Medigap Rate Increase Letters: How to Re-Shop Clients Without Underwriting Surprises

When a client's Medigap rate goes up, agents should check whether any guaranteed-issue or state rule applies, pre-qualify them for underwriting, compare total value, and keep the current policy until a new one is approved.

Quick answer:

• A rate increase alone is not a federal guaranteed-issue right. Outside the 6-month Medigap open enrollment period or a GI situation, most clients face underwriting.

• Check state rules next. Some states add birthday, anniversary or year-round rights.

• Pre-qualify before you quote. Health questions first, price second.

• Never cancel the old policy first. Wait for approval, then use the 30-day free look.

• Compare more than premium. Rating method, rate history, discounts and the carrier's record all matter.

This builds on my Medicare Supplement underwriting field guide. If underwriting is new to you, start there.

A rate letter is not a crisis. It's a service moment. The agent who calls first, with a plan, keeps the relationship.

This is not legal advice. Verify with the carrier and the state insurance department.

Why 2027 renewals are hitting hard

Medigap rates are filed with state regulators. Go to the filings. The NY DFS summary of 2027 Medicare supplement requested rate actions, dated July 10, 2026, shows a weighted average request of +9.5% in the individual market and +12.2% in the group market. The 12 individual-market insurers' averages ranged from +2.5% to +30.0%.

Those are requests, not approvals. DFS says they "have not been approved by DFS." The additional information page lists each filing's SERFF number, effective date (mostly January 1, 2027) and narrative summary. The narrative is the carrier's own explanation of why.

That's one state. I don't have a national number from a primary source, and I won't make one up. Elsewhere, SERFF Filing Access shows public filings in participating states, and CMS suggests asking your SHIP for a "Medigap rate comparison shopping guide" (CMS, Choosing a Medigap Policy).

With clients, label it right: requested or approved. The number that counts is the one on their renewal notice.

Who can actually move

Federal GI vs state rules

Medicare.gov: "In most cases, you won't have a right under federal law to switch Medigap policies" outside the 6-month Medigap open enrollment period or a guaranteed issue right (Medicare.gov).

The federal GI situations in CMS's guide are:

• Their MA plan leaves Medicare, stops serving the area or has a significant network change, or they move out of the service area, and they return to Original Medicare.

• Employer group coverage (including retiree, COBRA or union) that pays after Medicare is ending.

• They move out of a Medicare SELECT service area.

• Trial rights: they joined MA or PACE when first eligible at 65, or dropped Medigap to try MA for the first time, and leave within a year.

• The Medigap carrier goes bankrupt, or coverage ends through no fault of their own.

• The company didn't follow the rules or misled them.

Notice what's missing. "My premium went up" isn't on the list (Social Security Act 1882(s)(3)). MA clients losing a plan, or wanting out, are a different conversation: see my plan exits guide and can MA clients switch to Medigap.

State law can add rights. Verified examples:

• New York: insurers must accept applications "at any time throughout the year," with no health-based denials or pricing (NY DFS).

• Connecticut: plans are "community-rated and guaranteed-issue," per the state's CHOICES Medigap chart (revised July 2025).

• California: 60 days from the birthday, equal or lesser plan (California DOI).

• Oregon: 30 days before to 30 days after the birthday (Oregon DFR).

• Missouri: an anniversary window, same plan letter (Missouri DOI).

The NAIC birthday rule chart lists more states, some effective as recently as January 2026. Check the client's state every time.

Underwritten switches

Everyone else gets underwritten. Outside open enrollment and GI, the carrier "is allowed to deny you a policy if you don't meet their medical underwriting requirements" (Medicare.gov).

Fine for a healthy client. A problem for one with a recent diagnosis.

One timing rule: if the current policy has been in force more than 6 months and the new one has the same benefits, the new carrier can't exclude pre-existing conditions or make the client wait. Under 6 months, there can be a wait (CMS guide, pages 26 to 27).

The re-shop workflow

1. Read the notice. New premium, effective date, plan letter.

2. Check rights. Open enrollment, federal GI, state rule. Keep the proof.

3. Pre-qualify. Run the carrier's health questions honestly before you quote. Leaving out material medical facts can give the carrier grounds to deny claims later (NAIC Model 651, replacement notice).

4. Quote the same plan letter. CMS says the premium "is the only difference between policies with the same plan letter sold by different companies." Compare G to G.

5. Apply with the replacement notice. The client and agent sign it, and it says: "Do not cancel your present policy until you have received your new policy and are sure that you want to keep it."

6. Wait for approval and the policy. Federal law gives at least 30 days after issue to return it for a full refund (SSA 1882(c)(4)). That's the free look. The client pays both premiums that month.

7. Cancel the old policy last. Once it's gone, they may not get it back.

8. Document the why. The NAIC model requires reasonable efforts to determine that a replacement is appropriate.

Comparing beyond premium: rate history, household discounts, carrier stability

Cheapest today is not cheapest over time. Use CMS's shopping questions.

• Rating method. CMS lists community-rated, issue-age-rated and attained-age-rated. Attained-age policies "may be the least expensive at first, but they can eventually become the most expensive."

• Rate history. CMS tells buyers to ask, "Has the premium for this Medigap policy increased in the last 3 years due to inflation or other reasons?" In New York, rate filings include a history of rate adjustments exhibit.

• Household and other discounts. CMS mentions discounts "like for women, non-smokers, or married people; for paying yearly or for paying your premiums using electronic funds transfer; or for multiple policies." Get them in writing.

• Carrier stability. Check complaints with the state insurance department. The NAIC's complaint research guide points to a carrier's financial condition and three years of complaints, and warns against deciding on one factor.

When staying put is the right answer

• The client won't qualify. A higher premium beats losing coverage.

• The policy is under 6 months old and a pre-existing condition wait could apply.

• The old policy has benefits that aren't sold anymore. CMS notes policies bought before June 1, 2010 "may offer coverage that isn't available in a newer Medigap policy."

• The savings are thin, or the cheaper option is attained-age and the gap closes with age.

You can still ask the current carrier about other plan letters or a high-deductible option, and whether that needs underwriting.

A cheaper policy is not a win if it puts coverage at risk.

Proactive outreach to your book

Call your existing clients before the letter does the talking. Sort by who got a notice, who has a state window coming and who may have GI. Keep it simple: your notice came, let's review it, and nothing changes unless it makes sense.

Be careful with non-clients. States regulate Medigap marketing, and the NAIC model bans "cold lead advertising" that hides that it's an insurance solicitation. If it touches MA or Part D, CMS rules bar unsolicited calls, texts and social media DMs (42 CFR 422.2264). My compliance checklist and SOA and TPMO guide cover the MA side.

Rewrite for the client, never for a new first-year commission. The NAIC model prohibits twisting: misleading comparisons to get someone to drop a policy. Consumer mailers and emails go through approval where required.

Brock partners can find an underwriting quoting tool that covers Med Supp on our agent resources page.

FAQs

Can my client switch Medigap plans anytime?

They can apply anytime, but outside open enrollment, a GI right or a state rule like New York's, most carriers can underwrite.

Does a rate increase give my client a guaranteed issue right?

Not under federal law. Some states have birthday or anniversary windows, so check the client's state.

Where can I see filed rate increases?

State DOI sites and SERFF Filing Access show many filings, and some states post summaries, like New York's 2027 requested rate actions. Note whether a figure is requested or approved.

Is a lower premium always better?

No. Compare rate history, rating method, discounts and carrier stability too.

Should my client cancel the old policy once they apply?

No. Wait until the new policy is issued, use the 30-day free look, then cancel the old one.

Have a book full of rate-increase calls? Book a call and let's talk about how Brock supports Med Supp agents.

A rate letter is not a cancellation notice. It's an appointment.