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 Metric | NC Plans Richer? | Non-Commissionable | Commissionable |
|---|
| Average Benefit Richness Score | ✕ No | 23.1 | 29.3 |
| % Offering OTC Benefits | ✕ No | 100% | 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, April 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.
| Carrier | NC Plans | Richness vs. Own Comm | OTC vs. Own Comm | MOOP vs. Own Comm | Post-NC Enrollment |
|---|
| Alignment Health | 9 | +0.3% | −40.5% | +11.3% | −4.4% |
| Anthem / Elevance | 6 | −33.6% | −20.7% | +29.1% | −18.1% |
| BCBS TX / HCSC | 3 | +15.2% | +5.5% | +3.6% | −4.2% |
| Devoted Health | 5 | −8.3% | −23.1% | −5.0% | — |
| Elevance / Anthem | 26 | −23.2% | −30.8% | +32.1% | −19.8% |
| Florida Blue | 9 | −20.8% | — | +10.4% | −27.6% |
| HCSC | 18 | +14.5% | +13.3% | +2.7% | −14.0% |
| HealthSpring / Cigna | 18 | −35.0% | −66.3% | +10.1% | −29.0% |
| Humana | 30 | −18.0% | — | −14.5% | −7.9% |
| UHC / UnitedHealthCare | 34 | −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, plans with sufficient bilateral data.
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: -40ppMid-Size
1,000 – 10,000 members
−15.8%
NC median change
+5.8%
Commissionable median
Gap: -22ppLarge
10,000 – 50,000 members
−1.5%
NC median change
+2.1%
Commissionable median
Gap: -4ppNational
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 Size | NC 2024 Cohort | NC 2025 Cohort | NC 2026 Cohort* | All Cohorts |
|---|
| Small | +125.2% (n=2) | −3.3% (n=13) | −23.2% (n=18) | −4.8% |
| Mid-Size | — | −19.2% (n=42) | −9.5% (n=38) | −15.8% |
| Large | +9.4% (n=11) | −8.5% (n=11) | −6.5% (n=11) | −1.5% |
| National | +3.1% (n=9) | — | — | +3.1% |
*Most recent cohort has limited post-NC data. Treat as early indicators, not conclusions. Green = growth; Red = decline relative to starting enrollment.
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 Metric | NC Plans | Commissionable | What It Means |
|---|
| Star Rating Change (Dec 2025→2026) | −0.041★ declined | −0.024★ declined | NC contracts trending better year-over-year |
| Plans With Star Declines | 23% dropped | 26% dropped | NC 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 Concentration | 54% | 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.
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 298 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 153 plans with sufficient bilateral data. 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.