2025 Maximum Broker Commissions for Medicare Advantage & Medicare Part D

The Centers for Medicare & Medicaid Services (CMS) have updated the 2025 Medicare Advantage and Part D broker commissions following recent lawsuits concerning the 2025 Medicare Final Rule. These updates, issued on July 18, 2024, replace the initial figures from the June 28, 2024 memo.

Key Updates on 2025 Medicare Broker Commissions

Broker commissions will increase for the tenth consecutive year. However, the 2025 Medicare increases now exclude a fixed administrative fee. CMS will also reinstate the regulatory framework [42 C.F.R. 422.2274(e)], permitting payments for services other than enrollment, such as training, customer service, agent recruitment, operational overhead, or assistance with health risk assessments, until the lawsuits are resolved.

Carriers will continue to pay 2025 Medicare commissions at or below the maximum amounts set by CMS, similar to previous years. These commissions may vary from carrier to carrier and plan to plan.

Medicare Part D Commissions

Under CMS rules for Medicare Part D in 2025:

  • Initial commissions will rise from $100/member/year to $109/member/year, a 9% increase year-over-year.
  • Renewal commissions will increase from $50/member/year to $55/member/year, a 10% increase year-over-year.

The previously stated one-time administrative increases of $100 for initial enrollments and $50 for renewals have been removed by CMS.

Medicare Advantage Commissions

The 2025 Medicare Advantage commissions vary by state/region:

  • CT, PA, and DC: Initial commissions will increase from $689/member/year to $705/member/year (2.32% increase). Renewal commissions will increase from $345/member/year to $353/member/year (2.32% increase).
  • CA and NJ: Initial commissions will rise from $762/member/year to $780/member/year (2.36% increase). Renewal commissions will rise from $381/member/year to $390/member/year (2.36% increase).
  • Puerto Rico and the U.S. Virgin Islands: Initial commissions will increase from $418/member/year to $428/member/year (2.39% increase). Renewal commissions will increase from $209/member/year to $214/member/year (2.39% increase).
  • All other states: Initial commissions will increase from $611/member/year to $626/member/year (2.45% increase). Renewal commissions will increase from $306/member/year to $313/member/year (2.29% increase).

CMS has removed the previously stated one-time administrative increases of $100 for initial enrollments and $50 for renewals.

MA & PDP Maximum Broker Compensation for 2025

  Initial Renewal
Product Region 2024 2025 %  2024 2025 % 
MAPD National $611 $626 2.45% $306 $313 2.29%
CT, PA, DC $689 $705 2.32% $345 $353 2.32%
CA, NJ $762 $780 2.36% $381 $390 2.36%
Puerto Rico, U.S. Virgin Islands $418 $428 2.39% $209 $214 2.39%
PDP National $100 $109 9% $50 $55 10%

CMS Final Rule 2025 Agent Compensation Changes Update

The 2025 Medicare Advantage & Part D Final Rule included significant changes to Medicare agent compensation. Many in the industry anticipated standardized commissions and a cap on agent/broker non-salary compensation. However, a federal judge in Texas granted a stay on July 3, 2024, in the lawsuits filed by Americans for Beneficiary Choice (ABC) and Council for Medicare Choice (CMC) against the Department of Health and Human Services (HHS).

Currently, the implementation of CMS’ 2025 commission changes is on hold pending the court’s decision. The lawsuits will determine if these changes, which include eliminating separate administrative fees, setting fixed commission amounts, capping non-salary compensation, and prohibiting enrollment incentives that may bias agent recommendations, exceed CMS’ statutory authority or were implemented properly. A final court outcome is expected in 2025 or 2026.

Conclusion

The ongoing litigation and updates make understanding Medicare commissions complex. However, as long as the court-ordered stay is in place, the current commission structure and opportunities are expected to remain unchanged.

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