10.6 Million Medicare Advantage Members Are in Plans Rated Below 4 Stars. How Many Are in Your Book?

Pulling the CMS 2026 plan landscape through our data pipeline and matching every Medicare Advantage plan's overall star rating to its March 2026 enrollment, the split is stark: 18.3 million members sit in plans rated 4 stars or better, while just over 10.6 million members, 36.7% of everyone in a rated plan, sit below 4 stars. That second group is not an abstraction. It is spread across the books of every independent agent in the country, and it is exactly the group most likely to hear about their plan's rating from an AI assistant, a competitor, or a carrier mailer before they hear it from you.

Where the 2026 star ratings actually landed

CMS publishes an overall star rating, 1 to 5 stars in half-star steps, for every Medicare Advantage contract with enough data to be measured.¹ Joining those ratings to the plans in the CMS 2026 landscape file and to CMS monthly enrollment for March 2026 gives you the picture below.²

Three things jump out of that table. First, the biggest single bucket by plan count is not the 4.5-star tier the carrier ads celebrate. It is 3.5 stars: 1,383 plans carrying roughly 8.3 million members. Second, quality is concentrated at the top: barely 195 plans, offered by 11 parent organizations across 20 states, earned a 5.0 overall rating for 2026. Third, the bottom is small but real: about 144,000 people are enrolled in plans rated 2.5 stars or lower, the range where CMS historically applies its low-performing warning to contracts that stay there year after year.¹

A scope note so the numbers stay honest. CMS assigns the overall star rating at the contract level, and every plan sold under a contract carries that contract’s rating, so the plan counts above are plans available for sale matched to their contract’s 2026 overall rating. This analysis covers Medicare Advantage plans that received a 2026 overall rating. Standalone Part D drug plans are rated separately under the Part D summary rating, and plans that are too new or lack enough data are excluded by CMS. Enrollment counts come from the CMS March 2026 monthly enrollment file, which suppresses plans with ten or fewer enrollees.²

The trend behind the table matters as much as the table. Table 1 of the CMS 2026 Star Ratings Fact Sheet shows the enrollment-weighted average overall rating for MA-PD contracts sliding from 4.14 in 2023 to 4.07 in 2024, 3.95 in 2025, and 3.98 in 2026.¹ The top hollowed out fastest: 57 contracts held 5 stars in 2023, just 9 held it in 2025, and 2026 recovers only to 18. Meanwhile the 3.5-star share of rated contracts climbed from about 23% in 2023 to about 34% in 2026. Quality did not gently drift; it compressed toward the middle.

Part of the mechanism is structural: CMS recalculates measure cut points every year from that year’s actual performance, so a contract can run the same operation and still slide as the field improves around it. That is exactly why a book that was fine three years ago needs a fresh look now.¹ As a cross-check on our plan-level join, CMS reports approximately 64% of MA-PD enrollees in contracts at 4 or more stars for 2026, in line with the 63.3% our enrollment match produces.¹

What a below-4-star plan means for the client sitting in it

Star ratings are not a vanity metric. Per the CMS fact sheet, the 2026 ratings are built from a maximum of 45 measures across up to 9 domains, covering outcomes like managing chronic conditions, member complaints, call center performance, and how often members leave the plan.¹ A plan sitting at 3 or 3.5 stars is, by CMS's own scoring, middling on the things your client actually feels: how hard it is to get an appointment authorized, how the plan handles an appeal, whether the drug coverage works at the pharmacy counter.

The rating also shapes the plan's economics. Contracts at 4 stars or better qualify for quality bonus payments, money that flows back into richer benefits, and 5-star contracts get the marketing advantage of year-round enrollment. Plans stuck below 4 stars have less bonus revenue to spend on benefits, which is one reason below-4-star plans so often pair with benefit trims at renewal.

The client does not experience a star rating. They experience the denied prior authorization, the pharmacy surprise, and the benefit that quietly disappeared in the Annual Notice of Change. The rating just predicts how often that happens.

None of this means every below-4-star plan is the wrong plan. A 3.5-star plan with the right network and the right formulary can absolutely be the best fit for a specific client, and plenty of 3.5-star plans are on their way up, not down. The point is different: you should know which of your clients are in that 10.6 million, and they should hear what it means from you. An unexamined book is where retention problems incubate.

The 5-star enrollment window that is open right now

Here is the part that makes this a July conversation instead of an October one. Medicare's 5-star special enrollment period lets a beneficiary who lives in the service area of a 5-star Medicare Advantage plan, Medicare cost plan, or Medicare drug plan switch into that 5-star plan once between December 8 and November 30 of the following year.³ In other words, for clients with a 5.0-star plan available where they live, the switch window is open today, and it stays open until November 30.

In our join of the CY2026 landscape file, the footprint is real but narrow: 195 plans with a 5.0 overall rating for 2026, offered by 11 parent organizations, reachable in parts of 20 states and 565 counties. If you work a market inside that footprint, the 5-star SEP is the single most underused move in your toolkit, because most agents treat enrollment as an AEP-only sport. Two cautions belong in every 5-star conversation. First, a member can only use the SEP once per period, so the move has to be the right one.

Second, drug coverage. If a client moves from a Medicare Advantage plan with drug coverage into a 5-star plan without it, they can lose drug coverage and face a Part D late enrollment penalty later, so the fit check still comes first.³

Outside the 5-star footprint the same review still pays, it just pays in October. AEP runs October 15 to December 7, and the agents who walk into it with a pre-tiered book, already knowing who is in a 3-star plan with a shrinking benefit, run circles around the agents who start sorting on October 14.

The 5-step star review for your book of business

This is the same review we run for agencies inside Digital Foundation, and you can run it manually in an afternoon.

Step 1: Export your book with plan identifiers

Pull every active client from your CRM or carrier portals with their contract number and plan ID, the H-number and plan combination on their member card. If your CRM cannot produce that in one export, that is a data problem worth fixing this week, because every downstream automation depends on it. Our take on cleaning a stale CRM is the database reactivation playbook.

Step 2: Match every client to their plan's 2026 overall rating

CMS publishes the full star ratings data on its Part C and D performance data page, free.¹ Match on contract number. An hour with a spreadsheet lookup, or a data pipeline like ours if you want it continuous, and every client in your book has a star rating next to their name.

Step 3: Tier the book into four segments

• Segment A: 2.5 stars or lower. The small group in officially struggling contracts. Called first. If a contract has been rated below 3 stars for three years running, CMS notifies those members directly and gives them a special option to switch by contacting Medicare, which means a letter from CMS can reach your client before your call does.³
• Segment B: 3.0 and 3.5 stars. The big middle, roughly 10.5 million people nationally. Reviewed for fit before AEP, prioritized by plans that also trimmed benefits at the last renewal.
• Segment C: 4.0 stars and up. A reassurance touch that confirms the plan still fits and doubles as a review-request opportunity while the news is good.
• Segment D: inside a 5-star service area. Overlay of any segment. Flagged for a possible 5-star SEP conversation right now instead of in October.

Step 4: Make it a service call, not a pitch

The call is simple and compliant when it is framed as service to your existing client: CMS published new quality ratings for your plan, here is what changed, here is what it means for you, and here is when it makes sense to look at alternatives. Document the conversation. If the answer is that the current plan still fits, that documented review is itself retention gold.

Step 5: Publish what you know

The same analysis that protects your book wins you new clients when it lives on your website. A county-level page explaining which plans in your market earned what rating for 2026, updated when CMS updates, anchored to named CMS data, is precisely the content AI engines cite. That is the heart of Answer Engine Optimization, and it is why the agencies doing this work show up in AI answers while their competitors argue about Google rankings.

Your clients are already asking AI about their plan

Star ratings are the single easiest Medicare data point for an AI assistant to retrieve and repeat. Ask ChatGPT or Google's AI about almost any Medicare Advantage plan by name and the overall star rating shows up in the first paragraph of the answer, because it is structured, public, and unambiguous. We walked through the mechanics of that shift in the Medicare choice overload report: overwhelmed seniors are delegating plan questions to AI, and AI answers lead with quality ratings.

Play that forward for the 10.6 million people in below-4-star plans. Some meaningful share of them, or their adult children, will type the plan name into an AI tool this year and read a sentence like: this plan received 3 out of 5 stars from Medicare for 2026. The next question is automatic: should I switch, and to what? The only open variable is who answers it, you, a call center, or whatever agency the AI happens to cite. Being the agent who already called beats being the agent who gets called about it. Being the agency the AI cites is a book-protection strategy, not a marketing vanity project.

How to do the outreach without a TPMO problem

Everything in this playbook is doable inside CMS marketing rules, but the rules are real. Under CMS's marketing and communications regulation, plan-comparison conversations with beneficiaries carry real requirements when they cross from service into marketing. The working rules:

• The TPMO disclaimer on marketing materials and marketing calls where it applies.
• A documented scope of appointment before a personal marketing appointment, generally at least 48 hours in advance, with limited exceptions.
• Call recording for marketing calls with beneficiaries where required.
• No endorsement claims. Never present a star rating as a CMS endorsement of you or your agency, and never disparage a specific plan beyond what the published data says.
• Needs first. The client's documented needs assessment, not the rating alone, is the basis for any switch.

Servicing your existing client relationship, reviewing the plan they already have, and documenting fit is the safe center of the fairway. When in doubt, your FMO's compliance desk sees these questions weekly. And keep your own website's tracking stack clean while you are at it, because HIPAA compliant tracking is now table stakes for anyone marketing health products online.

The 2026 star ratings are published, public, and sitting next to 10.6 million members who mostly have not read them. Your book review is either on your calendar for this month or it is happening informally in an AI chat window without you. If you want to see how visible your agency is to the AI engines your clients are already using, the free Audit takes about a minute.