Medicare market disruption is inevitable, but recent changes in the market are throwing all stakeholders off balance, including carriers, agencies, and agents. As insurance companies adjust to evolving federal regulations, some are modifying commission structures.
As we approach the next annual enrollment period (AEP), agents are concerned about their income and how to best serve their clients during this period. But agencies can remain resilient, member-focused, and profitable with the right strategy.
This article provides an updated overview of non-commissionable plans, why carriers are making unprecedented changes, and what you can do to protect your agents and clients.
We’ll also share insights from Samantha George, Director of Client Relationships at The Baldwin Group and expert in the Medicare space, who highlights areas of opportunity to best serve your clients and stay informed as we enter AEP 2026.
Historically, non-commissionable plans were rare. Only a handful of products from each carrier didn’t pay agents. But the market is evolving rapidly, and non-commissionable plans are now impacting many agents across the country.
Before we get into why carriers are discontinuing commissions and how you can take action, we want to share our overview of non-commissionable plans to recap recent changes. We’ll keep this overview updated as we learn more.
Aetna
As of 2024: New sales of select HMO, PPO, and HMO/PPO D-SNP and I-SNIP Advantage plans are non-commissionable. Renewals honored. States impacted include CA, CT, DC, FL, MD, NY, TX, UT, and VA.
Starting 2025: All new Part D sales are non-commissionable. Renewals honored.
Allstate
Starting 2025: Supplement plan applications are no longer available electronically. Commissions honored.
Cigna
As of 2024: New sales of select PPO Advantage plans are non-commissionable. States impacted include CT, GA, NJ, and NY. Select PPO Advantage plans are suppressed in AL, AR, AZ, CO, CT, DC, DE, GA, IL, KS, KY, MO, MS, NC, NJ, NY, OH, OK, OR, PA, SC, TN, TX, UT, VA, and WA. All Part D plans are suppressed. Renewals honored.
Elevance/Anthem
As of 2024: New sales of select D-SNP, C-SNIP, HMO, PPO Advantage plans are non-commissionable. Renewals honored. States impacted include CA, CT, GA, IA, IN, KY, ME, NH, NJ, NY, OH, TN, TX, VA, and WI.
Starting 2025: All Advantage plans are suppressed (except D-SNP).
HSCS/BCBS
As of 2024: New sales of select PPO, HMO, and PDP Advantage plans are non-commissionable. Part D sales are non-commissionable across all states. All renewals honored. States impacted include IL, MO, NM, OK, and TX.
Humana
Starting 2025: New sales of select PPO and HMO Advantage plans are non-commissionable. Renewals honored. States impacted include CO, FL, GA, IN, IA, KY, LA, MA, NM, ND, OH, SC, TN, TX, VA.
UnitedHealth Group
Starting 2025: All new Part D sales are non-commissionable. Select PPO, HMO, and SNP Advantage plans are suppressed in CA and VT. Renewals honored.
WellCare
As of 2024: New sales of Part D and renewals are non-commissionable. All PPO Advantage plans are suppressed in CA, LA, NY, OR, and WA. Commissions honored.
As insurance carriers adapt to new rules and regulations governing Medicare products, they adjust their strategies to stabilize cost structures and plan distribution. Several factors influence the shift to non-commissionable plans, including the three listed below.
The Inflation Reduction Act (IRA) was introduced in 2022 and included several provisions aimed at reducing Medicare insurance costs for beneficiaries. Most of these provisions targeted drug costs.
While these changes make drug costs more affordable for beneficiaries, they place more responsibility on insurance carriers. Many point to one of the newest IRA rollouts, the Part D out-of-pocket cap, as the breaking point. For example, in some ZIP codes where many beneficiaries need expensive medications, carriers need to shift their strategy to minimize risk.
As of this year, the Centers for Medicare and Medicaid Services (CMS) has expanded coverage for behavioral health care. Medicare Part B will expand its coverage of mental health services to include mental health counselors, addiction counselors, and marriage and family therapists. Supervision requirements no longer require a doctor, physician assistant, or nurse practitioner to be on site, which allows behavioral health professionals to deliver more services with fewer restrictions. Medicare will also continue to cover telehealth, a COVID-era allowance that has proven helpful for those with limited access to in-person providers.
Since Medicare Advantage plans are required to cover all services offered under traditional Medicare, carriers have to consider the expanded coverage in their plan designs and cost structures. Behavioral health services may also include psychiatric evaluations and medications, so insurers must also account for the additional costs of drug prescriptions for mental health conditions after the new out-of-pocket cap.
In January 2024, CMS released the Interoperability and Prior Authorization Final Rule, which requires insurers to expedite prior authorization processes. They must authorize or deny a proposed service within seven days, or 72 hours for urgent decisions. Insurers must also develop systems to automate provider requests and enhance data exchange, which further expedite the process. And finally, insurers must publicly report how often they approve or deny prior authorization requests.
While this final rule benefits patients and providers, insurance carriers take on the administrative burden of meeting these requirements. They may need to hire additional personnel to approve prior authorizations under tighter deadlines and allocate funds toward building efficient systems for provider-insurer communication by January 2027.
To meet these new standards and remain compliant, carriers must balance cost, accessibility, and compliance priorities while re-evaluating commission models. More regulations are on the horizon, so agencies should prepare for possible changes as late as the fourth quarter of the year (similar to what we saw last year).
Unfortunately, the market’s turbulence is unpredictable, and agents feel the pressure. Good agents are more than salespeople—they build relationships with their clients and help them make life-changing financial decisions about their health. Now, they’re faced with the ethical dilemma of protecting their bottom line.
Agents are also faced with legal challenges. All agents are required to carry errors and omissions insurance. The policies of this insurance state that agents must be compensated for their service for the service to be covered. If an agent advises a client on a non-commissionable plan and an issue arises, the agent’s coverage may not apply since the service was rendered without compensation.
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But agents aren’t the only ones affected. Some beneficiaries will see significant changes to their plans, like higher copays or premiums. Many agents may drop out of the industry due to uncertainty, leaving their clients without guidance. And clients may be left to navigate Medicare enrollment on their own. Suppose a client tells their agent that they would like to enroll in a non-commissionable plan. To avoid liability risk, the agent may redirect the client to Medicare’s website or to the insurance carrier itself. Many clients would find this process more tedious and confusing than going through an agency, and they lose their agent as a resource.
So, what do we do about these changes, and how do we protect our business and our clients?
Now, more than ever, agencies need to remain vigilant and encourage agents to keep their heads high. Discontinued commissions aren’t a welcome change, but they don’t have to threaten your business. Instead, the evolving market could strengthen your business if you take advantage of new opportunities to help new or existing clients. Here are three ways to do so as we enter AEP 2026.
Agencies need an effective tool to manage their client base. Maintaining visibility into clients’ needs and unexpected plan adjustments helps agents identify medical changes, new gaps in coverage, and increases in plan costs.
The ConnectureDRX Active Analytics Platform alerts agents when changes in coverage impact your members. The platform offloads agents by providing real-time analytics on market changes and new opportunities, allowing them to confidently service more members.
It’s hard to keep up with the insurance market’s changes. CMS regulations, legislation, and policy changes occur at the blink of an eye, and they’re not always obvious. Agents often learn about changes through an upline or a news headline unless they receive a notice directly from the carrier. A complicated insurance landscape doesn’t bode well for insurance agent turnover—more than 60% of health insurance agents leave the industry within their first two years on the job as it is.
But the turbulence isn’t the only reason agents are leaving the field. About 66% of health insurance agents are 40 years or older, with an average age of 46. Only 11% of agents are young adults entering the field. More agents are approaching retirement, leaving a growing client base of aging Americans behind with fewer agents available to help. The United States is projected to see a 47% increase in older adults (aged 65 and older) from 58 million in 2022 to 85 million in 2050, many of whom are eligible for Medicare benefits.
While some commissions may disappear, the addressable market continues to grow. Agencies can expand their client base by positioning themselves in visible areas for prospective clients and preparing internal processes and systems to handle incoming demand.
Agencies need to abide by CMS marketing restrictions, but there are ways to stay visible in the communities you serve. “I’ve been advising agents to do a lot of educational events virtually or in person. Host a town hall meeting. Invite legislators. Talk about the things that are going on and the changes that are happening right now, whether it’s new legislation or healthcare news,” said George. “Hosting educational events positions you as the subject matter expert and a valuable resource for the community, offering stability, advice, and direction. Bring people together in a common area and have these discussions, so they have a place to go to get the information they need on these topics.”
The agencies and agents most impacted by the discontinuation of commissions are those that rely on a single dominant carrier. Diversifying your portfolio allows you to sell a range of products from multiple carriers, providing greater flexibility as the market evolves. A diverse portfolio also helps you appeal to a broader market and the growing number of older adults.
Here are a few ways agencies can diversify their portfolio to help agents meet their clients’ needs while still making a commission.
Consider selling Affordable Care Act (ACA) products: In 2024, a record-breaking 21.4 million people chose ACA marketplace coverage. This marks the fourth consecutive year of growth. By selling these products, you may develop relationships with adults before they turn 65. If they stick with your agents by the time they turn 65, they’ll be ready to enroll in Medicare benefits. Enrolling new 65-year-olds is a triple win: new sales commissions on eligible products, more opportunities to sell layered coverage, and potential future commissions from renewals (which most carriers still honor).
Given the increased responsibility placed on carriers, we may see higher-than-normal premium increases for Medicare Part D plans and higher out-of-pocket costs for Medicare Advantage plans. Many beneficiaries may need a change, like switching from original Medicare with Part D to a Medicare Advantage plan paired with an ancillary product.
Medicare Advantage plans are also less likely to cover hearing, vision, and dental. Many older adults need coverage in at least one of these areas, so pairing plans with an ancillary product could help beneficiaries receive proper care and account for lost commissions elsewhere.
In some cases, insurance plan adjustments pose an opportunity to move a client from a non-commissionable product to a commissionable one. Keeping a client on a non-commissionable plan might not affect renewal commissions. But according to George, if the plan’s commission structure is adjusted, benefit adjustments could follow.
"Commissions are often a canary in the coal mine, so to speak. Removing commission is something that indicates a stability concern with the plan,” George said.
Agents may not need to move their client right away, as it could still be the best option for them. However, plans that become non-commissionable are likely to experience benefit degradation. In rare instances, they can rebound and resume commissions. If a plan becomes non-commissionable, agents should monitor it closely to ensure it continues to serve their clients. Catching detrimental benefit changes in plans protects the client and creates an opportunity for agents to transition the member to a more stable, competitive plan, when appropriate.
We’ve witnessed many shifts in the insurance industry over the past year, and there are likely more to come. Keeping up with changes can feel overwhelming and complicated, so we asked George about the best way agents and agencies can stay informed.
First, George advised getting educated. “Agents need to understand how to read legislative pieces, bills, and reconciliations. The better you know the healthcare industry, legal language, and the legislative processes, the better off you are,” said George. Otherwise, you’ll find yourself relying solely on interpretations from outlets.
If you do rely on interpretations, seek varied opinions. “Look at multiple outlets and resources that have different vantage points to form your own collective opinion,” she added. This enables you to effectively explain current affairs, helping your clients to see how they may be impacted and what decisions they may need to make about their healthcare. Then, research legislation that has been introduced or recently passed.
You can also stay involved by keeping in touch with your local legislator, if you feel compelled. “You can pick up the phone (or email them) and say, ‘Hey, I want to talk to you about the implications of this bill, good or bad,’ including informing them about how a bill might positively or negatively impact their constituents. The most impactful messages come from their constituents,” said George.
As we move into AEP 2026, we must stay focused on serving our clients. “This is really about seeing the changes as opportunities and not reasons to panic or pull back," stressed George. "We need to be the advocates and stability for beneficiaries, because that’s where the opportunity lies.”
Beneficiaries need agents more than ever. Are you ready to step up to the plate?
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