For 2027, 183 counties and county-equivalents across 16 states and the U.S. Virgin Islands have no MA-PD plan open to general enrollment. For roughly 551,000 Medicare eligibles in those areas, the AEP conversation isn't "which Advantage plan?" It's Original Medicare, a standalone Part D plan, and whether to add Medicare Supplement coverage.
That makes these counties the clearest Medigap market in the country right now. An estimated 206,000 beneficiaries already hold an MS policy there, and the share of eligibles who don't is the opportunity.
Three versions of "no MA-PD"
More than half of these counties still have some MA-PD presence, but only through Special Needs Plans. A typical beneficiary who isn't dual-eligible or institutionalized, and has no qualifying chronic condition, can't enroll.
Category | Counties | Medicare eligibles | Est. MS enrollment |
|---|---|---|---|
MA-PD only through SNPs | 97 | 304,948 | 87,028 |
No MA plan of any kind | 55 | 219,518* | 108,200 |
No MA plan; cost plan with Part D | 31 | 26,614 | 10,632 |
Total | 183 | 551,080 | 205,860 |
*Excludes Alaska's 23 boroughs and census areas, where eligible counts weren't available.
The cost-plan counties are concentrated in the Dakotas, where Section 1876 cost plans remain a Part D-inclusive alternative to MA. The SNP-only group has the lowest Medigap share, which suggests these counties held meaningful MA enrollment until recently.
What's driving it: carrier exits, not new deserts
Most of these counties had general-enrollment MA-PD until recently. The clusters in our data map to specific carrier decisions for 2026 and 2027.
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