KFF: Enrollment in Medicare Advantage special needs plans on the rise

Special needs plans (SNPs) enrollment is rising and now accounts for 21% of all MA enrollees.

According to a new KFF report, that's up from 13% in 2018, when SNPs became a permanent fixture in the Medicare Advantage program. It's enough to account for 7.3 million beneficiaries, up from 2.6 million over that time.

Growth in SNPs comprised nearly half (48%) of the total increase in Medicare Advantage enrollment in that window, according to the data.

WHAT'S THE IMPACT

The report examined three types of SNPs: dual eligible SNPs (D-SNPs), which are limited to people with both Medicare and Medicaid; chronic condition SNPs (C-SNPs), which are limited to people with certain chronic conditions; and institutional SNPs (I-SNPs), which are limited to people who require an institutional level of care.

Through 2024, growth in SNPs was driven by an increase in enrollment in D-SNPs, which grew from 2.2 million enrollees in 2018 to 5.8 million enrollees in 2024, comprising more than 90% of SNP enrollment growth over that time, the report found.

C-SNPs comprised 75% of total SNP enrollment growth between 2024 and 2025. That's in contrast to prior years, where enrollment growth was mainly in D-SNPs. In 2025, C-SNP enrollment increased by 476,300 new enrollees, triple the increase in D-SNP enrollment.

These changes in special needs plans arise from changing regulations that govern each of the three different SNP types, researchers said.

“The acceleration of C-SNP enrollment growth and slowing of D-SNP enrollment growth coincided with implementation of new rules for D-SNPs requiring greater integration between Medicare and Medicaid,” they wrote. “C-SNPs are not required to have a similar level of integration.”

A small share of SNP enrollees – just 14% – are in plans administered by nonprofit insurers, found KFF. 

SNP enrollment is highly concentrated among a small number of large national carriers, with UnitedHealth Group and Humana plans comprising more than half (54%) of total SNP enrollment, while UHG accounts for half of all C-SNP enrollees, said KFF.

THE LARGER TREND

While SNP enrollment is on the rise, the 2025 Medicare Advantage competitive enrollment report released in March by healthcare advisory firm Chartis and consulting firm HealthScape Advisors showed overall decelerating growth for Medicare Advantage plans. 

MA plans have faced recent headwinds of declining payment rates, medical cost pressures, regulatory burden and less favorable star ratings.

Several plans exited the market, including Premera and Blue Cross Blue Shield Kansas City, and others reduced their service areas, such as Aetna and Humana, according to the report. Prior to the annual enrollment period, many for-profit health plans signaled their intent to slow growth or even contract membership due to the pressures. This has resulted in a flattening of MA plans available nationally, the report said.