As enrollment in Medicare Advantage (MA) plans continues to grow, so does the number of Medicare beneficiaries who are enrolled in Special Needs Plans (SNPs). More than 6.6 million Americans were enrolled in SNPs in 2024 – more than double the enrollment of 2019. In Arizona, SNP enrollees comprised 34% of the total Medicare Advantage enrollees in 2024.
Of the 6.6 million SNP enrollees, 88% were individuals eligible for both Medicare and Medicaid and enrolled in D-SNPs. Another 10% were enrolled in C-SNPs for people with chronic illnesses, with the remaining 2% enrolled in I-SNP plans for institutionalized care.
Increasing enrollment in these plans – as well as changes to enrollment periods – create opportunities for agents to educate their clients and adapt their portfolios to include plans that will meet their clients’ needs.
D-SNP Enrollment and SEP Changes for 2025
As enrollment in D-SNPs increase, CMS wants to improve care coordination and reduce costs by having dual eligible individuals receive their Medicare and Medicaid benefits from the same plan or organization. This will reduce fragmentation of care and simplify the process for enrollees who often must contend with different coverage rules and provider networks.
These qualifying D-SNPs fall into three categories: fully-integrated, highly-integrated, and applicable-integrated. Some types of plans are unavailable in some states. What is not included is look-alike D-SNPs, which are MA plans designed to attract dual-eligible beneficiaries but do not provide coordination between Medicare and Medicaid.
Over the next several years, CMS will begin reducing the enrollment threshold for look-alike D-SNPs, forcing carriers to transition enrollees into integrated D-SNPs or $0 premium plans. Agents should reach out to their carriers to find out what type of D-SNPs they offer.
In 2025, two separate SEPs replace the quarterly SEP for dual-eligible individuals and LIS recipients:
- Revised monthly SEP to enroll in a stand-alone PDP.
- Monthly enrollment for those eligible for Medicare and full Medicaid benefits to enroll in an integrated D-SNP plan. This is intended to give dual-eligible beneficiaries who are not enrolled in an integrated D-SNP more opportunities to do so.
It’s important to note that each state administers its own Medicaid programs, meaning rules and regulations vary. States differ in regard to what type of D-SNP plans they offer as well as how often they allow Medicaid recipients to switch plans. You need to be aware of the regulations in the state(s) where you are licensed. For example, in most cases, Arizona only allows changes once per year on the Medicaid recipient’s annual re-enrollment date. This means the dual-eligible clients in this state cannot use the monthly SEP. Other than using their annual re-enrollment date, they will have to wait for AEP to change plans. Medicare agents should educate their dual-eligible clients on these changes.
Potential Changes to Medicaid in 2025
There could be significant changes to Medicaid funding in 2025 that would greatly reduce the number of people who qualify for benefits. Policy changes are currently being discussed that would put a cap on federal Medicaid spending and reduce the federal matching dollars paid the to the states. This would create a significant financial hardship for most states, forcing them to cut the number of people they can cover as well as the benefits they offer. These changes (if enacted) would reduce the number of people who qualify for D-SNP plans. In this scenario, you may have clients who need your help finding new coverage they could afford.
C-SNPs
C-SNP enrollment increased in 2024 by 45% compared to 2023 enrollment, with the majority of enrollees in plans for people with diabetes or cardiovascular conditions. In 2025, CMS set two new requirements for C-SNP carriers regarding the Special Supplemental Benefits for the Chronically Ill (SSBCI). These are the supplemental benefits that C-SNP plans offer, usually comprising of benefits such as food, utilities, and transportation.
- Plans must demonstrate that the supplemental benefits they provide actually improve the health or overall function of the enrollee. This is to ensure plans are spending CMS rebate dollars appropriately.
- To increase benefit utilization, insurers must send customized mid-year notices to enrollees to inform them of the benefits they are not utilizing as well as instructions on how to use them.
Medicare agents with C-SNP clients can help by providing education about the SSBCIs available to clients through their plans and the health advantages they can achieve by utilizing these benefits. Remind your clients to keep you informed of any changes to their health that would make them eligible for an SEP to enroll or disenroll from a C-SNP.
The dedicated team at Western Asset Protection is here to keep you informed on Medicare’s regulations. Contact us today.