Medicare Open Enrollment and Home Health: What to Check Before You Switch Plans

Open enrollment for 2027 runs October 15 to December 7. If your parent has home health now, or may need it soon, the plan they pick this fall decides who approves that care, which agencies they can use, and what they pay.

I'm an occupational therapist, and I've worked in home health. I've seen a January plan change catch a family off guard in the middle of therapy. This guide is about the decision and the calendar. For how a Medicare Advantage plan approves home health, its deadlines and appeals, read our guide to Medicare Advantage and home health.

Below, a rule means a federal regulation from 42 CFR. Guidance means a CMS manual or Medicare publication. Anything else is my own suggestion, and I'll say so.

The Dates That Matter

The rule and Medicare.gov name these windows differently. The fall window is the rule's annual coordinated election period: "Beginning in 2011, the annual coordinated election period for the following calendar year is October 15 through December 7" (42 CFR 422.62(a)(2)(iii)). During it, a person "may change his or her election from an MA plan to Original Medicare or to a different MA plan, or from Original Medicare to an MA plan" (422.62(a)(2)(iv)). The change takes effect "as of the first day of the following calendar year" (422.68(b)). Medicare's handbook adds the practical catch: "Your coverage starts on January 1 (as long as the plan gets your enrollment request by December 7)."

The January window is narrower. Someone in a Medicare Advantage plan "may make an election once during the first 3 months of the year to enroll in another MA plan or disenroll to obtain Original Medicare" (422.62(a)(3)(i)). That change starts on "the first day of the first calendar month following the month in which the election is made" (422.68(c)). Medicare & You 2027 lists what it does not allow: "During this period, you can't switch from Original Medicare to a Medicare Advantage Plan". And: "You can only make one change during this period".

Read the Annual Notice of Change First

If your parent is in a Medicare Advantage plan, the plan has already said what changes in January. A plan changing its rules must, "For changes that take effect on January 1, notify all enrollees at least 15 days before the beginning of the Annual Coordinated Election Period" (42 CFR 422.111(d)(2)). It comes as the Annual Notice of Change, which the plan "Must send for enrollee receipt no later than September 30 of each year" (42 CFR 422.2267(e)(3)(i)).

Medicare's handbook describes it: "Includes any changes in coverage, costs, and more that will be effective in January." It also says, "If you don't get these important documents, contact your plan."

The handbook says: "These rules can change each year. The plan must notify you about any changes before the start of the next enrollment year." Read this year's notice even if last year's plan worked fine.

For home health, I look for three things in it.

Approval before care. Medicare's handbook says that in a Medicare Advantage plan "You may need to get approval (prior authorization) from your plan before it covers certain services or supplies." Look for home health there. Each plan must also post on its website, by March 31, the previous year's "list of all items and services that require prior authorization" (42 CFR 422.122(c)(1)). That shows last year. For 2027, go by the notice and the Evidence of Coverage, and call the plan.

What home health costs. Under Original Medicare, the handbook says: "You pay nothing for covered home health services." A Medicare Advantage plan's in-network charge depends on which yearly out-of-pocket limit it picked. On two of the three, it "may not exceed the cost sharing required under original Medicare" (42 CFR 422.100(j)(1)(i)). On the lower limit, the rule allows up to this: "the cost sharing must not be greater than 20 percent coinsurance or an actuarially equivalent copayment" (42 CFR 422.100(j)(1)(i)(D)). Find the home health line in the notice and see whether it changed.

The network. The notice may not catch every network change. The handbook warns: "Providers can join or leave a plan's provider network any time during the year."

A Checklist Before You Switch

This section is my suggestion, not a rule. If your parent uses home health, or probably will, I'd get these answers before December 7.

1. Is the current agency in the new plan's network? Ask the agency's office and ask the plan. The handbook says "You can also contact your provider directly to find out if they're in network." In my experience the two answers don't always match.
2. Does the plan require approval for home health? If yes, ask the agency how long approval usually takes.
3. What does the plan charge per home health visit, in network and out? Get the number, not just a yes.
4. What is the yearly out-of-pocket limit? The handbook says Medicare Advantage plans "have a yearly limit on what you pay for covered Medicare services". Under Original Medicare, "There's no yearly limit on what you pay out of pocket, unless you have supplemental coverage". Home health is $0 there, but other care is not. See what patients pay under Original Medicare.
5. Are your parent's doctors in the network? Home health needs a doctor or other health care provider to order it.
6. Write down who you talked to, the date, and what they said.

If Your Parent Is on Home Health Right Now

Moving from Original Medicare into a Medicare Advantage plan

The new plan cannot simply stop care that's already going. A coordinated care plan (an HMO, PPO or other network plan, 42 CFR 422.4(a)(1)(iii)) must give "A minimum 90-day transition period for any active course(s) of treatment when an enrollee has enrolled in an MA plan after starting a course of treatment, even if the service is furnished by an out-of-network provider" (42 CFR 422.112(b)(8)(i)(B)). The same paragraph says "This includes enrollees new to a plan and enrollees new to Medicare". My reading: a move from one Medicare Advantage plan to another counts too.

On the agency's side, CMS's OASIS guidance manual says "Medicare does not require a new SOC when a patient's payer changes from Original Medicare (FFS) to a Medicare Advantage (MA) plan". SOC means start of care. My reading: once the 90 days are up, the plan's usual network and approval rules can apply, which is why checklist items 1 and 2 matter. If the plan then approves the care, that approval "must be valid for as long as medically necessary to avoid disruptions in care" (42 CFR 422.112(b)(8)(i)(A)).

Moving from a Medicare Advantage plan back to Original Medicare

The same manual, guidance for agencies rather than a regulation, says:

"When there is a pay source change from MA to Medicare FFS, while a new SOC OASIS is required the original eligibility for the home health benefit is uninterrupted."

In plain words, the agency does a new start-of-care assessment, but your parent's eligibility doesn't break because the payer changed. The manual also says "The agency does not have to re-admit the patient in the sense that it would normally admit a new patient with all the paperwork that entails." The manual does recommend that the agency discharge your parent from the old payer and reassess under the new one, so you may see discharge paperwork. My reading: that is about billing, not the end of care.

CMS's OASIS questions and answers add a caution: "In addition to OASIS completion, other regulatory and payer requirements may be affected by a payer source change."

My suggestion: if your parent's coverage changes January 1, call the agency in December. Tell them the date and the new coverage, and ask who will do the new assessment and when. Agencies handle this paperwork, but only if they know.

Medigap, if your parent is leaving Medicare Advantage

Medigap (Medicare Supplement Insurance) helps with Original Medicare's out-of-pocket costs, and buying it later isn't always possible. Medicare & You 2027 says "In certain situations, you may have rights to buy a Medigap policy (guaranteed issue rights) outside of your Medigap Open Enrollment Period." Two situations it describes:

• "If you drop a Medigap policy to join a Medicare Advantage Plan for the first time, you'll have a single 12-month period (your trial right period) to get your Medigap policy back if the same insurance company still sells it once you return to Original Medicare."
• "If you joined a Medicare Advantage Plan when you were first eligible for Medicare Part A at 65, you can buy certain Medigap policies sold by an insurance company in your state if you switch to Original Medicare within the first year of joining the Medicare Advantage Plan."

The handbook also says: "Most Medigap policies don't automatically cancel when you join a Medicare Advantage Plan." And "it's illegal for anyone to sell you a Medigap policy unless you're switching back to Original Medicare."

Where to Get Help

• Your State Health Insurance Assistance Program (SHIP). Medicare.gov says "SHIPs aren't connected to any insurance company or health plan." Find your state's program at shiphelp.org ("Find Your Local SHIP"). Medicare & You lists each state's SHIP phone number in "Find helpful contacts".
• 1-800-MEDICARE (1-800-633-4227). TTY users can call 1-877-486-2048. Medicare.gov says you can talk with a real person "24 hours a day, 7 days a week (except some federal holidays.)"
• Medicare's plan comparison tool at Medicare.gov/plan-compare, to see the plans in your parent's area and their costs.

My suggestion: bring the Annual Notice of Change and this checklist to the SHIP appointment.

Frequently asked questions

When is Medicare open enrollment for 2027 coverage?

October 15 to December 7, 2026. A change made then starts January 1, 2027, as long as the plan gets the request by December 7. If your parent is in a Medicare Advantage plan on January 1, there is a second window from January 1 to March 31 to switch plans or go back to Original Medicare, once.

What is the Annual Notice of Change?

It is the letter a Medicare Advantage plan sends its members each fall listing what changes in January: coverage, costs and more. The plan must send it for members to receive by September 30. If your parent didn't get one, call the plan.

If my parent switches plans while on home health, does the care stop?

Not automatically. If your parent joins a Medicare Advantage HMO, PPO or other network plan (the rule calls these coordinated care plans) in the middle of home health, the federal rule gives at least 90 days without the plan disrupting the care or asking for a new approval. If your parent leaves a Medicare Advantage plan for Original Medicare, CMS guidance says the agency does a new start-of-care assessment, but your parent's eligibility for home health is uninterrupted.

Can my parent get a Medigap policy back after leaving Medicare Advantage?

Sometimes. Medicare's handbook describes a 12-month trial right for people who dropped Medigap to join a Medicare Advantage plan for the first time, and a first-year right for people who joined one when they were first eligible for Medicare at 65. Outside those situations it may not be possible, so talk to your State Health Insurance Assistance Program before dropping anything.

Sources

• 42 CFR §422.62, Election of coverage under an MA plan (Cornell LII)
• 42 CFR §422.68, Effective dates of coverage and change of coverage (Cornell LII)
• 42 CFR §422.111, Disclosure requirements (Cornell LII)
• 42 CFR §422.2267, Required materials and content (Cornell LII)
• 42 CFR §422.122, Prior authorization requirements (Cornell LII)
• 42 CFR §422.100, General requirements (Cornell LII)
• 42 CFR §422.112, Access to services (Cornell LII)
• 42 CFR §422.4, Types of MA plans (Cornell LII)
• Medicare & You 2027 (Medicare.gov)
• Joining a plan (Medicare.gov)
• Talk to someone (Medicare.gov)
• OASIS-E2 Guidance Manual, Chapter 1, section 1.5.2.3, Changes in Payer Source (CMS)
• CMS OASIS Q&As, Category 2, Q35.1 (CMS)
• State Health Insurance Assistance Programs (shiphelp.org)