Medicare Advantage Special Needs Plans Reach 21% Enrollment Amid Market Shifts

Enrollment in Special Needs Plans (SNPs) within the Medicare Advantage (MA) program has increased significantly, now representing 21% of all MA enrollees, up from 13% in 2018. This growth has expanded the SNP beneficiary population from 2.6 million to 7.3 million, accounting for nearly half of the overall Medicare Advantage enrollment increase during this period.

The SNP category includes three types: dual eligible SNPs (D-SNPs) for individuals with both Medicare and Medicaid, chronic condition SNPs (C-SNPs) for those with specified chronic illnesses, and institutional SNPs (I-SNPs) for beneficiaries requiring institutional care. From 2018 to 2024, D-SNPs drove most of the expansion, growing from 2.2 million to 5.8 million enrollees and constituting over 90% of SNP growth.

However, between 2024 and 2025, C-SNPs led enrollment growth, increasing by 476,300 new enrollees — three times the increase seen in D-SNPs. This shift aligns with regulatory changes mandating greater integration between Medicare and Medicaid for D-SNPs, whereas C-SNPs face no such requirements. These evolving regulations have influenced market dynamics among SNP types.

The SNP market is concentrated, with for-profit insurers dominating enrollment. UnitedHealth Group and Humana collectively hold over 54% of total SNP enrollment, and UHG alone covers half of all C-SNP enrollees. Nonprofit insurers administer only 14% of SNP plans, reflecting a largely concentrated payer/provider landscape.

Despite growth in SNPs, the overall Medicare Advantage market is experiencing slowed expansion, impacted by declining payment rates, increased medical costs, regulatory pressures, and lower star ratings. Several insurers are scaling back or exiting markets, resulting in fewer Medicare Advantage plans available nationally and signaling potential shifts in competitive dynamics.

This trend highlights the significance of regulatory frameworks and payer strategies in shaping Medicare Advantage submarkets, notably within special needs populations. Stakeholders should monitor SNP enrollment shifts and the broader Medicare Advantage environment for compliance, risk management, and strategic planning purposes.