The 2026 Medicare Advantage (MA) and Part D (MA-PD) bidding cycle reflects a continuation—and in many cases, an intensification—of the trends shaping the market. Plan sponsors are navigating the full implementation of the redesigned Part D benefit, ongoing MA revenue dynamics, and sustained elevated healthcare cost trends. On September 26, 2025, the Centers for Medicare and Medicaid Services (CMS) released the 2026 landscape file,¹ offering the first comprehensive view of how organizations responded to these challenges through benefit design, premium positioning, and market participation decisions—including plan terminations and service area reductions. At the time of publishing, CMS had not released plan crosswalk details. Our analysis focuses on net plan count metrics, and the forthcoming crosswalk file may clarify or supplement the list of plan terminations. This paper serves as the first of a series that summarizes key observations from the MA-PD market and highlights notable shifts that may influence future strategy.

Market consolidation intensifies – premiums rise among premium-bearing MA-PD plans as terminations accelerate

The growth in special needs plans (SNPs) continues.

Non-SNP MA-PD (including MA Only) offerings declined again for 2026 as plan sponsors prioritized products that target specific special needs populations. The total number of MA-PD plans decreased slightly in 2025—which was the first year-over-year decline in the MA-PD market—and 2026 plan counts further declined to a total of 5,555 plans. Non-SNPs saw the sharpest reductions, declining approximately 9% (5% decline in 2025), while institutional SNP (I-SNP) counts were largely flat. In contrast, dual-eligible SNP (D-SNP) and chronic SNP (C-SNP) offerings continued to expand above and beyond the growth in 2025, growing by 10% (8% in 2025) and 44% (21% in 2025), respectively, signaling a sustained strategic shift toward serving these higher-acuity populations. See Figure 1 for additional details.

Plan count shifts largely driven by national carriers. Figure 2 highlights the shifts in national carrier plan counts² by plan type, indicating that organizations are increasingly focusing on expanding D-SNP and C-SNP offerings. While not included in Figure 1, it is important to emphasize that regional players played a significant role in the plan count contraction as well.

• All national organizations outside of CVS and HealthSpring added D-SNPs, and C-SNP counts were significantly expanded for both CVS and Devoted Health.
• Humana added a significant number of non-SNPs and D-SNPs, far outpacing other national organizations but on par with Devoted Health.
• Devoted Health added a significant number of C-SNPs, increasing from four C-SNPs in 2025 to 122 C-SNPs in 2026. In 2026, Devoted Health’s total footprint will operate in 29 states, nine more than in 2025.

Market availability of $0 plans continues to tighten, and there are fewer plan offerings at lower premiums.

At the time of publishing, CMS had not released plan crosswalk details due to the government shutdown. Our analysis focuses on net plan count metrics, and the forthcoming crosswalk file may clarify or supplement the list of plan terminations. We exclude MA Only plans, which are nearly always offered at a $0 premium, in this section of the analysis.

When focusing on the number of non-SNP MA-PD plans, there are 231 fewer $0 premium plans in the market in 2026 relative to 2025. This is the second consecutive year of decline in the count of these plan offerings, though the decrease this year is much starker, at 9.5% following a 1% decrease in 2025. Beyond just $0 premium plans, reviewing a histogram comparison of the percentage of non-SNP MA-PD premium-bearing plans by premium level, as shown in Figure 3, illustrates that there are fewer plan offerings at all lower premium levels in 2026. This indicates that, between 2025 and 2026, the market reduced the number of $0 plan offerings through a combination of closing the plans altogether or increasing plan premiums.

Once again, carrier exits and plan terminations will lead more beneficiaries to shop for plans

Plan and carrier contraction persisted into the 2026 cycle, reflecting sustained margin pressures and market realignment. Six Medicare Advantage organizations (MAOs) will fully cease operations in 2026, affecting approximately 98,500 individual MA-PD enrollees.³ An additional three MAOs will only maintain their SNPs, impacting 208,600 members, emphasizing a targeted approach to MA market participation.⁴

Many organizations cited increasing market and financial pressures as their rationale for exiting or shifting their footprint in the MA market, signaling that consolidation and market exits may persist in the coming years.⁵⁶

The state of Vermont, which in 2025 had three distinct MA carriers, is now the lone state with only one MA carrier, and some counties will have no MA availability, leaving only access to Medicare fee-for-service (FFS) in 2026. The Vermont example illustrates the financial pressures discussed previously and will be an important state to watch. The key question is how beneficiaries in the remaining covered counties will respond—will there be substantial movement back to FFS, or will the lone carrier capture more enrollment than projected in its bids?

PPO plan types were disproportionately impacted as carriers shifted their managed care approach for 2026. A significant number of plan terminations and/or consolidations for the 2026 plan year occurred in the PPO segment, amplifying disruption for beneficiaries who value broad network access. In the 2025 to 2026 landscape, PPO plan counts continued to decline across several national carriers, as depicted in Figure 4. This shift may signal a continued move toward a preference for HMOs in the MA market as plans seek tighter network control and cost containment heading into 2026. Outside of HealthSpring, on a plan count basis, organizations either invested in adding HMO plan types or were largely neutral (in the case of United and Centene).

Both medical maximum out-of-pocket (MOOP) and Part D deductibles continue to edge upward

We again exclude MA Only plans in this section of the analysis. For non-SNP MA-PD plans, in 2026, the prevalence of plans offering a medical MOOP at or below $4,200 (the 2026 “Lower MOOP limit”)⁷ will decrease by 8%, and plans offering a medical MOOP over $6,750 will increase by nearly 8% (the 2026 “Mandatory MOOP limit”). See Figure 5 for the distribution of plans by year.

In addition, the number of non-SNP MA-PD plans in 2026 with a $0 Part D deductible applicable to all tiers declined almost 24%, while the count of plans with the defined standard Part D deductible increased nearly 14%. Note often in the non-SNP market, Part D deductibles tend to apply to non-generic tiers only. See Figure 6 for the distribution of plans by year.

These one-year shifts may suggest that MAOs may be adjusting their benefit designs to better manage exposure to individuals with higher out-of-pocket (OOP) spend.

Our aim in future white papers in this series is to contextualize enrollment weighted changes by carrier as well as county-specific impacts once the CMS plan crosswalk details are made public.

What should MAOs be doing now?

To address the shifts in the 2026 marketplace, top of mind for all MA-PD stakeholders should be taking steps now to proactively build strong product offering and service area strategies for the 2027 bid cycle.

Critical evaluation of how plan sponsors and national carriers react to these shifts, as well as how beneficiary habits and shopping preferences may change, will be important for success in the MA-PD space for the 2026 annual enrollment period and moving forward into 2027.

Caveats, limitations, and qualifications

The information in this paper is intended to describe premium changes and trends in the Medicare MA-PD market. It may not be appropriate, and should not be used, for other purposes.

We relied on publicly available enrollment and premium data from the CMS to support the data presented in this paper, which include the CY 2026 Landscape file and the 2025 Milliman MACVAT®. At the time of publishing, CMS had not released plan crosswalk details. Our analysis focuses on net plan count metrics, and the forthcoming crosswalk file may clarify or supplement the list of plan terminations. We counted plan segments as distinct plan offerings. We excluded Employer Group Waiver Plans (EGWPs), Prescription Drug Plans (PDPs), Medicare-Medicaid plans (MMPs), Program of All-Inclusive Care for the Elderly (PACE) plans, Medical Savings Account (MSA) plans, and Cost plans. Where applicable, we excluded SNPs and focused our analysis on the non-SNP market. If this information is incomplete or inaccurate, our observations and comments may not be appropriate. We reviewed the data for reasonability but did not audit the data.

Julia Friedman and Ivan Yen are members of the American Academy of Actuaries and meet the qualification standards of the American Academy of Actuaries to render the actuarial opinion contained herein.

¹ Centers for Medicare and Medicaid Services. (September 26, 2025). Medicare Advantage (Part C) and Prescription Drug Plan (Part D) List. Retrieved October 20, 2025, from https://www.cms.gov/files/zip/cy2026-landscape-202509.zip.

² We define national carriers to be UnitedHealthcare, Humana, CVS, Centene, HealthSpring (Cigna/HCSC), Elevance, and Devoted Health.

³ The Carle Foundation / Health Alliance / First Carolina Care (~31,200 members); Ochsner Clinic Foundation (~5,900 members); Sonder Health Plans (~24,900 members); University of Michigan Health (~8,700 members); PHSI, Inc (~1,700 members); Blue Cross and Blue Shield of Vermont (~26,100 members).

⁴ Of the organizations terminating all but their D-SNP business, the following organizations were impacted: UCare terminated offerings (~153,100 members); Samaritan Health Plan terminated offerings (~13,900 members); Sentara Health Plans terminated offerings (~41,600 members).

⁵ Minemyer, P. (July 29, 2025). UnitedHealthcare to exit certain Medicare Advantage markets as costs balloon, impacting 600K enrollees. Fierce Healthcare. Retrieved October 20, 2025, from https://www.fiercehealthcare.com/payers/unitedhealth-cuts-2025-outlook-elevated-medical-costs-continue-sting.

⁶ Pifer, R. (September 5, 2025). Elevance cuts MA footprint, exits standalone Medicare prescription drug plans. Healthcare Dive. Retrieved October 20, 2025, from https://www.healthcaredive.com/news/elevance-medicare-advantage-plan-exits-part-d-2026/759360/.

⁷ Coleman, K. A. (April 16, 2025). Final Contract Year (CY) 2026 Standards for Part C Benefits, Bid Review and Evaluation [Memo]. Centers for Medicare and Medicaid Services. Retrieved October 20, 2025, from https://www.cms.gov/files/zip/3rd-week-april-14-18-2025zip.zip.