Medigap Market Update: Double-Digit Rate Hikes, New Rules Ahead

September 2025 update on the Medigap Market

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Here is what you’ll find in this week’s newsletter!

  1. Important links 🔗 - the best articles we found this week about the Medicare Market along with links to Jared’s recent LinkedIn posts.

  2. Deep Dive 📚 - Medigap Market Update: Double-Digit Rate Hikes, New Rules Ahead

  3. 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:

  1. Individual Supplemental Health Insurance Market Earns Nearly $10 Billion in Premium during 2024 - (link)

  2. American Hospital Association urges Aetna to rescind new MA inpatient payment policy - (link)

  3. CVS to expand program aimed at reducing hospital readmissions for Medicare members - (link)

  4. AHA-supported legislation would apply prompt payment standard to MA plans - (link)

  5. CMS orders Medicare Advantage plans to disclose provider networks - (link)

  6. Samaritan announces it is cutting Medicare Advantage service- (link)

  7. NCQA Releases 2025 Health Plan Ratings - (link)

  8. Prior auth catches congressional heat - (link)

Jared’s recent LinkedIn posts:

  1. Tea Leaves - AEP 2026 - (link)

  2. 6 new Birthday Rule Adopters. - (link)

  3. Health Alliance expected to exit MA market in 2026 - (link)

  4. September 2025 MA/MAPD and PDP enrollment data - (link)

DEEP DIVE 📚

Medigap Market Update: Double-Digit Rate Hikes, New Rules Ahead

The Medigap market has been relatively steady when compared to the turbulence in Medicare Advantage. But beneath the surface, the Medigap market also has pressure.

Carriers are filing fewer new products, regulators are reshaping enrollment rules, and rate increases are climbing faster than in recent years.

In this week’s update, we take a closer look at new product activity, rate filings, updated claim trend estimates, and regulatory developments shaping the Medicare Supplement landscape.

New Products

Chubb has continued filing new Med Supp plans under its “Insurance Company of North America” charter.  The filings contain Plans A, F, G, HDG and N and will include a 7% household discount.

No other companies have initiated new multi-state product filings. New product roll-outs have been slowed by uncertainty in claim trends, elevated loss ratios and birthday rule expansion.

→ Carriers are beginning to look at new product opportunities as the market stabilizes.

Rate Increases

→ 2025 rate filings continue to show approved increases that are 2.5% - 3.5% higher than those approved in 2024.

→ The following chart shows the average rate increases on open Medigap blocks for Plans F, G, and N over the past four years. 

→ The frequency of double digit rate changes continues to increase. They are much more common in 2025 than in previous years. The following table shows the frequency of Plan G rate increases by different levels of increase. Only 38% of rate increases are below 10% compared to 66% in 2024 and 83% in 2023.

Increase Amount

2022

2023

2024

2025

20%+

1%

1%

1%

12%

15 – 19.9%

4%

5%

11%

19%

10 - 14.9%

15%

12%

23%

31%

5 - 9.9%

45%

48%

55%

30%

<5%

36%

35%

11%

8%

Updated Medigap Claim Trend Estimates

→ Experience through mid-year suggests that Medigap claim cost trends may be down 1% from previous years.

→ Plan F and Plan G medical trends have been ranging from 10-11% over the past 3 years.

2025 experience is showing medical trends between 9-10% (a modest easing).

Loss Ratios continue to be elevated, largely due to the lag between approval of rate increases and when they impact the experience.

Regulatory Updates

Delaware recently updated their regulations to introduce a new Birthday Rule enrollment window. This new rule has an effective date of January 1, 2026.

Indiana DOI distributed email to clarify that carriers are no longer permitted to cap commissions at 2% of premium on policies issued to individuals eligible for Medicare by reason of disability.

The following states had proposed regulations this year, but most failed due to legislative sessions ending. California, Michigan, Ohio and Illinois’ legislative sessions are still open.

  1. Under 65/Disability/ESRD

    1. California

    2. Georgia

    3. Illinois

    4. Iowa

    5. Michigan

    6. Ohio

    7. Rhode Island

    8. Texas

  2. Open Enrollment Periods

    1. California

    2. New Hampshire

    3. Vermont

    4. Washington

    5. Oregon

    6. Rhode Island

  3. Birthday Rule Guaranteed Issue

    1. Iowa

    2. Michigan

    3. Nebraska

    4. New Mexico

For more detailed information on Regulatory changes, you can subscribe to our Insurance Regulatory Insights newsletter.

Bottom Line

→ New product activity remains muted. Beyond Chubb, carriers are hesitant to launch until loss ratios stabilize, though we expect interest to pick up.

Rate pressure is intensifying. 2025 filings are coming in ~3 points higher than 2024, and double-digit increases are now common — a shift that will continue to strain affordability and distribution.

Claims are moderating slightly, but not enough to offset losses. Trends are down modestly, but loss ratios continue to be elevated.

Regulation is expanding. New birthday rules (Delaware) and commission clarifications (Indiana) show states are still actively reshaping Medigap rules, with more changes likely in 2026.

SPONSOR SNAPSHOT 🚀: Medicare Market Insights Plus

What is Medicare Market Insights - Plus?

  1. Tea Leaves - AEP 2026

  2. Medicare Advantage Insights Web Application tool

  3. Members-Only Content

  4. Insurance Regulatory Insights + Reg Tracker

All the moving pieces in the Medicare market result in opportunities!

  • Opportunities for you to help more consumers.

  • Opportunities for distributors to grow books of business.

  • Opportunities for Carriers to add new members.

  • Opportunities for Investors to invest in companies solving problems in the changing Medicare space.

What are you going to do to take advantage?

Stop guessing. Start making informed decisions.

What MMI + Subscribers read this week…

  • Tea Leaves - AEP 2026 🍂 - Repository of 2026 AEP changes / opportunities - (link)

  • September '25 MA/MAPD and PDP enrollment data - September '25 enrollment data has been loaded. Here are a few observations. (link)

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  • Monthly newsletters providing insight into recent insurance regulatory action

  • Access to Reg Tracker, a comprehensive list of insurance regulatory actions in all states for this calendar year that are included in the newsletters.

Insurance Regulatory Insights is now included in your MMI+ subscription! You can also subscribe using the link below.

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