospice care coinsurance; (5) Skilled nursing facility coinsurance of $217/day for days 21–100 per benefit period; (6) The Part A deductible of $1,736 per benefit period; (7) 100% of Part B excess charges; (8) 80% of foreign travel emergency costs after $250 deductible, up to a $50,000 lifetime maximum. After paying the $283 Part B deductible once per year, a Plan G holder has no further out-of-pocket costs for Medicare-covered services.

Medicare Part A covers SNF care for up to 100 days per benefit period under specific conditions (3-day qualifying hospital stay, skilled care need). Medicare pays 100% for days 1–20. For days 21–100, the daily coinsurance is $217 in 2026. Without Medigap, a 30-day SNF stay would cost a beneficiary $217 × 10 = $2,170. Plan G covers this coinsurance 100%, leaving the beneficiary with no SNF costs for days 21-100 beyond what they already pay for Medicare. Medicare pays nothing after day 100 — custodial long-term care beyond day 100 requires separate long-term care insurance or self-payment.

When a Medicare provider does not accept Medicare assignment, they can bill up to 15% above Medicare's approved rate under the limiting charge rule. For example, if Medicare approves $500 for a service, a non-participating provider can charge up to $575 ($500 × 1.15), leaving the beneficiary with $75 in excess charges above the standard 20% coinsurance. Plan G covers 100% of these excess charges. This protection is particularly valuable for beneficiaries who use physicians at academic medical centers or specialists who commonly decline Medicare assignment. In 8 states (CT, MA, MN, NY, OH, PA, RI, VT) that ban balance billing, this benefit has no practical value.

Medicare Part A covers inpatient hospital stays as follows: days 1–60 (after $1,736 deductible, paid by Plan G), days 61–90 ($434/day coinsurance, paid by Plan G), days 91–150 (lifetime reserve days at $868/day, paid by Plan G). After Medicare's 150-day hospital benefit (including 60 lifetime reserve days) is exhausted, Medicare pays nothing. Plan G (like all Medigap plans) then provides an additional 365 days of hospital coverage at no cost to the beneficiary. This benefit is most relevant for beneficiaries facing extended hospitalizations due to serious illness — it provides a safety net well beyond what Medicare alone covers.

Plan G eliminates virtually all Medicare cost-sharing with one exception: the $283 annual Part B deductible (2026). This deductible applies to outpatient Medicare services (doctor visits, outpatient surgery, labs, imaging, etc.) and is paid by the beneficiary at the beginning of each calendar year the first time Part B services are used. After the $283 deductible is satisfied, Plan G covers 100% of all remaining Part B coinsurance, Part A deductibles, SNF coinsurance, and excess charges for the rest of the year. For 2026, the complete out-of-pocket cost picture for a Plan G holder is: monthly premium (typically $130–$190/month at age 65) + $283 Part B deductible + $202.90/month Part B premium (standard) + Part D drug plan premium.

Plan F covers every Medicare Part A and Part B cost-sharing gap, making it the only plan that can leave a policyholder with virtually zero out-of-pocket costs for Medicare-covered services. The complete list of Plan F benefits: (1) Part A hospital coinsurance + 365 extra days; (2) 100% Part B coinsurance/copayment; (3) First 3 pints of blood; (4) Part A hospice care coinsurance; (5) Skilled nursing facility coinsurance at $217/day for days 21–100 (2026); (6) Part A deductible of $1,736 per benefit period (2026); (7) Part B deductible of $283 per calendar year (2026); (8) 100% of Part B excess charges; (9) 80% foreign travel emergency after $250 deductible, $50,000 lifetime max. No other Medigap plan covers both the Part B deductible AND excess charges.

Both Plan F and Plan G cover: Part A coinsurance + 365 extra days; Part B coinsurance (100%); blood; hospice; SNF coinsurance; Part A deductible ($1,736); excess charges; and 80% foreign travel emergency. The sole difference is Plan F also covers the annual Part B deductible ($283 in 2026). Per KFF 2023 data, Plan F averages $274/month nationally while Plan G averages $164/month — a $110/month ($1,320/year) difference. Since Plan F's only extra benefit is worth $283/year, the net additional cost of Plan F over Plan G is $1,037/year. This math strongly favors Plan G for nearly all pre-2020 eligible beneficiaries.

Part B excess charges are an additional billing amount that occurs when a provider does not accept Medicare assignment. Under the Medicare 'limiting charge' rule, non-participating providers can bill up to 15% above the Medicare-approved amount. Plan F covers 100% of these excess charges. For example, if a non-participating physician charges $575 for a service Medicare approves at $500, Plan F covers both the standard 20% coinsurance ($100) and the $75 excess charge — leaving the Plan F holder with nothing to pay. This protection is most valuable in markets with high concentrations of non-participating providers, such as certain specialties in major metropolitan areas.

KFF 2023 data reported the national average Plan F premium at $274/month, ranging from $214/month in Vermont to $313/month in New York. By 2026, factoring in average annual rate increases of 5–8%, Plan F premiums are estimated at $200–$350+/month for current enrollees. Plan F premiums are rising faster than Plan G because its enrollment pool is closed and aging — higher average age means higher claims, which drives up premiums. For a 65-year-old who somehow qualifies (pre-2020 eligible who hasn't enrolled yet), Plan F quotes would range from $200–$300/month depending on state and carrier. The premium trajectory for Plan F is unfavorable long-term.

High-Deductible Plan F works identically to HD-G except that once the $2,950 deductible is met, HD-F provides full Plan F benefits — including coverage of the Part B deductible ($283) and excess charges. HD-F requires the beneficiary to pay all Medicare cost-sharing up to $2,950 per year before the plan pays anything. After that threshold, the plan covers everything Plan F covers. Due to MACRA, HD-F is only available to individuals who were eligible for Medicare before January 1, 2020. For post-2020 eligibles, HD-G is the equivalent option. The premium for HD-F is comparable to HD-G in the $30–$70/month range.

Medigap Plan N provides comprehensive coverage with modest cost-sharing retained. Its benefits include: (1) Part A hospital coinsurance + 365 additional days; (2) Part B coinsurance/copayment — 100% except for a copay of up to $20 for office visits and up to $50 for ER visits not resulting in admission; (3) First 3 pints of blood; (4) Part A hospice care coinsurance; (5) SNF coinsurance of $217/day for days 21–100 (2026); (6) Part A deductible of $1,736 per benefit period; (7) 80% foreign travel emergency (after $250 deductible, $50,000 lifetime max). Plan N does NOT cover the Part B deductible ($283) or Part B excess charges. In exchange for these limits, Plan N premiums average $90–$130/month — significantly less than Plan G.

The $20 office visit copay is a federal maximum — Medigap carriers offering Plan N can charge anywhere from $0 to $20 per office visit. This copay applies to Part B outpatient physician office visits covered by Medicare. It does not apply to preventive care visits (which Medicare covers at 100% with no cost-sharing). The copay applies after the $283 annual Part B deductible is met for the year. For emergency room visits that do not result in inpatient admission, Plan N allows a maximum copay of $50. If the ER visit leads to hospital admission (inpatient status), the $50 ER copay is waived entirely. Copay amounts are set at plan design and don't vary visit-by-visit.

One of Plan N's strong features is its full coverage of SNF coinsurance. For Medicare-covered skilled nursing facility stays, Medicare pays 100% for days 1–20. For days 21–100, the daily coinsurance is $217 in 2026, and Plan N covers 100% of this amount — leaving no cost-sharing for the beneficiary during days 21–100 of a qualifying SNF stay. After day 100, Medicare's benefit is exhausted and neither Medicare nor Medigap covers further SNF costs (custodial-only care). This is the same SNF protection as Plan G, making Plan N a strong choice for clients concerned about rehabilitation or post-surgical nursing facility stays.

The Medicare Part A deductible applies to each new benefit period (which resets after 60 consecutive days without inpatient care). In 2026, the Part A deductible is $1,736 per benefit period. Plan N covers this deductible in full, meaning a Plan N policyholder who is hospitalized pays $0 toward the Part A deductible. This is one of Plan N's most important benefits — without Medigap, multiple hospitalizations could result in multiple $1,736 deductibles in a single year. Plan N's Part A deductible coverage is identical to Plan G in this respect.

Plan N's specific exclusions from Medicare cost-sharing: (1) Part B annual deductible of $283 (2026) — the beneficiary pays this each calendar year; (2) Part B excess charges — if a provider does not accept Medicare assignment and bills up to 15% above the approved rate, Plan N does not pay the excess; (3) Standard Plan N copays: up to $20 for Part B office visits; up to $50 for ER visits not resulting in admission (not technically 'not covered' but retained as cost-sharing). Beyond Medicare cost-sharing: Plan N does not cover prescription drugs, dental, vision, hearing, long-term custodial care, or any service not covered by Original Medicare.

According to KFF 2023 data, the average Medigap premium was $217/month nationally, ranging by state from $191/month in Alaska to $267/month in New York. This average reflects all plan types (A through N) weighted by enrollment. Since Plan F and Plan G make up the majority of enrollment at 36% and 39% respectively, these plans heavily influence the average. Factoring in average annual premium increases of 5–8%, the 2026 national average is estimated at approximately $230–$250/month. Individual plan averages vary significantly: Plan K (~$77/month) at the low end, Plan F ($274/month in 2023) at the high end.

KFF 2023 data reports Plan G at $164/month nationally, ranging from $140/month in Washington D.C. to $236/month in New York. Adjusting for 2026 rate increases of 5–8% per year, Plan G premiums for a new 65-year-old non-smoker are estimated at $130–$190/month, with higher-cost states like New York, California, and Florida on the upper end. Plan G is the most widely shopped Medigap plan, with the most carrier competition — which helps keep premiums relatively competitive. Premiums increase with age for attained-age-rated plans, with 70-year-olds typically paying $180–$250/month and 75-year-olds $220–$310/month.

The premium gap between Plan G and Plan N reflects the cost-sharing differences: Plan N retains copays (up to $20 office, $50 ER) and doesn't cover excess charges, while Plan G has no copays and covers excess charges. This reduced coverage exposure allows carriers to price Plan N 20–35% below Plan G. Using median estimates: Plan G at $160/month vs. Plan N at $110/month = $50/month savings. Annually, that's $600 in premium savings. For a typical enrollee with 5–8 doctor visits, Plan N's total annual cost (premiums + copays + deductible) is still $300–$500 less than Plan G. This premium differential makes Plan N the third most popular Medigap plan (10% market share per KFF 2023).

KFF 2023 reported Plan F at $274/month nationally, ranging from $214/month in Vermont to $313/month in New York. By 2026, Plan F premiums have continued to rise faster than Plan G due to the closed and aging enrollment pool. Estimates for a new applicant in 2026 (pre-2020 eligible, 65 years old, non-smoker) range from $200–$300/month depending on state and carrier — though many carriers have exited the Plan F new-applicant market. Existing Plan F policyholders who entered the plan when younger may be paying $250–$350+/month by 2026 after years of annual rate increases. The premium trend for Plan F is unfavorable compared to Plan G.

HD-G premiums vary by carrier, state, pricing method, age, and gender. For a 65-year-old non-smoker in 2026, most states offer HD-G at approximately $30–$70/month. This compares to standard Plan G at $130–$190/month — a difference of $60–$160/month ($720–$1,920 per year). The trade-off for the dramatically lower premium is the $2,950 annual deductible before full Plan G benefits kick in. HD-G is not as widely available as standard Plan G — not all carriers offer HD-G in every state. Carriers offering HD-G include some BCBS affiliates, Mutual of Omaha, and several regional carriers.

Under attained-age (or 'current-age') rating, the Medigap premium is tied to the policyholder's age at the time of billing. Most carriers use age bands — a set premium applies from, say, age 65–65, then a new higher rate from 66–66, etc. (or bands of 5 years). As the beneficiary ages into each new band, the premium steps up. This means a Plan G policy that costs $160/month at 65 will cost more at 66, more at 70, and more still at 75. In addition to age adjustments, general rate increases (from medical cost inflation) also apply. Attained-age policies typically start with the lowest initial premiums of the three rating methods, making them attractive to new 65-year-old enrollees — but they become the most expensive method over time.

Attained-age rate increases come from two sources: (1) Age adjustments: As the beneficiary moves into a new age band, the carrier's age-based rate schedule adds an age component, typically 2–5% per year; (2) General rate increases: Filed annually with state insurance departments to reflect medical cost inflation, claims experience, and carrier profitability — typically 3–6% per year. Combined, total annual increases of 5–10% are common for attained-age Medigap policies. Over 10 years (age 65 to 75), compounded at 7%/year, a $160/month premium grows to approximately $315/month — nearly doubling. Over 20 years (to age 85), the same policy could reach $620/month. These long-term trajectories are the primary argument for issue-age or community-rated alternatives.

The main advantages of attained-age pricing for new enrollees: (1) Lowest initial premium: At age 65, attained-age carriers offer the lowest entry-level premium among the three methods. A plan that starts at $150/month (attained-age) might start at $175/month (issue-age) — saving $25/month initially; (2) Cash flow advantage: Lower early payments allow retirees to preserve savings or invest the difference; (3) Market liquidity: Attained-age is the most common method, offering the widest carrier selection and competitive options; (4) Potential to switch: Healthy enrollees at 65 can switch to a lower-rate attained-age carrier in future years (subject to underwriting in most states), resetting the premium base. For younger, healthier enrollees, attained-age policies often make financial sense in the early retirement years.

Disadvantages of attained-age pricing at older ages: (1) Compounding cost increases: Each year adds both an age component and a general inflation increase, compounding over decades; (2) Lock-in risk: At age 75+, health conditions may prevent switching to a lower-cost carrier (requires underwriting in most states); (3) Premium affordability at advanced ages: Premiums reaching $300–$500+/month in their 80s can strain retiree budgets on fixed incomes; (4) Plan F spiral effect: Attained-age Plan F holders face doubly compounded increases — age adjustments + closed pool adverse selection — making them particularly expensive; (5) Limited birthday rule windows: Not available in all states, limiting switching options for unhealthy older enrollees.

All three Medigap pricing methods (attained-age, issue-age, community-rated) are subject to general rate increases when the carrier files for and receives approval to raise rates due to medical cost trends, claims experience, or other factors. These general increases apply equally across all policyholders in the rate class regardless of pricing method. The critical distinction: attained-age policies add an additional age-based increase on top of general increases each year. Issue-age policies only have general increases — no age component. Community-rated policies also only have general increases with no age component. This means issue-age and community-rated policies have a structural advantage in long-term cost stability compared to attained-age.

The Medigap Open Enrollment Period (OEP) is a federally guaranteed 6-month window that begins the first month you are both age 65 or older AND enrolled in Medicare Part B. During this window, no insurer can deny you coverage, charge you a higher premium due to pre-existing conditions, or make you wait for benefits to start (beyond a limited 6-month look-back exclusion period). It is the single most valuable enrollment window in Medigap because it removes underwriting risk entirely. Missing it forces applicants to go through medical underwriting in most states, which can result in denial or higher premiums.

Under federal law (42 U.S.C. § 1395ss), during your 6-month Medigap OEP, insurance companies are legally required to sell you any Medigap plan they offer in your state at the same rate as a healthy applicant. They cannot ask health questions to determine eligibility, deny coverage based on pre-existing conditions, or charge a higher premium due to medical history. They may apply a waiting period of up to 6 months for coverage of pre-existing conditions that were treated or diagnosed in the 6 months before enrollment, but only if you had a gap in creditable coverage of 63 or more days.

The federal OEP guarantee applies to all standardized Medigap plans (A, B, C, D, F, G, K, L, M, N) that a given insurer offers in your state. However, not every insurer sells every plan in every state. If you want Plan F, for example, you must have been eligible for Medicare before January 1, 2020 (due to MACRA). Within those constraints, any plan you qualify for cannot be denied or rated up during OEP. Plan G and Plan N are the primary plans available to new Medicare enrollees in 2026.

Even during the guaranteed-issue OEP, insurers may apply a pre-existing condition exclusion period of up to 6 months for conditions that were treated or diagnosed in the 6 months before your Medigap effective date. However, this waiting period can be reduced or eliminated by prior creditable coverage. For each month of prior creditable coverage (from employer plans, COBRA, other Medigap, etc.), one month is subtracted from the 6-month exclusion. If you had 6+ consecutive months of prior creditable coverage with no gap exceeding 63 days, the insurer cannot impose any waiting period.

After purchasing a Medigap policy, you have a federally mandated 30-day free-look period. If you decide the plan is not right for you within that window, you can return the policy and receive a full refund of any premiums paid, no questions asked. This period begins on the date you receive the policy. It applies to both OEP and guaranteed-issue enrollments. The free-look period is especially valuable if you're transitioning between carriers or comparing plans — you can finalize a backup plan before canceling the first.

Under federal law, certain life events trigger a guaranteed issue right, which obligates any insurance company selling Medigap plans in your state to accept your application and charge you the standard rate for your age and location. During a guaranteed issue period, the insurer cannot ask health questions, reject your application, impose a waiting period for pre-existing conditions, or charge a higher premium due to health history. Eight specific federal situations trigger this right, ranging from your Medicare Advantage plan leaving your area to losing employer group coverage involuntarily. You must apply within 63 days of losing prior coverage to preserve this protection.

Federal law specifies eight guaranteed issue trigger situations: (1) your Medicare Advantage plan leaves your area or stops providing care; (2) your Medigap insurer goes bankrupt or becomes insolvent; (3) you move out of your Medicare Advantage, Medicare SELECT, or PACE plan's service area; (4) your plan misled you or failed to meet its contractual obligations; (5) you dropped Medigap to try Medicare Advantage and want to return within 12 months (trial right); (6) you joined Medicare Advantage at age 65 for the first time and want to return within 12 months; (7) your employer group coverage ends involuntarily; and (8) you have a Medicare SELECT plan and move out of the service area. Each situation requires action within a specific window.

Due to MACRA (Medicare Access and CHIP Reauthorization Act of 2015), Plans C and F are no longer available to individuals who first became eligible for Medicare on or after January 1, 2020, because those plans cover the Part B deductible (which was $283 in 2026). Even when a GI right is triggered for post-2020 eligible beneficiaries, insurers can only offer Plans A, B, D, G, High-Deductible G ($2,950 deductible in 2026), K (with an $8,000 out-of-pocket limit), and L (with a $4,000 out-of-pocket limit). Plan G has become the new gold-standard comprehensive option for this population, covering everything Plan F did except the Part B deductible.

When a guaranteed issue right is triggered, federal law prohibits insurers from using health information to deny, delay, or price a Medigap policy. The insurer must accept the application and charge the same premium that a healthy person of the same age in the same location would pay. However, the insurer can still impose a pre-existing condition exclusion period of up to 6 months if you had a gap in creditable coverage. If you had continuous creditable coverage (like group health insurance or Medicare Advantage) for 6 or more months immediately before applying, the insurer must waive this waiting period entirely. Pre-existing condition exclusions are separate from premium surcharges, and both are governed by strict federal rules.

Guaranteed issue rights are tied to specific involuntary or qualifying events — not voluntary plan cancellations. If someone simply decides to leave their Medicare Advantage plan during the Annual Election Period (AEP) without a qualifying event, they are NOT entitled to a GI right and must pass medical underwriting to buy Medigap (except in GI-friendly states like CT, NY, VT, and WA). The main exception is the 12-month trial right: if someone left Medigap to try Medicare Advantage for the first time and wants to return within 12 months, that DOES qualify. Outside the trial right, voluntary MA disenrollment puts the person in the standard underwriting market.

Medical underwriting occurs when a Medigap applicant submits a health questionnaire and the insurer evaluates their medical history to determine insurability. Unlike Medicare Advantage, which has guaranteed issue during Annual Election Periods, Medigap insurers can use health information to (1) deny the application entirely, (2) approve with standard rates, (3) approve with a rate-up or surcharge for certain conditions, or (4) approve with a pre-existing condition exclusion of up to 6 months. Underwriting applies any time a person applies for Medigap outside of their 6-month Open Enrollment Period, outside of a federal guaranteed issue situation, and outside of state-specific protections like birthday rules or continuous open enrollment. About 70-80% of Medigap policies are sold without underwriting (during OEP) or under GI rights, but for the remainder, health history is decisive.

In states that permit Medigap medical underwriting (most states), insurers have three broad options when processing an application outside of a protected enrollment period: (1) approve at standard rates if the health history is acceptable, (2) approve with a premium surcharge — commonly called a 'rate-up' — of 10-50% above standard for certain manageable health conditions, or (3) decline the application outright for serious conditions. The specific rate-up percentages and conditions are governed by state insurance filings and vary by insurer. Rate-ups are applied to the standard age-based premium. For example, if the standard Plan G premium for a 68-year-old is $175/month and a 25% rate-up is applied, the premium becomes $218.75/month. Some carriers apply flat dollar surcharges instead of percentages.

Medigap underwriting relies on multiple data sources. First, the applicant completes a health questionnaire listing medical conditions, surgeries, hospitalizations, and current medications — typically covering the past 3-10 years. Second, the insurer may obtain medical records directly from providers with the applicant's signed authorization. Third, insurers often query the Medical Information Bureau (MIB), a shared database of health information from previous insurance applications. Fourth, prescription drug history from pharmacy benefit databases (like IntelliScript) reveals medication use patterns that can indicate undisclosed conditions. Finally, some insurers use predictive analytics combining all data points. Providing false information on the application constitutes material misrepresentation, which can void coverage and result in claim denials or policy rescission.

From an insurer's perspective, more comprehensive plans (Plan G, Plan F) carry higher financial risk because they cover more costs — so some carriers apply stricter underwriting criteria for these plans than for basic plans like Plan A (which only covers the Part A coinsurance and 365 extra hospital days) or Plan K (which covers 50% of most benefits with an $8,000 out-of-pocket limit in 2026). However, this is not a universal rule — many large carriers like UHC/AARP apply the same underwriting criteria across all plan types. In practice, the difference matters most for borderline health conditions where the insurer's risk assessment may differ depending on how much they're potentially on the hook for. Agents should always apply for the plan the client needs, then explore downgrades only if declined.

The Medigap underwriting timeline varies by insurer and the complexity of the applicant's health history. Simple cases with no major health history may be processed in 5-10 business days. Complex cases requiring medical records from multiple providers, specialist consultations, or laboratory results review can take 4-8 weeks. During this period, the applicant typically does not have Medigap coverage — they remain on whatever plan they currently have. This is why applying well before a prior plan ends is critical. Some carriers offer conditional approval within days for applicants with straightforward histories, followed by full underwriting confirmation. Carriers may also request additional information or a phone health interview, which extends the timeline.

The Medigap birthday rule is a state-enacted consumer protection that gives existing Medigap policyholders an annual window — typically centered around their birthday — to switch to another Medigap plan of equal or lesser benefits from any carrier, without answering health questions. The nine states with birthday rules are California, Idaho, Illinois, Kentucky, Louisiana, Maryland, Nevada, Oklahoma, and Oregon. The window length varies by state — California's original rule allows 30 days before and after the birthday; Oregon and others follow similar models. The birthday rule benefits policyholders who want to shop for lower premiums, switch carriers, or downgrade plans while still healthy enough to benefit. It does not allow upgrading to a plan with more benefits without underwriting.

California's Medigap birthday rule (California Insurance Code Section 10192.25) was the first in the nation, enacted in 2009. It provides a 60-day switching window: 30 days before the policyholder's birthday and 30 days after. During this window, the policyholder can switch to any Medigap plan of equal or lesser coverage from any carrier selling Medigap in California — with no health questions, no medical review, and no pre-existing condition exclusions. The new policy's effective date is typically set to the first day of the month following the birthday. Carriers in California are required to offer this guaranteed switch right to all existing Medigap policyholders. California's rule applies to all standardized Medigap plans (A through N) within the equal-or-lesser benefit constraint.

The birthday rule protects equal-or-lesser plan switches, not upgrades. Plan G covers the Part A deductible and Part B excess charges, while Plan N does not cover excess charges and has copays for office and ER visits. Since Plan G provides greater benefits than Plan N overall, switching from N to G using the birthday rule is not permitted. However, a birthday rule holder on Plan N could switch to a different carrier's Plan N without underwriting (same or lesser benefits), potentially saving money on premiums if another carrier charges less. If a client genuinely needs to upgrade from Plan N to Plan G — for example, because they're now seeing specialists who charge excess fees — they would need to apply through standard underwriting. In states with continuous open enrollment (CT, NY, VT, WA), upgrades can be made freely year-round.

The birthday rule has spread significantly since California and Oregon pioneered it. States that have adopted birthday rules include: California (2009), Oregon (2009), Louisiana (2001), Maryland (2010), Oklahoma (2020), Idaho (2021), Illinois (2021), Kentucky (2022), and Nevada (2022). As of 2026, several additional states are in various stages of legislative consideration, including Florida, Georgia, and others responding to consumer advocacy. The trend is driven by consumer protection advocates and insurance agents who see the birthday rule as a fair balance between consumer flexibility and insurer risk management. Each state's version differs in window length, eligible plans, and implementation details. The federal NAIC has discussed model language for birthday rules but has not issued a mandatory standard.

The birthday rule switching process is generally straightforward: (1) Confirm you are within the birthday window (check your state's specific dates — typically 30-60 days before or after your birthday); (2) Select the new carrier and plan that is equal to or has lesser benefits than your current plan; (3) Submit a standard Medigap application to the new carrier, but check the box indicating you are applying under the state's birthday rule — some states provide a specific birthday rule declaration; (4) Provide your current Medigap policy number and carrier name as documentation of your existing coverage; (5) Your Medicare card and Part B enrollment date should be included; (6) The new carrier processes the application without health questions and issues the new policy effective the first of the month following approval. You then cancel the old policy effective the same date to avoid overlap charges.

Medigap and Medicare Advantage represent two fundamentally different approaches to Medicare coverage. With Medigap: the beneficiary keeps Original Medicare (Parts A and B) as their primary coverage, sees any Medicare-participating provider nationwide, and Medigap pays after Medicare pays its portion — covering deductibles, coinsurance, and copays. With Medicare Advantage: a private insurer contracts with CMS to replace Original Medicare, typically restricting the beneficiary to a network of providers, charging copays and coinsurance, and potentially including extra benefits like dental, vision, and drug coverage. In 2026, approximately 34.1 million Americans (54% of all Medicare beneficiaries) are in Medicare Advantage, while about 13.5 million have Medigap. Both approaches have tradeoffs, and the right choice depends entirely on individual health needs, financial situation, provider preferences, and geography.

Federal law explicitly prohibits the sale of a Medigap policy to a person already enrolled in Medicare Advantage, and vice versa. The reason is structural: Medigap supplements Original Medicare's cost-sharing, but when a person is in Medicare Advantage, Original Medicare is essentially suspended — the MA plan provides coverage instead. There is no Medicare cost-sharing for Medigap to cover. Any agent who sells a Medigap policy to an MA enrollee is committing a federal violation and is subject to penalties. If a beneficiary wishes to switch from Medicare Advantage to Medigap, they must first disenroll from the MA plan and return to Original Medicare (Parts A and B), then purchase Medigap. This must be coordinated carefully to ensure no gap in coverage.

One of the most important practical differences between Medigap and Medicare Advantage is prescription drug coverage. Medigap policies do not and cannot include Part D drug coverage — federal law prohibits selling a Medigap plan with drug benefits to new enrollees (since 2006). A Medigap enrollee must purchase a standalone Part D Prescription Drug Plan (PDP) separately if they want drug coverage. The average standalone Part D premium varies, but in 2026 the typical range is approximately $15-$80/month depending on the plan's formulary. In contrast, most Medicare Advantage plans (known as MA-PD plans) bundle Part D drug coverage into the plan automatically, often at no additional premium. This integration is a significant convenience and cost advantage for many MA enrollees, though the formularies and tier structures vary by plan.

Standard Medigap policies cover only the cost-sharing gaps defined by Medicare — deductibles, coinsurance, copays, and in some plans, foreign travel emergencies. They do not cover dental, vision, hearing, fitness memberships, transportation, or over-the-counter benefits. These must be obtained separately if desired. Medicare Advantage plans, however, routinely include extra benefits that go beyond Medicare coverage. In 2026, most MA plans offer some combination of dental (preventive through comprehensive), vision (annual eye exams, allowances for glasses or contacts), hearing (annual hearing exams, hearing aid allowances), fitness programs (like SilverSneakers), and other supplemental benefits. These extra benefits are a significant marketing advantage for MA plans and are often the deciding factor for budget-conscious beneficiaries choosing between MA and Medigap.

Medicare Advantage plans are required by CMS to accept any Medicare-eligible beneficiary who lives in their service area during designated enrollment periods (Annual Election Period: October 15-December 7; Open Enrollment Period: January 1-March 31; Special Enrollment Periods for qualifying events). This is called 'guaranteed issue' for Medicare Advantage — no health questions, no denials, no premium variations based on health status. This contrasts sharply with Medigap, which allows medical underwriting outside of protected windows in most states. For beneficiaries with serious health conditions who miss their Medigap OEP and are in a standard underwriting state, Medicare Advantage becomes the de facto alternative — it's always available without health scrutiny.

Medigap switching is not simply a matter of calling your insurer and changing plans. The rules depend heavily on the type of switching window available to you: (1) During your 6-month Medigap OEP, you can choose any plan without underwriting; (2) During a GI trigger event, you can switch among the GI-eligible plans; (3) In the nine birthday rule states (CA, ID, IL, KY, LA, MD, NV, OK, OR), you get an annual underwriting-free window; (4) In the four continuous open enrollment states (CT, NY, VT, WA), you can switch anytime without underwriting; (5) Outside these windows, in the majority of states, switching requires a new application with full medical underwriting. Unlike Medicare Advantage, there is no standardized annual election period for Medigap switching.

In states without birthday rules or continuous open enrollment, the Medigap switching process involves: (1) Identify the target plan and carrier — compare premiums across carriers for the same plan letter (benefits are standardized, so only price and carrier reputation differ); (2) Complete the new application including the health questionnaire — the new insurer will conduct medical underwriting; (3) Wait for the underwriting decision, which typically takes 2-6 weeks; (4) Upon approval, confirm the effective date of the new policy; (5) Only after the new policy is confirmed active, cancel the old Medigap policy in writing — keeping the old policy in force until the new one starts prevents any gap in coverage; (6) Keep documentation of both the old cancellation and new policy start for your records. The risk in this process is that a health condition discovered during underwriting can result in denial, leaving the applicant to remain on the old plan.

Because Medigap benefits are standardized by plan letter (Plan G from carrier A has identical core benefits to Plan G from carrier B), some beneficiaries assume switching carriers without changing plan letters avoids underwriting. This assumption is incorrect in most states. When you apply with a new carrier — even for the exact same plan letter — the new carrier treats it as a new application and has the right to conduct full medical underwriting. The only exceptions are: (1) During your Medigap OEP (6 months from Part B enrollment at 65+); (2) During a GI trigger event; (3) In birthday rule states (CA, ID, IL, KY, LA, MD, NV, OK, OR) during the annual birthday window — you can switch to the same or lesser plan without underwriting; (4) In continuous OEP states (CT, NY, VT, WA) — switching is always permitted without underwriting. The motivation for same-letter carrier switching is typically lower premiums — but the underwriting risk must be weighed against the premium savings.

Premium management is a central reason clients consider switching Medigap plans. In 2026, rate increases are averaging 5-8% annually across most plans and carriers. Attained-age rated policies (the most common type, at roughly 70-80% of policies) automatically increase as the policyholder ages, compounding the inflation-based increases. Over 10-20 years, these increases can be dramatic — a $150/month Plan G premium at 65 could exceed $300/month by age 80 with typical rate trajectories. Switching to a lower-premium carrier offering the same plan letter can deliver immediate savings, particularly for healthy clients who can pass underwriting. In birthday rule states (CA, ID, IL, KY, LA, MD, NV, OK, OR), annual carrier shopping around the birthday is a standard strategy to manage premiums without health risk. Issue-age and community-rated policies are more premium-stable but often carry higher initial premiums.

When switching Medigap plans outside of a protected window, the new carrier may impose a pre-existing condition exclusion (PCE) of up to 6 months for conditions present in the 6 months before the new policy's effective date. However, federal law requires the new carrier to give credit for prior continuous Medigap coverage — since you were continuously insured, this prior coverage credit should reduce or eliminate the PCE. If you had 6 or more consecutive months of continuous creditable coverage (including the prior Medigap policy) immediately before the new policy's start, the PCE must be waived entirely. The risk of a new PCE is minimal for people who switch without any coverage gap, because the continuous coverage credit fully offsets the 6-month exclusion window.

UnitedHealthcare (UHC) markets its Medigap products exclusively through the AARP brand, leveraging AARP's enormous membership base of over 40 million Americans aged 50+. With 31%+ market share and approximately 4.4 million Medigap policyholders, UHC/AARP dwarfs all competitors — the next largest carriers hold single-digit market shares by comparison. Key factors behind UHC/AARP's dominance include: (1) Brand trust — AARP's name signals consumer advocacy and credibility; (2) Nationwide availability — UHC/AARP plans are available in all 50 states and DC; (3) Community-rated pricing in many states — providing premium stability regardless of age; (4) Extensive agent support and marketing infrastructure; (5) AARP membership benefits bundled with the plan; and (6) Consistent strong financial ratings (AM Best 'A' or better). UHC/AARP is particularly strong with Plan G and Plan N, the two most popular plan types in 2026.

The AARP-UnitedHealthcare relationship is a brand licensing arrangement. AARP, a nonprofit advocacy organization, licenses its name to UnitedHealthcare for use on Medigap (and other Medicare products) in exchange for royalties that fund AARP's advocacy activities. UHC is the actual insurance company that underwrites, administers, and pays claims on 'AARP Medicare Supplement Insurance Plans.' To purchase an AARP Medigap plan, applicants must hold an AARP membership, which costs approximately $16-$18/year. AARP membership includes benefits such as discounts at hotels, restaurants, pharmacies, and financial services. The membership fee is separate from the Medigap premium. AARP receives approximately $800 million-$1 billion annually in royalties from its UHC relationship, which critics note creates a potential conflict of interest in AARP's health policy advocacy.

UnitedHealthcare/AARP offers a comprehensive range of standardized Medigap plans, though specific availability varies by state. In most states, they offer: Plan A (basic hospital coverage), Plan B, Plan C and F (for pre-2020 eligible only — no longer available to post-2020 Medicare-eligible individuals per MACRA), Plan G (their flagship offering, covering everything except the $283 Part B deductible in 2026), Plan N (with $20 office visit and $50 ER copays for premium savings), Plan K (50% cost-sharing, $8,000 OOP limit in 2026), and Plan L (75% cost-sharing, $4,000 OOP limit in 2026). UHC/AARP is not known for offering High-Deductible Plan G in many markets — this is an area where competitors like Mutual of Omaha or Cigna may have broader HD-G availability.

UHC/AARP uses community rating in many states, meaning all policyholders of the same plan type pay the same premium regardless of age. This differs from attained-age rating (most common industry-wide) where premiums increase as the policyholder gets older. At age 65, UHC/AARP Plan G premiums may be 10-20% higher than the lowest-cost attained-age competitors for the same plan. However, by age 75 or 80, community-rated premiums are often lower than attained-age premiums that have compounded with both age and inflation increases. Over a 10-20 year horizon, UHC/AARP's community-rated model can represent strong value for long-term policyholders. For clients who prioritize immediate premium minimization at age 65, a lower-cost attained-age competitor may initially appear more attractive.

UHC/AARP Medigap advantages include: (1) Trusted AARP brand that many seniors associate with consumer advocacy; (2) Available in all 50 states with broad plan options; (3) Community-rated pricing in many states for long-term premium stability; (4) Strong financial ratings from AM Best (typically 'A' or better); (5) Extensive customer service infrastructure; (6) Included AARP membership discounts on travel, retail, and financial services. Disadvantages include: (1) Premiums can be 10-20% higher at age 65 than the lowest-cost attained-age competitors; (2) Mandatory AARP membership fee ($16-$18/year) adds a small cost; (3) High-Deductible Plan G (HD-G) is less widely available from UHC/AARP than from some competitors like Mutual of Omaha or Cigna; (4) Some client complaints about bureaucratic customer service for claims and billing; (5) The AARP royalty relationship creates a conflict of interest concern for some consumers.

Medicare SELECT plans are Medigap policies with an added network requirement. Like all Medigap plans, they offer the same standardized benefits by plan letter — Plan G SELECT covers the same benefits as standard Plan G, for example. The key difference is that to receive the Medigap benefits (i.e., for the policy to pay its share), policyholders must use the SELECT network of hospitals and sometimes physicians for non-emergency care. If they see an out-of-network provider for non-emergency services, the SELECT plan may not pay its portion — leaving the policyholder responsible for the cost-sharing that Medicare didn't cover. Emergency care is always covered regardless of network. In exchange for this network restriction, SELECT plans offer lower premiums than comparable standard Medigap plans. SELECT plans were authorized by Congress in 1990 as a way to encourage network-based delivery of care within the Medigap framework.

The fundamental differences between standard Medigap and Medicare SELECT center on provider flexibility and cost: Provider access — standard Medigap pays benefits for any Medicare-participating provider in the US with no geographic or network restriction; SELECT requires network use for non-emergency care within the coverage area. Premium — SELECT premiums are typically 10-30% lower than comparable standard Medigap premiums, representing the primary financial incentive. Benefits — SELECT benefits are identical to the standard Medigap plan letter for the same letter designation (Plan G SELECT = standard Plan G benefits when network is used). Emergency coverage — both standard and SELECT plans cover emergency care anywhere in the US regardless of network status. Portability — standard Medigap is fully portable; SELECT has limited portability tied to the network's geographic coverage. Geographic stability — SELECT works best for policyholders who live in one area and primarily use local providers.

Federal law allows SELECT versions of all standardized Medigap plan letters that are otherwise available in a given state. In practice, not all carriers offer SELECT versions of every plan letter, and many states have very limited SELECT plan availability. The most commonly offered SELECT plans where they exist are Plan G SELECT (the SELECT version of the most popular Medigap plan) and Plan A SELECT. Since Plans C and F are only available to those who became Medicare-eligible before January 1, 2020 (MACRA), their SELECT versions have the same eligibility restriction. High-Deductible Plan G can also theoretically have a SELECT version, though this is rare in practice. The specific SELECT plans available in a state depend on which carriers have filed SELECT plans with the state insurance department.

This is one of the most important clarifications about Medicare SELECT. Medicare Parts A and B function identically for SELECT and standard Medigap policyholders — Medicare pays its standard benefit amounts for all covered services from any Medicare-participating provider in the US, regardless of whether that provider is in the SELECT network. What changes with out-of-network care is the SELECT plan's supplemental payment — the part that covers Medicare's cost-sharing (deductibles, coinsurance, copays). For example, if a SELECT Plan G policyholder sees an out-of-network specialist for a non-emergency visit, Medicare pays 80% of the approved amount as usual. The remaining 20% (Part B coinsurance) that Plan G would normally cover is NOT paid by the SELECT plan because the provider is out-of-network. The policyholder is responsible for that 20%.

Congress created Medicare SELECT as a demonstration program in 1990, responding to growing concerns about the affordability of Medigap premiums for low- and moderate-income seniors. The program was based on the concept of preferred provider organization (PPO) managed care — by restricting non-emergency care to a select network of hospitals and physicians, insurers could predict and reduce costs, passing savings on as lower premiums. After successful demonstration periods, it was made permanent in 1994. Medicare SELECT plans offer the same standardized benefits as regular Medigap (Plans A through N) but at lower premiums in exchange for network requirements. Emergency care remains covered nationwide regardless of network.

In 2026, Medicare Part A charges a $1,736 deductible each time a beneficiary begins a new benefit period — meaning each separate hospital stay after a 60-day break resets this cost. Without Medigap, a beneficiary hospitalized twice in one year could owe $3,472. Plans B, C, D, F, G, and N pay the entire $1,736. Plan M covers 50% ($868), while Plans K and L cover 50% ($868) and 75% ($1,302) respectively before reaching their out-of-pocket limits. Plan A is the only standardized plan that does not cover the Part A deductible at all.

After the first 60 days of a hospital stay (which are covered after the Part A deductible), Medicare beneficiaries face a $434/day coinsurance charge for days 61 through 90. For a 30-day stay in this range, that totals $13,020 out of pocket without Medigap. All standardized Medigap plans except K and L cover this daily coinsurance in full. Plans K and L cover 50% ($217/day) and 75% ($325.50/day) respectively, with the beneficiary responsible for the remainder until their annual out-of-pocket limit is reached.

When a Medicare beneficiary exhausts the standard 90 inpatient days in a benefit period, they can draw on lifetime reserve days — a pool of 60 days available over their entire lifetime. In 2026, the daily coinsurance for lifetime reserve days is $868. Once these 60 days are used, they are not renewed; the beneficiary is fully responsible for all costs beyond them. All standardized Medigap plans that cover the Part A hospital coinsurance (Plans A, B, C, D, F, G, M, N) also cover the lifetime reserve day coinsurance. Additionally, all Medigap plans provide 365 extra hospital days after Medicare coverage ends.

Plan G is the most comprehensive Medigap plan available to new Medicare enrollees in 2026, and it covers the Part A deductible ($1,736 per benefit period) in full. It also covers Part A coinsurance for days 61–90 at $434/day and lifetime reserve day coinsurance at $868/day. Additionally, Plan G provides 365 extra hospital days after Medicare benefits are exhausted, covers Part A hospice care coinsurance, and includes skilled nursing facility coinsurance for days 21–100. The only cost Plan G does not cover is the Part B deductible ($283/year).

In 2026, Plan K applies cost-sharing to most Medicare expenses, covering 50% of the Part A inpatient deductible ($868 of $1,736), 50% of Part A coinsurance for days 61–90 ($217/day), and 50% of Part B coinsurance. The key protection Plan K offers is an annual out-of-pocket cap of $8,000 — once reached, Plan K covers 100% of costs for the remainder of the calendar year. Plan G, by contrast, covers all those costs in full with no OOP limit needed (it pays everything except the $283 Part B deductible). Plan K's lower premiums make it suitable for healthier seniors willing to accept some cost risk.

Medicare Parts A and B are essentially limited to the United States, Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands. If a beneficiary experiences a medical emergency abroad — in Canada, Europe, Mexico, or elsewhere — Medicare pays nothing toward those costs. This creates a significant financial risk for Medicare beneficiaries who travel internationally. Medigap addresses this gap through a standardized foreign travel emergency benefit included in Plans C, D, F, G, M, and N, which covers 80% of emergency medical costs abroad after a $250 annual deductible, up to a $50,000 lifetime maximum.

All standardized Medigap plans that include foreign travel emergency coverage (Plans C, D, F, G, M, and N) provide the exact same standardized benefit: 80% of billed emergency medical costs outside the United States after a $250 annual deductible, for the first 60 days of any trip, subject to a $50,000 lifetime maximum. The benefit applies when a medical condition requires immediate treatment and the care cannot reasonably be delayed until the beneficiary returns to the U.S. Covered costs typically include emergency room visits, hospitalizations, emergency surgery, and related emergency physician services incurred abroad.

The foreign travel emergency benefit is not universal across all Medigap plans. Plans A and B — the two most basic plans — do not include it. Plans K and L — the cost-sharing plans with OOP limits — also exclude foreign travel emergency coverage. This means that beneficiaries on these four plans have zero Medigap coverage for international medical emergencies and must rely on personal travel insurance or self-pay. Given that Plans G and N are the most popular plans for new enrollees, the majority of Medigap holders in 2026 do have some foreign travel coverage, but those with Plan A or B should be specifically advised about this gap.

One of the defining features of Medigap is standardization — the benefits for each plan letter are identical regardless of the insurance company offering them. The foreign travel emergency benefit is no exception. Every Plan G from every carrier in every state that offers foreign travel coverage provides exactly the same terms: 80% coverage of emergency medical costs abroad after a $250 annual deductible, applicable to the first 60 consecutive days of each international trip, subject to a $50,000 lifetime maximum. Carriers cannot enhance or reduce this benefit — they can only choose to include or exclude it as prescribed by CMS standardization.

Medigap defines a foreign travel emergency as a medical condition that begins suddenly and unexpectedly, requires immediate treatment, and occurs during the first 60 days of a trip outside the United States. To qualify, the care must be medically necessary — meaning a delay in treatment would endanger the patient's health or life. Covered scenarios include heart attacks, strokes, severe accidents, emergency surgeries, and acute infections requiring hospitalization. Importantly, the care must be truly emergent at the time it is sought — a condition that existed before travel but becomes suddenly acute may qualify, whereas a planned procedure scheduled abroad would not.

Medigap policies standardized after January 1, 2006 do not cover outpatient prescription drugs. Beneficiaries who want prescription drug coverage must enroll in a standalone Medicare Part D Prescription Drug Plan (PDP) or a Medicare Advantage plan that includes drug coverage (MA-PD). Before 2006, some older Medigap policies (Plans H, I, J) included limited drug coverage, but these plans are grandfathered and closed to new enrollment. All 10 current standardized Medigap plans (A, B, C, D, F, G, K, L, M, N) cover only Medicare Parts A and B cost-sharing — drug costs require a separate Part D enrollment.

Before Part D launched in 2006, some Medigap plans (H, I, J) offered limited drug benefits to help with outpatient prescription costs. The MMA of 2003 created a comprehensive, standalone Medicare drug benefit (Part D) effective 2006. To eliminate overlap and simplify the benefit landscape, CMS prohibited new Medigap policies from including prescription drug coverage starting January 1, 2006. Beneficiaries with old Plans H, I, or J who kept their policies retain the grandfathered drug coverage, but it's minimal compared to Part D. CMS determined that having one dedicated drug program (Part D) was preferable to fragmenting drug coverage across multiple Medigap policies with different benefit levels.

Although Medigap does not cover Part D-type outpatient prescription drugs (those picked up at a pharmacy), it does cover the cost-sharing for drugs covered under Medicare Parts A and B. Under Part A hospice coverage, there are small copays (up to $5) for prescription drugs used for pain relief and symptom management — all Medigap plans cover these copays. Under Part B, certain drugs administered by a healthcare provider in a clinical setting are covered by Medicare (80%), and Medigap plans A through N (except K and L's partial coverage) pay the 20% coinsurance. Examples of Part B drugs include chemotherapy drugs, certain biologics, immunosuppressants post-transplant, and injectable osteoporosis drugs.

GoodRx and similar prescription discount programs are available to anyone, including Medicare beneficiaries. If a Medigap holder either does not have Part D or finds GoodRx prices lower than their Part D copay for a specific drug, they can use GoodRx. However, there are important considerations: using GoodRx means paying out of pocket without applying toward any Medicare benefit. CMS has rules about when discount card use counts toward Medicare drug cost calculations — generally, discount card spending does not count toward Part D out-of-pocket costs. Beneficiaries without Part D who rely on GoodRx risk paying full price without the catastrophic coverage protections Part D offers.

The Part D late enrollment penalty is 1% of the national base beneficiary premium per month of uncovered gap. For 2026, the base premium is approximately $36.78/month — so every 12 months without coverage adds about $4.41/month permanently. A beneficiary who goes without Part D for 36 months would permanently pay about $13.24/month extra on their Part D premium. Medigap alone does not constitute 'creditable' drug coverage for Part D penalty purposes. Medicare beneficiaries must either have a Part D plan, or have other creditable drug coverage (employer plan, TRICARE, VA) to avoid the penalty.

When a Medicare provider submits a claim, CMS processes Medicare's share and then automatically forwards the claim information to the beneficiary's Medigap insurer via the Medicare Crossover Program. This coordination eliminates the need for the beneficiary to file a separate claim with their Medigap company for covered services. Medicare's Coordination of Benefits Contractor (COBC) manages the crossover process, identifying which beneficiaries have Medigap coverage and routing claims accordingly. For the beneficiary, this creates a seamless experience — they receive an Explanation of Benefits (EOB) from both Medicare and their Medigap insurer, and ideally the provider receives full payment without billing the patient for covered amounts.

One of the key conveniences of Medigap is that it operates through Medicare's claim crossover system. When a beneficiary with Medigap receives a covered Medicare service, the provider bills Medicare, Medicare processes and pays its share, and then automatically sends claim information to the Medigap insurer. The Medigap insurer then pays the provider (or reimburses the beneficiary if the provider has been paid directly) for the applicable cost-sharing. Beneficiaries are not responsible for filing claims for domestic Medicare-covered services. The main exceptions are foreign travel emergencies (where no crossover system exists) and occasional situations where crossover isn't working properly.

CMS's Coordination of Benefits Contractor (COBC) — currently operated by Gainwell Technologies — serves as the hub for Medicare's coordination of benefits activities. When Medicare processes a claim for a beneficiary with Medigap, the COBC identifies the beneficiary's Medigap carrier from the enrollment data and electronically transmits the Explanation of Benefits (EOB) and claim information to that carrier. The Medigap carrier then processes the secondary claim and pays its portion. This system requires that the beneficiary's Medigap coverage be registered in Medicare's COBC database, typically handled automatically when the beneficiary enrolls in Medigap.

If a provider bills a Medigap-covered beneficiary directly for an amount that should have been covered, the beneficiary should: (1) Check their Medicare Summary Notice (MSN) or MyMedicare.gov to confirm Medicare processed the claim and what Medicare paid; (2) Check the Medigap Explanation of Benefits (EOB) to see if Medigap received and processed the secondary claim; (3) If Medigap shows no payment, contact the Medigap insurer's member services with the claim details (date of service, provider, claim number, amount); (4) The insurer can manually process the claim or investigate the crossover failure; (5) If the provider is demanding immediate payment, advise them the claim is in process. Do not pay a claim that Medigap should cover until all appeals and processes are exhausted.

After Medicare processes a claim and forwards it to the Medigap insurer via the COBC crossover system, the Medigap carrier must review and pay the claim. Most major carriers (UnitedHealthcare/AARP, Mutual of Omaha, Aetna, Humana, etc.) process crossover claims within 15–30 days. State insurance regulations may require payment within specific timeframes (often 30 days from receipt). The provider typically receives the full Medicare + Medigap payment within 4–6 weeks of billing, sometimes sooner. Beneficiaries receive their Medigap EOB showing what was paid usually within 1–3 weeks of the Medigap payment.

Federal law requires all standardized Medigap policies to be guaranteed renewable. This means the insurance company must renew the policy year after year as long as: (1) the beneficiary pays the required premium on time; and (2) the beneficiary has not committed fraud or material misrepresentation on the application. The insurer cannot cancel the policy due to age, health status changes, increased claims utilization, or any factor other than non-payment or material misrepresentation. This guaranteed renewable protection is one of the most important consumer protections in Medigap — it ensures a beneficiary cannot be dropped from their policy if they develop a serious illness and file many claims.

A core feature of the guaranteed renewable requirement is that claim history cannot be used as justification for canceling or not renewing a Medigap policy. Even if a beneficiary has used their Medigap heavily — due to cancer, multiple hospitalizations, or other costly conditions — the insurer must continue the policy as long as premiums are paid. This protection is especially critical for beneficiaries with chronic or serious conditions who would be uninsurable in the individual market without it. Insurance companies may raise premiums for the entire rating class (all policyholders of the same age and plan type in a state) based on aggregate claims experience, but they cannot single out high-utilizing individuals for cancellation or premium surcharges.

Material misrepresentation on a Medigap application typically involves: deliberately omitting a known medical condition when health questions are asked on the application; answering 'no' to questions about conditions that were diagnosed or treated before the application; or providing false information about medications, hospitalizations, or doctor visits. For misrepresentation to void a policy, the insurer must prove: (1) the statement was false; (2) the applicant knew it was false; and (3) the false statement was material — meaning the insurer would have declined or rated differently had it known the truth. Insurers typically have a 2-year contestability period during which they can investigate and rescind a policy for material misrepresentation. After 2 years, the policy generally cannot be rescinded even if misrepresentation is discovered.

State insurance guaranty associations provide a safety net for policyholders when a licensed insurer becomes insolvent. For Medigap specifically, if a carrier becomes insolvent: (1) The state guaranty association covers outstanding claims up to applicable limits (vary by state, typically the full policy amount for health insurance); (2) The insolvent insurer's Medigap policyholders receive a federal guaranteed issue right to enroll in a new Medigap plan from another carrier within 63 days without medical underwriting; (3) Policyholders can enroll in plans A, B, D, G, HD-G, K, or L (or A, B, C, F, HD-F, K, L for pre-2020 eligible). This protection ensures continuity of Medigap coverage even if the carrier fails.

Medigap standardization is set by federal regulation under CMS authority. All insurers selling a specific lettered Medigap plan (e.g., Plan G) must provide exactly the same core benefits regardless of the carrier. A carrier cannot: remove a benefit from a standardized plan; add non-standard benefits to a standardized plan (with limited exceptions for 'innovative benefits' in some states); or redesign the coverage structure. If CMS updates the standardization rules (as it did in 2010 when Plans C and F were modified), all policies issued after the update date must comply. The last major standardization update added Plans M and N in 2010. Carriers compete only on price, not on benefit design within a plan letter.

Eligibility for Medicare before age 65 occurs primarily through: Social Security Disability Insurance (SSDI) after a 24-month waiting period, or having ESRD or ALS. These under-65 Medicare beneficiaries have significant healthcare needs but face a federal legal gap — federal Medigap law does not require insurers to sell policies to them. Approximately 33+ states have filled this gap with state laws requiring carriers to offer Medigap to under-65 disabled beneficiaries, though terms vary significantly by state. Some states require only Plan A; others require a broader selection. Premiums for under-65 disabled beneficiaries are typically much higher than for age-65 counterparts — sometimes 3–5 times more expensive — due to the higher expected claims in this population.

For states that require Medigap availability for under-65 disabled beneficiaries, many provide an OEP upon Medicare eligibility — typically a 6-month window starting when the beneficiary has both Medicare Part B and is under-65. During this OEP, carriers must accept the applicant without medical underwriting. However, the plans available and the OEP structure vary by state. In states without a required OEP, under-65 applicants may face medical underwriting even if the insurer offers Medigap voluntarily. The 2026 research notes that only about 7% of under-65 Medicare beneficiaries have Medigap, compared to 46% of those over 65, reflecting both availability limitations and high premiums.

The higher premiums for under-65 disabled Medicare beneficiaries reflect the actuarial reality that this population has significantly higher healthcare utilization than age-65 Medicare beneficiaries. While an age-65 Plan G might cost $150–$190/month, the same Plan G (if available) for a 55-year-old on disability could cost $350–$600/month or more. In some states where only Plan A is required, even that basic plan can cost $200–$400/month for under-65 disabled individuals. The high premium can make Medigap financially impractical for many under-65 beneficiaries, which partially explains why only 7% of this group has Medigap coverage compared to 46% of those over 65.

Under-65 Medicare beneficiaries on disability who purchased Medigap (in states where available) receive a significant benefit at age 65: they enter the standard Medigap Open Enrollment Period, which guarantees access to any plan at standard (unloaded) age-65 premiums without medical underwriting. This 6-month OEP begins when they turn 65 and have Medicare Part B active. Importantly, they can switch from a high-premium under-65 plan to any plan letter available to newly-65 beneficiaries — including Plan G — at the much lower age-65 premium. This transition from high-cost under-65 coverage to standard age-65 coverage is a natural planning milestone for clients with long-term disability.

When Medigap is unavailable or unaffordable for under-65 Medicare beneficiaries, alternatives include: (1) Medicare Advantage — MA plans are available to all Medicare-eligible beneficiaries regardless of age and often have $0 premiums; they provide an out-of-pocket maximum (though typically $3,000–$8,300 for 2026 MOOP) and integrated drug coverage; (2) Full Medicaid eligibility — for those with low income, qualifying for full Medicaid effectively makes Medigap unnecessary; (3) Medicare Savings Programs — can cover the Part B premium and some cost-sharing for low-income disabled beneficiaries; (4) Extra Help — covers Part D drug costs for eligible low-income beneficiaries; (5) Staying on Medicare only with a self-pay strategy for smaller cost-sharing (works only for those with limited healthcare needs and savings).

To sell Medigap (Medicare Supplement Insurance), an agent must hold a valid state insurance license covering health insurance lines in each state where they transact business. The specific license type varies by state — most states issue a 'Life and Health' or 'Life, Accident and Health' license, while others have a standalone 'Health' license. Key requirements: (1) Pass the state insurance licensing exam (includes life, health, or combined exam); (2) Complete any state-mandated pre-licensing education (typically 20–60 hours); (3) Pass a background check; (4) Apply for the license through the state insurance department; (5) Complete ongoing continuing education (CE) for license renewal (typically 24 hours every 2 years). Medigap sellers do not need the separate CMS certification/appointment required for Medicare Advantage and Part D (AHIP certification), but many carriers require their own training certification.

AHIP certification is an annual training program developed by America's Health Insurance Plans and recognized by CMS as the standard Medicare certification for agents selling Medicare Advantage and Part D products. For Medigap-only agents, AHIP is technically not required under federal law or CMS regulations since Medigap is state-regulated and does not require CMS agent certification. However, some Medigap carriers — particularly those that also sell MA and Part D — require their appointed agents to complete AHIP or their own equivalent training before selling any Medicare products, including Medigap. AHIP certification costs approximately $175 and takes 4–6 hours online. Carriers that accept carrier-specific training in lieu of AHIP may reduce this cost.

Insurance licensing and carrier appointments are two separate requirements. A state insurance license grants the legal authority to sell insurance generally. A carrier appointment (also called an agency appointment or producer appointment) is a separate agreement between the insurance company and the agent, authorizing the agent to represent that specific carrier and sell its products. Without an appointment, an agent cannot sell, place, or service a carrier's Medigap policies. The appointment process typically involves: (1) Applying through the carrier's agent portal or through an FMO/IMO; (2) Completing any carrier-required training (product training, AHIP certification, E&O verification); (3) Submitting background check information; (4) Receiving formal appointment notification from the carrier via the state insurance department. Most agents work through a Field Marketing Organization (FMO) or Independent Marketing Organization (IMO) that manages appointments with multiple carriers.

Continuing education requirements vary by state but follow a general framework: (1) 24 hours of CE per renewal period (typically 2 years); (2) Mandatory 3+ hours of ethics; (3) Some states require specific CE in areas like senior care, Medicare, or long-term care for agents selling these products; (4) CE must be from state-approved providers; (5) CE can be completed online (most common), in-person, or through approved self-study; (6) CE certificates must be submitted to the state insurance department for license renewal. For Medigap specifically, agents should stay current on annual CMS updates to standardized benefits, pricing method changes, state regulatory updates, and MACRA/HIPAA compliance — even if specific Medicare CE is not mandated.

E&O insurance (also called Professional Liability insurance) covers agents against claims of professional negligence — situations where an agent's error or omission caused a client financial harm. In the Medigap context, E&O claims can arise from: recommending an inappropriate plan that leaves a client with unexpected costs; failing to disclose Plan N's excess charge gap; not informing a client of the late enrollment penalty risk; selling Medigap to a dual-eligible beneficiary who didn't need it; misrepresenting plan benefits; or errors in application submission. Standard E&O policies provide $1 million per-claim and $3 million aggregate coverage, costing approximately $300–$600/year. Carriers require proof of E&O before granting appointments and may revoke appointments if E&O lapses.