NC Plan Analysis  ·  May 2026 Overview & Verdicts Detailed Analysis CircleEngage Intelligence
Market Intelligence

Five Assumptions vs. What the Data Actually Shows

We tracked 310 confirmed NC contracts over 36 months and cross-referenced them against the full national plan matrix. Most of what is being said is based on assumptions. Here is what the numbers show.

1,809
NC plans confirmed (floor)
310
contracts with 36mo enrollment history
179
plans with full before-and-after data
53%
of NC plans are mid-size (1K–10K members)
Summary

Five Assumptions at a Glance

Each assumption is tested against CMS enrollment data and the national plan matrix. Verdicts reflect the weight of evidence, not certainty.

Assumption
What the data shows
Verdict
Plans went NC to control costs on their richest products.
NC plans are slightly leaner than commissionable plans on most benefit metrics. Only 2 of 10 carriers showed evidence of targeting richer products.
Mostly False
Going NC always leads to enrollment decline.
NC plans underperformed in 2 of 4 size bands. Impact varies significantly by plan size.
Mixed
NC plans signal broader market distress — benefit cuts, low stars, financial trouble.
Star rating trends are mixed. NC contracts changed -0.041☆ vs. -0.024☆ for commissionable. 23% of NC contracts had drops vs. 26%.
Mixed
Medicare Advantage is contracting and plans are responding by going NC.
MA grew to 35M members in February 2026, up from 34.4M a year ago. Growth slowed from 6.5% to 3.8% but the direction is still up.
Mostly False
Carriers will come back to brokers once they feel the enrollment pain.
NC continuity plans declined −5.6% median vs. commissionable +4.2%. No carrier replaced the broker channel in the data.
Likely True
Assumption 1

Did Carriers Go NC on Their Most Expensive Plans?

The assumption was that carriers targeted their richest products — the best OTC cards, lowest cost-sharing, and most supplemental benefits — to slow enrollment in plans that were too expensive to operate.

Benefit MetricNC Plans Richer?Non-CommissionableCommissionable
Average Benefit Richness Score✕ No23.129.3
% Offering OTC Benefits✕ No100%100%
Average OTC Value (plans that offer it)✕ No$317$539
Average Part D Deductible— inconclusive——
Median MOOP In-Network✕ No$6,700$6,500
% With $0 Plan Premium— inconclusive——
4★ or Above (rated contracts)— inconclusive——

Source: CMS Plan Intelligence Matrix, 5,134 active MA plans, May 2026. NC status from CircleEngage internal tracker compiled from carrier announcements.

Carrier-level nuance: Some carriers did go NC on plans richer than their commissionable counterparts — consistent with cost-management intent. But most went NC on plans that were leaner. The cost-management thesis fails for most plans in the data.
CarrierNC PlansRichness vs. Own CommOTC vs. Own CommMOOP vs. Own CommPost-NC Enrollment
Alignment Health9+0.3%−40.5%+11.3%−4.4%
Anthem / Elevance6−33.6%−20.7%+29.1%−18.1%
BCBS TX / HCSC3+15.2%+5.5%+3.6%−4.2%
Devoted Health5−8.3%−23.1%−5.0%—
Elevance / Anthem26−23.2%−30.8%+32.1%−19.8%
Florida Blue9−20.8%—+10.4%−27.6%
HCSC18+14.5%+13.3%+2.7%−14.0%
HealthSpring / Cigna18−35.0%−66.3%+10.1%−29.0%
Henry Ford Health System2———Too early
Humana30−18.0%—−14.5%−7.9%
Molina Healthcare5———Too early
South Country Health Alliance2———Too early
UHC / UnitedHealthCare34−13.4%—−7.4%−8.7%

Green = NC plans richer / better performing than carrier's own commissionable plans. Red = NC plans leaner / worse performing. Post-NC enrollment: CPSC ±12-month window, 179 plans with sufficient bilateral data (May 2026). Three new carriers (Henry Ford, Molina, South Country) appear in the May matrix with insufficient post-NC history to report enrollment outcomes.

Assumption 2

What Happened to Enrollment After Going NC?

The question is not whether NC plans grew or shrank in absolute terms. It is how NC plans performed compared to commissionable plans of the same size, in the same market, at the same time.

Small
Under 1,000 members
−4.8%
NC median change
+35.0%
Commissionable median
Gap: -40pp
Mid-Size
1,000 – 10,000 members
−15.8%
NC median change
+5.8%
Commissionable median
Gap: -22pp
Large
10,000 – 50,000 members
−1.5%
NC median change
+2.1%
Commissionable median
Gap: -4pp
National
50,000+ members
+3.1%
NC median change
−0.9%
Commissionable median
Gap: +4pp

NC medians: CMS CPSC enrollment, plans with sufficient bilateral data. Commissionable medians: CMS LIS Enrollment files, continuity plans only (>100 enrolled both years).

The Humana number you may have seen is not what it looks like. Humana's widely cited +1.2M enrollment growth came from plan consolidation — 76 plan-PBP combinations exiting and absorbing ~285,000 members into surviving plans. Humana NC continuity plans (plans in both years with >100 members) actually declined: −4.2% aggregate, −9% median, with 65% of plans declining.
Plan SizeNC 2024 CohortNC 2025 CohortNC 2026 Cohort*All Cohorts
Small+125.2% (n=2)−3.3% (n=13)−22.1% (n=27)−4.8%
Mid-Size—−19.2% (n=42)−10.1% (n=51)−15.8%
Large+9.4% (n=11)−8.5% (n=11)−6.5% (n=11)−1.5%
National+3.1% (n=9)——+3.1%

*2026 cohort now has 4–5 months of post-NC data for most plans. Early declines are not stabilizing — mid-size 2026 plans are tracking worse than the 2025 cohort at the same offset. Green = growth; Red = decline relative to starting enrollment.

Data Signal

The Enrollment Paradox

NC plans in the 2025 cohort show marginally better star rating trajectories than their commissionable peers. Yet enrollment continued flowing toward commissionable plans — including ones with declining star ratings. This pattern holds across size bands and carrier groups.

What the data shows: NC contracts improved an average of +0.024★ from 2025 to 2026. Commissionable contracts declined −0.022★ over the same period. Despite this, NC plans as a class underperformed commissionable plans by 13–18 percentage points at the median across every size band. Enrollment is not following quality signals.
What the data cannot answer: Whether this reflects agent incentive structures, carrier marketing practices, or beneficiary search behavior cannot be determined from enrollment data alone. All three explanations are consistent with the pattern observed. Disentangling them would require agent-level placement data that is not publicly available.
New Analysis

The Distribution Channel Effect: Which Plan Types Suffer Most?

NC status does not affect all plan types equally. The enrollment penalty from removing broker commissions is 3–5x larger for broker-dependent products than for plans distributed through institutional or Medicaid-aligned channels. The gradient is clean and consistent across size bands.

PPO
Most broker-dependent
−30pp
NC enrollment gap vs. commissionable
58% of PPO plans are NC. NC PPO median enrollment 3,138 vs. 2,104 for commissionable — carriers went NC on their larger products.
HMO
Moderate broker reliance
−12pp
NC enrollment gap vs. commissionable
35% of HMO plans are NC. More direct enrollment and employer group pathways partially offset the broker channel loss.
I-SNP
Institutional / facility channels
−6pp
NC enrollment gap vs. commissionable
15% of I-SNP plans are NC. Institutional channel (nursing facilities, long-term care) is largely broker-independent — smallest penalty in the data.
Plan Type Not Confirmed NC Growth NC Growth Gap (pp) NC Rate Interpretation
PPO +19.7% −10.2% −30pp 58.2% Largest gap — highest broker dependence
C-SNP +67.5% +38.5% −29pp — Large gap despite Medicaid channel — broker support may still matter for dual-eligible enrollment
D-SNP +4.0% −15.2% −19pp — Moderate gap — Medicaid-aligned but broker-enrolled
HMO +9.0% −3.3% −12pp 35.0% Moderate gap — partial direct channel offsets broker loss
I-SNP +8.7% +2.8% −6pp 14.9% Smallest gap — institutional channel is broker-independent

Source: CMS LIS Enrollment files 2025 and 2026, continuity plans only (>100 enrolled both years), joined against Plan Intelligence matrix for plan type classification and NC status. NC_Distribution_Channel_Analysis_2026_05.csv. S-prefix PDP contracts excluded throughout.

NC plans are larger than commissionable plans. NC PPO median enrollment is 3,138 vs. 2,104 for commissionable PPOs (+49%). NC HMO median is 3,053 vs. 2,218 (+38%). Carriers are not going NC on marginal products — they are removing commissions from their high-volume flagships and betting they can hold enrollment without broker support. The data shows that bet is failing at the PPO level by 30 percentage points.
What the data cannot answer: Whether the C-SNP gap reflects broker channel removal specifically, or whether NC C-SNPs have other quality or market differences, cannot be determined from enrollment data alone. The C-SNP finding warrants further investigation before being cited as broker-channel evidence.
Assumption 3

Are NC Plans a Sign of Broader Plan Distress?

The assumption was that NC plans are the ones cutting benefits, losing stars, and exiting markets. The reality is more structural: carriers appear to be identifying plans where broker-channel dependency is lowest.

Quality MetricNC PlansCommissionableWhat It Means
Star Rating Change (Dec 2025→2026)−0.041★ declined−0.024★ declinedNC contracts trending better year-over-year
Plans With Star Declines23% dropped26% droppedNC plans less likely to have declined
4★ or Above (rated contracts)——Gap reflects PPO/size composition, not deterioration
% With $0 Premium——NC plans attract price-sensitive members
PPO Concentration54%34%PPO members navigate more independently
Important: The PPO structural argument does not hold in practice. National and large plans — which are disproportionately PPOs — had the steepest enrollment declines after going NC. Plan type does not protect against enrollment loss when commissions are removed.
Carrier Intelligence

Carrier Posture: Who Is Likely to Return to Brokers?

Not all NC decisions look the same in the enrollment data. Based on 179 plans with post-NC history, carriers fall into four postures. This is not a prediction — it is a pattern from the data as of May 2026.

Carrier Posture Post-NC Median Evidence
Aetna (S5601) ↑ Growing +6.0% National-scale direct channel replacement confirmed. 2024 cohort now 16+ months post-NC with sustained growth. The exception that proves the rule.
Blue Shield CA ↑ Stable / Growing +8.3% Two large plans, both growing post-NC. Limited data window but consistent direction. Watch for AEP 2026 enrollment.
BCBS TX / HCSC → Mixed −4.2% Highly variable across plans within the same carrier. Some growing, some in severe decline. Segment before drawing conclusions.
HCSC → Mixed −14.0% Wide variance. Several plans growing strongly post-NC; others down 50–92%. Not a single carrier story.
Humana ↓ Declining −9.0% Continuity median negative across size bands. Consolidation masks the underlying decline in aggregate figures. 65% of continuity plans declining.
UHC / UnitedHealthCare ↓ Declining −8.7% Consistent mid-size decline across 34 contracts. Pattern is uniform, not isolated to specific markets.
Elevance / Anthem ↓ Declining — Confirmed Exits −19.8% Two confirmed MA plan terminations (H1732: −54.2% enrollment-driven exit; H3342: administrative closure). Multiple contracts declining portfolio-wide 2023–2024. Steepest average decline of any major carrier. No visible direct-channel replacement at scale.
HealthSpring / Cigna ↓ Declining — Exit Risk −29.0% Consistent steep declines across all 10 plans. Pre-NC trend was already negative on several. Warrants monitoring for plan exits.
Florida Blue ↓ Declining — Return Candidate −29.8% No visible direct-channel replacement. Steepest consistent decline of any regional carrier. The enrollment gap is measurable and growing. Most likely regional carrier to return to broker commissions.

Posture classification based on CPSC enrollment data, 179 plans with post-NC history, May 2026. Postures reflect enrollment patterns only — they are not statements about carrier financial health or strategic intent. "Exit Risk" means enrollment trajectory is consistent with plans that have historically preceded market exit; it is not a prediction.

New Analysis

Is NC Status a Precursor to Plan Termination?

We cross-referenced 113 confirmed H-prefix MA NC contracts against the 2026 active landscape to identify which plans have since exited the market. The answer reframes the brokerage question: NC is not a reliable exit predictor, but the pathway exists — and it has a recognizable signature.

1.8%
of MA NC contracts have genuinely terminated — 2 of 113 confirmed H-prefix contracts, both Anthem/Elevance.
17 mo
median time from NC effective date to market exit, across confirmed terminations. Range: 11–23 months.
−54%
enrollment decline before exit in the clearest case (H1732, Anthem/Elevance). A 48% single-month drop in January 2024 marked plan closure notification.
Contract Carrier NC Year Months to Exit Enrollment Decline Exit Type
H1732 Anthem / Elevance 2023 23 −54.2% Enrollment-driven — members moved to other carriers
H3342 Anthem / Elevance 2025 11 −3.0% Administrative — strategic closure, not market failure

Source: NC tracker (113 unique H-prefix MA contracts) cross-referenced against Plan_Intelligence_with_Outcomes_2026_05.csv. H-prefix only — standalone PDP contracts (S-prefix) excluded per CMS MA analysis conventions. Consolidation check performed on all terminated contracts against sibling carrier contracts in CPSC data. H4801 (BCBS TX, +19% growth before exit) and H0352 (Wellcare, insufficient CPSC history) excluded from confirmed termination table.

The Elevance context matters. Both terminated contracts are Anthem/Elevance products. This is not a cross-carrier finding — multiple other Elevance contracts (H0544, H3655) were also declining sharply in the same 2023–2024 window, suggesting broader carrier market challenges beyond the NC decision itself. NC may have accelerated exit for H1732, but it was not operating in isolation.
The two exit mechanisms are different things. H1732 shows the NC → enrollment decline → market exit pathway. H3342 exited with only −3% enrollment loss — that is administrative portfolio pruning, not a plan that failed in the market. Conflating these two patterns overstates the predictive value of NC status for plan exit.
What to watch for. H0352 (Wellcare, NC effective March 2026) has no CPSC history yet. Plans with sustained enrollment decline of >30% over 12+ months post-NC, combined with no evidence of direct-channel replacement, are the profile most consistent with H1732. Monitor: HealthSpring/Cigna plans (average −29.0%), Florida Blue plans (average −29.8%).
Assumptions 4 & 5

Is the Market Contracting? Will Carriers Come Back?

35M
MA members — up from a year ago. The market is not contracting.
3.8%
most-recent annual growth rate, down from 6.5% in the prior year. Slowing, not reversing. Non-SNP broker-heavy plans grew slowest.
−9.8pp
The enrollment gap between NC and commissionable continuity plans at the median. That is a measurable, attributable cost.
No carrier replaced the broker channel. NC continuity plans declined −5.6% at the median while commissionable plans grew +4.2%. Whether any given plan acts on that gap depends on whether they measured it and whether the outcome was intended. The carriers most likely to return to brokers are the ones who can see the gap clearly.
Implications

What to Do With This Information

For Health Plan Sales & Distribution Leaders
  • If your plan is in the under-1,000-member range and went NC without a direct-channel replacement strategy, the data puts the expected enrollment cost at 40 percentage points below where commissionable plans of your size landed. That gap has widened since prior periods.
  • PPO concentration does not reduce NC risk. Large and national PPO-heavy plans had the steepest enrollment declines. The structural argument does not hold in practice.
  • If you went NC on a plan, expect the narrative that you cut your best products. The data says that is usually wrong — but the perception will exist. Getting ahead of it with data is more credible than messaging alone.
For Brokerage Heads of Sales
  • Note: Aetna showed NC plan growth this period. Monitor whether this reflects channel replacement or consolidation artifacts.
  • The leverage argument is universal, not segmented. NC plans underperformed commissionable plans by 13–18 points at the median across every size band. The enrollment cost is present at every scale.
  • There is no guarantee plans will return, even in a better market. Carriers who attributed the enrollment shortfall to other factors have less reason to change course.
Limitations

What This Data Cannot Tell You

  • Whether any carrier's NC decision was financially correct. We do not know what each plan was trying to achieve or what their cost structure looked like.
  • Why NC plans have a lower 4☆+ rate. Year-over-year trajectory rules out deterioration, but the composition explanation — PPO-heavy and smaller plans — needs a longer time series to confirm.
  • Whether mid-size enrollment declines were intentional. Some carriers may have targeted exactly the outcome we observed.
  • How the most recent NC cohort will look at 12 months. Most 2026 plans have approximately 3 months of post-NC history at the time of this analysis. Those findings are provisional.
  • Whether regulatory changes will shift carrier strategy. Recent CMS rulemaking is favorable to brokers, but favorable rules do not force carriers to reinstate commissions.
  • What happened in the NC plans not in our tracker. Our CPSC sample is directional. The true NC vs. commissionable gap is likely larger than what we report.
Methodology

How We Analyzed This

CMS Plan Intelligence Matrix

Cross-sectional snapshot of all 5,134 active MA plan contracts for the current cycle, built from four CMS source files: the Landscape file, CPSC enrollment file, Part C and D Star Ratings master tables, and PBP benefit data file. NC status was determined by matching contract IDs against our internal tracker compiled from carrier announcements and broker bulletins. The matched plans are a confirmed floor — some plans in the comparison group may be NC plans not yet captured, meaning the true gap is likely larger than reported.

CPSC Enrollment Tracker

36 months of CMS CPSC monthly enrollment data. For each of the 310 confirmed NC contracts, we measured enrollment in the 12 months before and after the NC effective date. We required at least 3 months of valid data on each side, yielding 179 plans with sufficient bilateral data (up from 153 in April as 2026 cohort plans accumulate post-NC history). Plans showing a worsening enrollment trend after going NC are the dominant pattern; the mid-size segment is the most internally consistent signal in the data.