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Here is what you’ll find in this week’s newsletter!
Important links 🔗 - the best articles we found this week about the Medicare Market along with links to Jared’s recent LinkedIn posts.
Deep Dive 📚 - MA Risk Scores, FFS, and 2027 Plan Disruption
Sponsor Snapshot 🚀 - brought to you by Medicare Market Insights +
It’s only a 5 minute read, but it will make you 10x smarter.
Here are IMPORTANT LINKS 🔗 for the week:
3.16 Million MA Members Are Losing Their Plan: The Agent's Guide to Plan Exits and GI Medigap - (link)
Baba nabs $40M series A, backed by FirstMark Capital and CVS Health Ventures, for AI-powered Medicare patient navigation - (link)
Inside Humana’s Medicare Advantage star ratings resurgence - (link)
Centene lifts 2026 profit forecast, sees earnings growth continuing in 2027 - (link)
Medicare Policy Priorities For MedPAC’s 2026–2027 Analytic Agenda - (link)
Aetna sues to challenge 2027 MA star ratings - (link)
Medigap Guaranteed Issue Requirements: An Overview of Federal and State Rules - (link)
Jared’s recent LinkedIn posts:
DEEP DIVE 📚
MA Risk Scores, FFS, and 2027 Plan Disruption
Someone asked me a simple question recently: why has Minnesota been hit so hard with plan terminations the last two years?
It's a fair question. In 2025, 2.6% of Minnesota MA members had to find a new plan. In 2026 it was 31%. For 2027 it's 54%, the highest in the country. Their read was that carriers just have a hard time making it work there.
That sent me into the CMS data to see whether the numbers back that up, and if so, why. What we landed on was interesting. Minnesota isn't really an outlier. It's the most extreme case of a broader pattern: states where MA risk scores run low are the states with the most members impacted by plan terminations. Base payment rates don't explain it. Risk scores do.
Here's what the data shows.
Key takeaways
3.16M members must choose a new plan for 2027 (10.5%). Minnesota leads at 54%. (deep dive here)
Base rates aren't the driver. Minnesota's benchmark matches the U.S.
Risk scores are. Correlation: -0.66. Low-score states: 29% must choose vs 7% to 10% elsewhere. The gap opened in 2026.
Low FFS scores don't explain it. Minnesota's FFS population scores at average. Its MA members score 20% below. That's the lowest MA-to-FFS ratio in the country.
1. The 2027 disruption map
A member "must choose" if their plan terminates, or cuts their county and has no crosswalk target there.
3.16M of 30.1M individual MA and Cost members must choose (10.5%).
2.35M from terminations. 0.82M from service area reductions.
13 of 47 states are above 20%.
State | Must choose | Share |
|---|---|---|
Minnesota | 346K | 54.3% |
Idaho | 63K | 35.5% |
Maine | 68K | 34.0% |
Nebraska | 40K | 33.1% |
New Mexico | 61K | 29.8% |
New Hampshire | 25K | 29.3% |
In Minnesota, one parent drives most of it: Aware Integrated accounts for 259K of the 346K.
"Must choose" means a member has to re-enroll, not that their carrier is leaving. Blue Cross is replacing its plans with a new 2027 lineup that it says reaches more than 80% of current members. Nationally, Humana recaptured about 40% of members from its 2025 exits. Minnesota's 2026 spike was UCare leaving MA entirely, affecting more than 150,000 seniors.
2. MA Base rates aren't the problem
If thin MA benchmarks were pushing carriers out, high-disruption states would have low rates. They don't.
Minnesota's 2024 benchmark (0% bonus): $1,105 vs $1,108 nationally. 25th of 47.
Correlation with 2027 must-choose: -0.17. Weak, and the sign flips in other years.
One note: Minnesota's 2027 benchmark is 2% below the U.S. ($1,277 vs $1,298). Small, but it points the same way.
3. MA Risk scores are
MA Risk scores multiply the benchmark. Members scoring 0.95 bring 20% less revenue than members scoring 1.19.
The coding adjustment compounds it. CMS cuts every MA risk score by the same statutory coding adjustment. MedPAC notes this uniform cut reduces net revenue for plans with lower coding intensity, while higher-coding plans keep part of their coding lift. Low-coding markets take the full cut without the offset.
The state MA risk score correlates at -0.66 with 2027 must-choose share (-0.63 without Minnesota).
Lowest quartile: 29% must choose. Other quartiles: 7% to 10%.
Without Minnesota, the lowest quartile is still at 22%.
Lowest-quartile states: CO, HI, ID, ME, MN, MT, ND, NH, NM, OR, SD, UT.
4. It's been building since 2025
The link between low risk scores and disruption has strengthened three years running.
The lowest quartile went from 7% to 22% to 29%. The others stayed at 5% to 12%.
Minnesota went from 2.6% to 30.8% to 54.4% (40th, 7th, 1st).
The leaders change, but the type of state doesn't. Most are low-score or low-ratio states.
Theory: carriers point to rising medical and pharmacy costs. Blue Cross MN cited more than $500M in Medicare losses over three years. Cost trend hit every market. Markets with less revenue per member had less room to absorb it.
5. MA vs. FFS: health or coding?
A low MA risk score can mean a healthier population, or MA scores running below what the local population would predict. FFS scores in the same counties help tell them apart.
MA-to-FFS ratio = MA index / FFS index, where each index is the state average over the national average. Below 1.00 means MA scores run below what the local FFS population would predict.
Coding gap: Minnesota, North Dakota, Maine. FFS near average, MA well below.
Partly health: South Dakota, Montana, New Hampshire. FFS also scores low (0.87 to 0.90).
Big states are the exception: New York (0.89) and California (0.90) rank low but saw 13% and 6% disruption.
National payers are less present in low-ratio states. National carriers (UnitedHealth, Humana, CVS/Aetna, Elevance, Centene, Cigna, Molina) held 48% of individual MA enrollment in the 10 lowest-ratio states in July 2024. In the 10 highest-ratio states, they held 88%. In Minnesota, 20%.
6. Minnesota case study
Same base rate as the nation. Very different risk scores.
Same benchmark, less revenue. Minnesota members bring 15% less risk-adjusted A/B payment ($898 vs $1,059). The rebate is 41% thinner ($115 vs $194). Total revenue per member is 19% lower ($1,013 vs $1,253).
The rebate is where members feel it. Rebates fund $0 premiums and supplemental benefits, the money that competes for members.
A low FFS score doesn't explain it. Minnesota's FFS index has run 0.99 to 1.02 every year from 2020 to 2024. Its MA index is 0.80. FFS scores also reflect local coding habits, not just health (Finkelstein et al.), so this rules out a low FFS score as the cause, not every health difference.
Theories (not tested here):
Cost plan legacy: Cost plans aren't paid on risk scores. Before 2019 they covered 42% of Minnesota's Medicare members, and the 2019 sunset moved about 320,000 seniors. Members newer to MA tend to carry less coding, and about 85K are still in Cost plans.
Value-based care: large integrated systems with long total-cost-of-care histories may document less than MA-specific risk deals.
PPO structure: open networks may mean fewer wellness visits and in-home assessments.
Local nonprofit market: led by regional nonprofits, not national carriers with large risk adjustment operations.
7. Caveats
Correlation, not cause. Carries exit plans and markets for many reasons, and they cite cost trend first. In Minnesota, one parent's decision drives most of the count.
Must-choose isn't carrier loss. Many members can re-enroll with the same carrier in a new plan.
Other factors. Controlling for rurality, carrier concentration and MA penetration barely moves the result (ratio coefficient -0.54 vs -0.58 alone). Star Ratings aren't tested. They set rebate percentages, and Humana's 2027 exits targeted plans at 3.5 stars or lower.
Selection and coding in FFS. The FFS index describes people who didn't choose MA, and FFS scores reflect local coding habits as well as health.
Different models. 2024 MA scores blend the 2020 and 2024 CMS-HCC models. FFS uses the 2024 model. Indexing removes level differences, not weighting differences.
Timing and weights. Risk scores are 2024 payment data; disruption covers 2025 to 2027. With same-year enrollment weights, correlations soften to about -0.55. Minnesota is still lowest.
State-level analysis. 47 data points. Member-level patterns, such as rural members being more likely to lose a plan, can differ.
No judgment on accuracy. A low ratio says MA scores run below what local FFS would predict, not which side is right.
Methodology and data
Population: individual MA and Cost members, Oct 2026, excluding employer group and PACE (30.1M). State comparisons cover 47 states with 20K+ matched members, excluding Puerto Rico.
Must-choose: a member has a landing plan if any non-terminated crosswalk target is offered in their county in the next year's Landscape.
Payment and risk: CMS Part C payment data joined to enrollment on state, county, plan type and SNP type (about 97% matched). Risk-adjusted payment = standardized A/B payment x risk score. Benchmarks and FFS scores joined on SSA county code.
2023 validation: same results. Risk score correlation -0.66, ratio -0.58, Minnesota ratio 0.76 and lowest.
External check: a JAMA study from Johns Hopkins and Georgetown found 2.9M members (10%) forced to switch for 2026, with Vermont at 92%. Our 2026 figures: 2.94M (10.0%), Vermont 92%.
Sources: CMS Plan Payment Data (2023, 2024); CMS Ratebooks & Supporting Data (2023, 2024 and 2027 rate books; 2027 FFS risk scores, 2020 to 2024); CY2027 Plan Crosswalk and Landscape; MA enrollment by county (Oct 2026); 2025 and 2026 must-choose via Vlada (CMS Landscape and Crosswalk, Sept enrollment). Outside research: MedPAC on coding intensity across MA organizations; MedPAC coding estimates after V28; Finkelstein et al., Adjusting Risk Adjustment; JAMA 2026 forced disenrollment study; Blue Cross MN 2027 changes; UCare exit; Minnesota Cost plan history (1).
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What MMI + Subscribers read this week…
The Medigap Map🗺️: 183 Counties Where MA-PD Isn't an Option in 2027 - Where MA left, and where Medigap is filling the gap. (link)
2027 MA Crosswalks: Who's Being Auto-Enrolled into New Plan IDs👟 - 2.1 million Medicare Advantage members land in a new plan on January 1. Here's who's moving them and where. (link)
Oct ‘26 MA/MAPD and PDP enrollment data - October enrollment data has been loaded. Here are a few observations. (link)
11% of Medicare Advantage enrollees are losing their plan in 2027! 👋- Seven carriers are exiting individual MA entirely, Local PPO disruption climbs to 19%, and Minnesota faces a near-total reset. (link)
Insurance Regulatory Insights October 2026 - State bulletins, federal rulemaking, and a fresh round of MA bills — what's final, what's new, and what's moving. (link)
Tea Leaves - AEP 2027 🍂 - Repository of 2027 AEP changes / opportunities (link)
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