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April 2, 2026 – At a conference last week, Chris Klomp, chief counselor of the US Department of Health and Human Services and director of the Center for Medicare within the Centers for Medicare & Medicaid Services (CMS), stated that CMS is considering “the feasibility of models” that would automatically enroll beneficiaries into either Medicare Advantage (MA) or “accountable care organizations, such as those that participate in the Medicare Shared Savings Program,” according to Stat News. “Individuals could still opt in to a different insurance arrangement,” Klomp stated.
As the Stat article notes, the concept of automatic enrollment into MA is not novel. A 2024 Paragon Health Institute paper entitled “Improving Medicare Through Medicare Advantage” included a proposal to require new Medicare enrollees to “affirmatively choose” between MA and traditional Medicare upon enrollment in the Medicare program. The Heritage Foundation also has called for MA to be the default option for seniors. However, the devil(ed eggs) of any change to Medicare enrollment is in the details, and it is important to explore possible downstream implications. To help me tuck into these deviled eggs, I’m bringing in my colleagues Parashar Patel, Lynn Nonnemaker, and Olivia Gomez.
Let’s start with how Medicare enrollment works today. Once an individual reaches the age of 65 (or experiences another qualifying event), the initial enrollment period allows them to enroll in traditional Medicare by signing up for both Medicare Part A (hospital insurance) and Part B (medical insurance), or Part A only if they are still covered through an employer group plan. Individuals must enroll during designated enrollment periods to avoid late enrollment penalties that can affect monthly premiums. The initial enrollment period begins three months before and ends three months after the month an individual turns 65. If an individual is still working at age 65 and forgoes Part B enrollment during the initial enrollment period, they can enroll in Part B during a special enrollment period that begins when they stop working.
Typically, individuals must file an application with the Social Security Administration (SSA) to enroll in traditional Medicare. They must provide their date and place of birth, Medicaid number (if applicable), and information on their current health insurance, including their employment start and end dates with the employer that provides current coverage. Individuals who begin receiving Social Security benefits at least four months before turning 65 are automatically enrolled in traditional Medicare when they turn 65 and do not have to complete an application.
Now, what happens if an individual wants to enroll in MA rather than traditional Medicare? Individuals can choose to enroll in an MA plan during the initial enrollment period, but they must first enroll in Parts A and B (i.e., traditional Medicare). When an individual clicks the “Sign Up for Medicare” button on the SSA website, they are presented with links to enroll in Parts A and B, Part B only, and other parts of Medicare. The “other parts of Medicare” link takes them to the Medicare.gov plan compare tool, where they can sign up for an MA plan.
Individuals can also join, switch, or drop an MA plan during annual open enrollment periods. CMS facilitates enrollment in MA plans through Medicare.gov/plan-compare, which allows individuals to compare available plans in their geographic area. The plan compare tool allows users to view plans according to their benefits, quality ratings, monthly premiums, deductibles, and estimated annual drug costs. Eligible beneficiaries may also call 1-800-MEDICARE or directly contact the plan to enroll.
The current process can be difficult for seniors. Many individuals report feeling confused and overwhelmed both when initially enrolling in Medicare and when enrolling in MA.
Because Medicare beneficiaries currently must take multiple proactive steps to enroll in MA, stakeholders have considered a range of policy changes intended to streamline the MA enrollment process. The option that Director Klomp seems to have floated would be to automatically enroll a newly eligible Medicare beneficiary into an MA plan instead of traditional Medicare. A key question would be what plan the individual would be automatically enrolled in. The plan could be determined in accordance with plan cost or popularity, network capacity, overall affordability, or any number of other characteristics. Beneficiaries could be provided with information regarding other plan options and the ability to opt out of the assigned MA plan and into traditional Medicare. Given the rise in MA’s popularity and individuals’ tendency to stay in a plan once selected, many individuals might remain with the plan assigned to them.
While this approach would save beneficiaries from having to first enroll in traditional Medicare and subsequently go through the additional process of enrolling in an MA plan, it would require additional steps for individuals who prefer to enroll in traditional Medicare. Some commenters argue that this approach might make it more difficult for a beneficiary to choose traditional Medicare. Default enrollment also could make it more challenging for a beneficiary to obtain Medigap without medical underwriting in the future. Under current Medigap rules, beneficiaries can disenroll from MA within the first year of initial MA enrollment and still obtain Medigap without medical underwriting (guarantee issue). With default MA enrollment, beneficiaries in most states would lose the right of guarantee issue if they chose to switch back to traditional Medicare later on.
Automatic enrollment could be especially impactful to individuals who may benefit from enrollment in special needs plans (SNPs). If default enrollment were to take SNP eligibility into account and proactively assign individuals to an appropriate SNP, it could help increase access to integrated care management programs. However, SSA would need to collect additional information about an individual’s health status at the time of enrollment in order to determine eligibility for chronic conditions, institutional, or dual-eligible SNPs. Alternatively, assignment rules could consider SNPs if a beneficiary or a person acting on the beneficiary’s behalf checks a box indicating they need an SNP.
This policy could increase regulatory responsibilities for CMS and SSA. It could require that CMS and SSA develop assignment methodologies to be used during enrollment. Should the assignment methodologies be based on quality and network capacity, CMS would need to monitor plans’ adherence to standards more closely. Using criteria that may be subject to legal challenge (e.g., Star ratings) also could increase the risk of litigation in the default assignment process. Increased legal risk and administrative oversight could involve more frequent and detailed evaluations of plan performance and network capacity, requiring additional resources.
Other options beyond automatic enrollment could potentially help streamline MA enrollment. For example, individuals eligible for Medicare could be notified up front about their coverage options and be required to indicate their enrollment choice before completing the enrollment process. For this option, individuals would be sent to the Medicare.gov plan compare tool and would have to indicate a choice of MA or traditional Medicare. This approach is similar to Paragon Health’s proposal to require an affirmative enrollment decision. Information about MA and traditional Medicare options would still be provided to the beneficiary before their initial enrollment period begins, but individuals would be asked whether they wish to enroll in MA or traditional Medicare. Beneficiaries who indicate they wish to enroll in MA would be provided with the option to enroll in a plan immediately and would be directed to the Medicare.gov plan compare tool to do so.
Another option would be to allow or encourage MA health plans to exercise “seamless enrollment.” Under a seamless enrollment option, an individual may be passively enrolled from their current health coverage into an MA plan offered by the same company at the time of their Medicare enrollment. Individuals would not need to make any decisions regarding their plan, as they would be automatically enrolled into one. Based on existing rules for seamless enrollment, MA plans would have to provide 60 days’ notice to individuals about their upcoming conversion and provide opportunities to opt out. Unlike default assignment, seamless enrollment would occur only for individuals already covered by an applicable plan before their 65th birthday.
Section 1851(c)(3) of the Social Security Act authorized seamless enrollment as part of the Balanced Budget Act of 1997, and CMS subsequently addressed it in rulemaking and subregulatory guidance. CMS required MA plans to submit proposals demonstrating compliance with certain requirements to use this enrollment option. Plans had to provide details on their process for identifying eligible individuals, provide written notice to each individual at least 60 days before the date of conversion, and provide individuals with an opportunity to contact the plan directly to opt out or decline this enrollment option. CMS temporarily suspended its acceptance of new proposals to participate in this enrollment option in 2016, and participation is now limited to dually eligible individuals enrolled in plans approved by CMS for seamless enrollment. To expand this option, CMS could begin accepting new proposals from MA health plans to seamlessly enroll Medicare-eligible individuals into MA plans.
Increasing MA enrollment compared to traditional Medicare could shift market dynamics between providers and insurers. In markets with few plan choices, the enrollment options outlined above may lead to more concentrated insurer markets, giving MA plans greater bargaining power in service price negotiation, potentially leading to lower provider payment rates. More concentrated insurer markets could put additional pressure on providers to more closely align with or be acquired by plans to maintain revenues.
In other markets, more enrollment across a wider range of plans could push providers to join more MA networks and increase providers’ administrative burden to manage different prior authorization requirements, Part D formularies, and specialty provider referrals. Providers would also need to contend with the change in care coordination requirements that comes with MA plans compared to traditional Medicare.
While streamlining the enrollment process could enhance usability and ease of navigation for beneficiaries, changes might also result in unintended consequences, particularly with regard to automatic enrollment. Seamless and default enrollment into MA raises the risk of individuals being unknowingly enrolled into a plan they do not wish to have or a plan that lacks the most appropriate benefits, provider networks, or cost sharing structure. Even with an opt-out opportunity, such policies would potentially raise a barrier to enrollment in traditional Medicare. Introducing default enrollment into MA would also affect other provisions of Medicare, including retiree coverage, Medigap enrollment, and eligibility for low-income programs, which would require additional policy considerations. Any such policy would likely include guardrails to protect beneficiaries.
At the same time, automatic enrollment could match beneficiaries with more appropriate plans if an enrollment algorithm did a better job of choosing than an individual could do on their own. As noted, beneficiaries often find the process of Medicare enrollment confusing and overwhelming, which can result in less optimal plan choices. If an enrollment system had accurate information about an individual’s health conditions, provider preferences, and eligibility for special programs, it could help beneficiaries identify the best plan options.
Automatic enrollment would likely substantially alter the competitive dynamics within the MA plan market. Policymakers would need to think carefully about the criteria that could potentially be used to determine plan eligibility to receive automatic enrollment, and the factors that would determine which plan an individual would be enrolled in. For example, would plans need to achieve or maintain a minimum quality rating to receive enrollment? How would differences in plan benefits, networks, or premiums factor in to automatic enrollment decisions? Would small and large plans have the same likelihood of receiving an automatic enrollment? Would CMS have sufficient updated information from MA plans on their network capacities?
Default enrollment could lead to substantive shifts in total enrollment and market share. Some plans could benefit from default enrollment if they receive more automatic enrollments than they might achieve in a consumer-driven market, while others could be disadvantaged by the redirection of enrollments they would have achieved based on desirable benefit offerings, low cost-sharing, or other competitive factors.
Research also has found that Medicare beneficiaries rarely change their coverage during the annual open enrollment period. Problems related to “sticky” enrollment might be exacerbated if individuals are automatically enrolled in plans that do not offer the most appropriate benefits, network providers, quality outcomes, or cost sharing for their specific health needs.
Implementing any of the options discussed above would require CMS and SSA to assume new regulatory duties, including enhanced interagency coordination, strengthened oversight to ensure regulatory compliance, and the development of additional programming to support information display and system functionality. These new and enhanced functions likely would require increased funding.
This is a lot of food for thought. Changing MA enrollment could have far-reaching effects, many of which are unclear. Additional questions remain regarding the implications of enrollment change:
These and other important questions would likely need to be examined if CMS moves forward with implementing any change to Medicare enrollment processes.
Until next week, this is Jeffrey (and Parashar, Lynn, and Olivia) saying, enjoy reading regs with your eggs.
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