3.2 Massachusetts Medicare Supplement (Medigap) Regulations

A Waiver State With Its Own Plans

Most states standardize Medigap into lettered Plans A through N under federal rules. Massachusetts is one of only three waiver states (the others are Minnesota and Wisconsin) that pre-dated and were grandfathered around the 1990 federal standardization. So Massachusetts uses its own three plan designs:

A key recency point: because Supplement 1 pays the Part B deductible, federal law (MACRA) closed it to people who became newly eligible for Medicare on or after January 1, 2020. Newly eligible beneficiaries choose Core or Supplement 1A; those eligible before 2020 may keep or buy Supplement 1.

IMPORTANT: Massachusetts does NOT use Plans A-N. If an answer choice lists Plan F, Plan G, or Plan N for a Massachusetts resident, it is wrong. The only correct plan names are Core, Supplement 1, and Supplement 1A.

Worked example

A 67-year-old who turned 65 in 2018 wants the most complete coverage. She may purchase Supplement 1, which pays both the Part A and Part B deductibles. Her neighbor, who became Medicare-eligible in 2023, cannot buy Supplement 1 and would instead choose Supplement 1A (no Part B deductible) or Core.

Reading the benefit grid

The quickest way to keep the three plans straight on the exam is to anchor on the Part B deductible, which is the dividing line:

• Core pays neither the Part A nor the Part B deductible (lowest premium).
• Supplement 1A pays the Part A deductible and skilled nursing coinsurance but NOT the Part B deductible.
• Supplement 1 pays everything, including the Part B deductible (highest premium), and is closed to those newly eligible on or after January 1, 2020.

All three plans cover the same baseline: Part A and Part B coinsurance, the first three pints of blood, Part A hospice coinsurance, and 365 lifetime extra hospital days after Medicare's days run out. The differences are at the deductible and skilled-nursing level, so an exam question that hinges on "which plan pays the Part B deductible" is really asking you to identify Supplement 1.

Community Rating and Continuous Open Enrollment

Massachusetts requires community rating for Medigap. Every applicant for the same plan pays the same base premium regardless of age, gender, or health. Compare this to the rest of the country:

Continuous open enrollment

Massachusetts guarantees continuous open enrollment. A beneficiary may apply for or switch among Core, Supplement 1 (if eligible), and Supplement 1A at any time of year with:

• No health questions and no medical underwriting
• No pre-existing condition waiting periods
• Guaranteed issue year-round

This is far more generous than the federal baseline, where guaranteed-issue protection is generally limited to the six-month Medigap open-enrollment period that starts when the insured is 65 and enrolled in Part B, plus specific guaranteed-issue trigger events.

2026 premium reality

Because Supplement 1 is the richest plan, it is also the most expensive. For example, one carrier's 2026 monthly rates illustrate the spread: Core near $143, Supplement 1A near $233, and Supplement 1 near $289. Premiums differ by carrier, but the ranking (Core < Supplement 1A < Supplement 1) is the testable concept.

What Producers Must Communicate

Producers must explain that Massachusetts Medigap is unique: only three plans, community rating, continuous open enrollment, and the 2020 Supplement 1 eligibility cutoff. A common trap pairs Massachusetts with a six-month open-enrollment window; in Massachusetts enrollment is continuous.

Exam Tip: Memorize the three-state waiver group (Massachusetts, Minnesota, Wisconsin) and the three MA plans. Community rating = same premium for everyone; continuous open enrollment = switch anytime with no underwriting.

Medigap vs. Medicare Advantage and Replacement

Producers must also distinguish Medigap (supplements Original Medicare and pays cost-sharing) from Medicare Advantage (Part C, a private plan that replaces Original Medicare with a network). A consumer cannot use a Medigap policy to pay Medicare Advantage cost-sharing; pairing the two is prohibited and is a common compliance error.

When replacing one Medigap policy with another, Massachusetts producers must follow replacement rules: deliver a replacement notice, avoid leaving the client with a coverage gap, and never misrepresent that the new plan is required. Because Massachusetts uses continuous open enrollment with no underwriting, replacement is straightforward, but the producer still owes the client a suitability analysis comparing benefits and premiums across Core, Supplement 1, and Supplement 1A.

Scenario: A client on Supplement 1 complains about the premium. The producer may move her to Core or Supplement 1A at any time with no health questions, but should document that she understands she would lose the Part B deductible coverage. Telling her she must answer health questions first would be a false statement under Massachusetts rules.