3.2 Arizona Medicare Supplement (Medigap) Regulations

Medicare Supplement (Medigap) policies fill the "gaps" in Original Medicare (Parts A and B) — deductibles, coinsurance, and copays. Arizona follows the federal NAIC Medigap framework with standardized plans and a guaranteed open-enrollment window. Given Arizona's large retiree population, this is a heavily tested topic.

Standardized Medigap plans

Medigap plans are standardized by letter (A, B, C, D, F, G, K, L, M, N). Within a given letter, benefits are identical across insurers — only price and service differ. Insurers must offer Plan A if they sell any Medigap, and must offer Plan C or F (where available) or Plan D or G to applicants who qualify.

Exam Tip: Plans C and F cover the Part B deductible, so they are closed to people who became Medicare-eligible on or after January 1, 2020. Newly eligible beneficiaries commonly choose Plan G instead.

Six-month open enrollment

Arizona follows the federal 6-month Medigap open enrollment period, which begins on the first day of the month in which the applicant is both age 65 or older AND enrolled in Medicare Part B. During this window:

• Guaranteed issue — the insurer must accept the applicant regardless of health.
• No medical underwriting — health questions cannot raise the rate or deny coverage.
• No pre-existing-condition exclusion (if the applicant had prior creditable coverage; otherwise a limited look-back may apply).
• The applicant may buy any Medigap plan the insurer offers.

Guaranteed-issue rights outside open enrollment

Beyond the one-time open enrollment, federal/Arizona rules grant guaranteed-issue rights in specific situations, generally requiring application within 63 days of losing coverage:

No Arizona "Birthday Rule"

Unlike California, Oregon, and a few others, Arizona does NOT have a Birthday Rule that lets beneficiaries change Medigap plans each year without underwriting. In Arizona, after the open-enrollment window closes, switching Medigap plans (outside a guaranteed-issue event) generally requires medical underwriting — meaning the insurer can ask health questions, charge more, or deny coverage.

Exam Tip: If a question describes an Arizona beneficiary wanting to switch Medigap plans annually with no health questions, the answer is that Arizona has no Birthday Rule — underwriting applies unless a guaranteed-issue event exists.

Rating methods and pre-existing conditions

Medigap premiums may be set three ways:

Pre-existing conditions: During open enrollment, no exclusion applies if the applicant had prior creditable coverage. Outside that protection, an insurer may impose up to a 6-month waiting period for conditions treated within the 6 months before coverage began; prior creditable coverage reduces or eliminates that waiting period.

Medigap vs. Medicare Advantage — a critical distinction

Producers must never confuse the two. Medigap supplements Original Medicare: the beneficiary keeps Parts A and B, sees any Medicare-accepting provider, and the Medigap policy pays the gaps. Medicare Advantage (Part C) replaces Original Medicare with a private plan that usually has networks, may include drug coverage, and follows different enrollment rules. You cannot have both a Medigap policy and a Medicare Advantage plan paying simultaneously — selling a Medigap policy to someone in Medicare Advantage who does not need it (and cannot use it) is improper.

Marketing rules and senior protection

Federal and Arizona rules restrict Medigap marketing to prevent abuse of seniors. Prohibited or restricted practices include high-pressure tactics, cold-lead cards disguised as government mailings, selling duplicate coverage, and misrepresenting a plan as government-endorsed. Producers must determine whether the applicant already has adequate coverage before selling.

Outline of coverage and delivery

At or before application, the producer must deliver an Outline of Coverage summarizing the plan's benefits, and the policy must be delivered promptly. The 30-day free look that applies to Medigap lets the buyer return the policy for a full refund — a key consumer protection given how often seniors are solicited.

Exam Tip: A Medigap policy and a Medicare Advantage plan cannot pay at the same time. Selling Medigap to a current Medicare Advantage enrollee who will keep that plan is an improper duplicate sale.