Medigap Insurers Are Quietly Increasing Switching Denials Ahead of 2026

For years, switching from Medicare Advantage to a Medigap (Medicare Supplement) plan has carried a well-known risk: unless you're in a guaranteed issue window, insurers can use medical underwriting to deny you coverage. But as we move into early 2025, beneficiary advocates say the landscape is changing—and not for the better.

Across several states, seniors report seeing higher rejection rates, longer underwriting delays, and stricter health-question interpretations when trying to switch into Medigap coverage. The trend appears strongest among people attempting to leave Medicare Advantage before the 2026 rule and pricing changes, which have been widely discussed in policy circles.

While CMS has not formally announced any new Medigap regulations for 2026, some carriers seem to be anticipating market pressures that could reshape the Medigap-MA balance. And consumers are feeling it.

A Quiet but Noticeable Shift in 2024–2025 Underwriting Behavior

Historically, underwriting denials have been relatively predictable: beneficiaries with recent heart events, chronic conditions, unmanaged diabetes, or hospitalizations often faced barriers. But according to early 2025 feedback from consumer groups, insurance agents, and state SHIP counselors, the denial pattern is widening.

Three changes are being reported:

1. Faster Denials for "Borderline" Conditions

Insurers are rejecting applications for cases that agents say "used to pass," such as:

• Controlled hypertension
• Mild COPD
• Past depression or anxiety diagnoses
• Routine use of certain maintenance medications

In prior years, many of these applicants were approved—sometimes with rated premiums, but still approved.

2. Underwriting Questionnaires Are Getting Stricter

Multiple SHIP programs note insurers are revising questions to be more restrictive. Examples include:

• Adding look-back periods for doctor visits
• Requiring disclosure of "possible upcoming tests"
• Counting certain medications as evidence of conditions even if the applicant has no formal diagnosis

This creates more opportunities for carriers to rule an applicant ineligible.

3. MA-to-Medigap Switchers Seem Disproportionately Affected

Agents report that beneficiaries leaving Medicare Advantage—especially those who had issues with prior authorizations or networks—are the group seeing the highest spike in denials.

SHIP counselors in at least four states have echoed the same trend anecdotally, though no nationwide dataset exists yet.

Why Is This Happening Now?

Industry analysts point to several overlapping factors creating pressure:

1. Medigap Carriers Expect Higher Demand in 2025–2026

Beneficiaries have become more aware of:

• Medicare Advantage prior authorization crackdowns
• Narrow networks
• Out-of-pocket caps tightening
• Supplemental benefit changes expected for 2026

As a result, more seniors are exploring Medigap as the "safer," predictable option. Carriers may be preparing for a shift by tightening who they accept.

2. 2026 Medicare Cost Forecasts Are Already Causing Nervousness

CMS hasn't finalized 2026 pricing, but early projections show:

• Part B premiums rising
• Part D out-of-pocket changes stabilizing after the 2025 cap
• More MA plan variability expected as insurers adjust

Medigap insurers may try to minimize risk ahead of these shifts, especially if they expect an influx of older or higher-cost members coming from MA.

3. Several States Are Debating Medigap Reform Bills

States including Maryland, Connecticut, Oregon, and Minnesota have recently considered (or are currently considering) expanding Medigap switching rights.

When states begin debating new guaranteed-issue rules, carriers sometimes respond by tightening underwriting on the front end to "stabilize" their pool before any reforms pass.

4. Increased Awareness of Prior Authorization Issues Is Driving MA Disenrollment

After years of national media coverage—and multiple high-profile OIG reports—many seniors now better understand the limitations of MA plans.

That means more people trying to leave MA for Medigap, which increases the carrier's incentive to screen aggressively.

Source: HHS-OIG reports on inappropriate prior authorization denials (2023–2024).

What This Means for Beneficiaries in 2025 and 2026

For many seniors, this shift comes as a surprise. They've heard that Medigap "has better coverage" or that it's the "safer option," but they often don't realize that:

• Medigap is not guaranteed issue in most states
• Carriers can deny you for any health reason
• Leaving Medicare Advantage after your initial window carries real risk

And now, that risk appears to be growing.

1. Switching Later Will Likely Get Harder

If the trend continues, the approval window may narrow even more. Beneficiaries in their mid-70s and 80s—who already face challenging underwriting odds—could find switching nearly impossible.

2. Beneficiaries With Chronic Conditions Should Act Early

Those who have:

• Heart disease
• Diabetes
• COPD
• Autoimmune conditions
• Recent hospitalizations

…may have better luck applying now instead of waiting for possible 2026 changes.

3. Medicare Advantage Enrollees Should Understand True Switching Rules

There's a widespread misconception that seniors can simply "change to Medigap" whenever they want.

That is not the case—except in states with expanded rights (like California, Oregon, Missouri, Maine, etc.). Most states still require medical underwriting outside very narrow windows.

What Consumers Can Do Now

Here are the steps beneficiary advocates recommend:

1. Check Your State's Medigap Switching Rights

Some states provide:

• Birthday rules
• Anniversary rules
• Guaranteed-issue switching
• Limits on underwriting

Learn the basics about Medigap in our Medigap guide.

2. Apply During a Period of Relative Health

If possible, apply when you have:

• No pending surgeries
• No diagnostic tests scheduled
• No recent hospitalizations
• No new medication changes

3. Be Honest but Precise on Underwriting Forms

Many denials come from:

• Over-disclosing uncertain diagnoses
• Listing symptoms instead of conditions
• Reporting "possible tests" that were never ordered

Answer what is asked—no more, no less.

4. Compare Multiple Carriers

Underwriting varies wildly between companies. One may deny you while another approves the same application.

5. Don't Drop Your MA Plan Until You're Approved

This is a common and costly mistake. You must keep your existing coverage active until the Medigap carrier issues the approval.

Could Federal Changes Be Coming?

While CMS has not formally proposed any nationwide change to Medigap switching rights, several signs hint at possible reform discussions:

• The National Association of Insurance Commissioners (NAIC) continues reviewing standardized Medigap benefits.
• Several consumer groups have pushed for a federal birthday or anniversary rule.
• Rural health advocates argue that restrictive Medigap underwriting contributes to care inequities.

Any major reform would likely take years—but insurers might be tightening underwriting now in anticipation of heavier scrutiny.

The Bottom Line

The quiet shift happening inside Medigap underwriting departments could become one of the most consequential Medicare trends of 2025–2026. With more seniors expressing dissatisfaction with Medicare Advantage—especially around prior authorization and network limitations—demand for Medigap is rising.

Carriers appear to be responding by tightening the gates.

Beneficiaries who want the security of Medigap should consider their options now, understand their state's rules, and avoid assuming switching will get easier in the future.