HEALTH POLICY TYPES · 6 MIN READ
Medicare Advantage, Medigap, and Coordination of Payers
Medicare Advantage (Part C) plans deliver Medicare benefits through private plans paid by CMS. The product shelf mirrors commercial managed care — HMO, HMO-POS, PPO, private fee-for-service (PFFS), and medical savings account (MSA) designs — and plans may bundle Part D drug coverage (MA-PD) or not (MA-only). Every MA plan must cap enrollee spending with an in-network maximum out-of-pocket (MOOP), with a higher combined limit for out-of-network use in PPO designs. Special Needs Plans (SNPs) restrict enrollment to defined populations: C-SNPs for beneficiaries with one or more severe or disabling chronic conditions on the CMS-approved list (verified by physician attestation), D-SNPs for dual-eligibles who hold both Medicare and Medicaid, and I-SNPs for institutionalized beneficiaries. CMS steers the MA market through quality and payment machinery. Plans bid against a county benchmark; bids below benchmark generate rebates that fund supplemental benefits. Payments are risk-adjusted by enrollee health status using diagnosis-driven risk scores. The Star Rating system (1 to 5 stars) scores each contract on clinical quality, member experience, and drug measures: 5-star plans earn a year-round special enrollment period, 4-plus-star plans earn quality bonus payments, and a contract rated below 3 stars for three consecutive years can be terminated by CMS and is flagged as low-performing. Beneficiaries who delay Part D creditable drug coverage face a late enrollment penalty, and special enrollment periods open on qualifying events such as moving or losing coverage. Original Medicare enrollees instead buy Medicare Supplement (Medigap) policies — federally standardized plan letters such as A, F, G, and N — to fill cost-sharing gaps, with guaranteed-issue rights protecting applicants in defined situations from underwriting. Finally, coordination rules decide who pays first: under the Medicare Secondary Payer working-aged rule, an employer group plan pays primary for a working 65-plus employee only when the employer has 20 or more employees; below 20, Medicare is primary and the group plan is secondary — and employers may not offer incentives to push workers onto Medicare. Parallel coordination rules govern veterans' programs and Indian Health Service care, and Medicaid remains the payer of last resort after spend-down.
Key rules
C-SNP enrollment requires a CMS-listed severe or disabling chronic condition.
Conditions such as diabetes, chronic heart failure, ESRD, dementia, and HIV/AIDS qualify, verified by physician attestation with CMS post-enrollment validation; D-SNPs serve dual-eligibles and I-SNPs serve institutionalized members.
Why the exam cares: Matching each SNP type to its population is a standard Medicare Advantage question.
Star Ratings drive enrollment rights, bonuses, and contract termination.
Ratings run 1-5 stars: 5-star plans get year-round special enrollment, 4+ stars earn quality bonus payments, and below 3 stars for three consecutive years exposes the contract to CMS termination.
Why the exam cares: The three-consecutive-year termination consequence is the specific regulatory fact examiners test.
Every MA plan must have a maximum out-of-pocket limit; PPOs add a combined cap.
The in-network MOOP caps enrollee cost-sharing; out-of-network use in PPO designs counts toward a higher combined limit.
Why the exam cares: MOOP structure separates MA from Original Medicare, which has no out-of-pocket cap on its own.
Under 20 employees, Medicare pays primary for a working 65+ employee.
The working-aged Medicare Secondary Payer rule makes the group plan primary only for employers with 20 or more employees; smaller-employer plans pay secondary, and incentivizing Medicare enrollment over the group plan is prohibited.
Why the exam cares: The 20-employee threshold, and which payer is primary on each side of it, is the classic coordination question.
Medigap plans are standardized by letter; guaranteed-issue rights limit underwriting.
Plans A, F, G, and N deliver identical benefits from any carrier selling the letter; in guaranteed-issue situations the insurer must accept the applicant without medical underwriting.
Why the exam cares: Standardization means questions test letters and rights, not carrier-specific benefits.
Numbers to memorize
- Fewer than 20 employees — employer size at which Medicare becomes primary for working aged 65+
- Below 3 stars for 3 consecutive years — Star Rating level exposing an MA contract to CMS termination
- 5 stars — rating earning a plan year-round special enrollment eligibility
- 1–5 stars (half-star increments) — CMS Star Rating scale for MA and MA-PD contracts
Common traps
- Reversing the working-aged rule — the group plan is primary at 20+ employees; Medicare is primary below 20, not the other way around.
- Assuming any chronically ill beneficiary can join a C-SNP — the condition must be on the CMS-approved list and physician-attested; dual-eligibility instead points to a D-SNP.
- Confusing MA-PD with MA-only plans — only MA-PD bundles Part D drug coverage; separate drug decisions carry late-enrollment-penalty risk.
- Treating Medigap as an alternative to Medicare Advantage that can be stacked — Medigap supplements Original Medicare cost-sharing and does not pair with an MA plan.
For coordination questions, line up the payers and ask who is primary first — employer size, dual-eligibility, or program rules decide it — before touching what the secondary payer owes.
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