Congress permanently authorized special needs plans seven years ago, although insurers have been selling the policies since 2008. Companies initially focused on marketing to people dually eligible for Medicare and Medicaid and the market reflects that legacy. Dual Eligible SNPs comprise 83.2% of the 7.3 million special needs plan enrollees in 2025.
But as competition in the D-SNP market grows and fewer people age into Medicare, insurers are diversifying by investing in C-SNPs, said Allison Rizer, executive vice president at ATI Advisory, a healthcare consulting firm. There, they found a large pool of potential customers: Approximately 80% of Medicare-eligible adults, or 50 million people, have at least two chronic conditions, and 27%, or about 17 million people, have multiple chronic illnesses, according to the National Council on Aging, an advocacy group.
“Medicare Advantage is going to continue to evolve as we add more market penetration and get closer to market saturation. Insurers just have to differentiate. We are seeing that with these C-SNPs popping up,” Rizer said.
Upcoming regulatory changes could provide an additional bump to C-SNPs.
The cancelation of the Value-Based Insurance Design model in 2026 will likely drive former members to C-SNPs as an alternative policy, Rizer said. Additionally, a 2030 mandate that D-SNP insurance companies hold a state Medicaid contract could move insurers without a Medicaid presence to diversify, she said.
As in the overall Medicare Advantage market, UnitedHealthcare is the largest C-SNP carrier, accounting for nearly 555,400 enrollees, or 50.1% of the market. The company more than doubled its count of C-SNP members from 2024 to 2025. UnitedHealthcare did not respond to an interview request.
“If United was not generating this type of significant growth in C-SNP, the overall growth in the C-SNP market would not have screened as being so significant,” said Scott Fidel, managing director of healthcare services at the Stephens investment bank.
Absent UnitedHealthcare’s investment, the market grew 26% this year, still outpacing CMS and Wall Street projections. The growth serves as a stark contrast to the larger Medicare Advantage market, which grew at the slowest rate in program history in 2025.
Companies like Alignment Health and SCAN Health Plan that sell Medicare Advantage plans to consumers with specific identities – like LGBTQ+, women and veterans – have also zeroed in on the C-SNP market.
This year, Alignment Health launched new C-SNP plans that treat depression and lung conditions, such as chronic obstructive pulmonary disease, or COPD, said President Dawn Maroney. These add to the company's C-SNP plans targeted at people suffering from diabetes, kidney failure and heart disease.
The insurer worked with marketers to identify people with these specific diagnoses in areas where it sells policies, Maroney said. The company also invested in a new transportation benefit that pays for C-SNP enrollees’ rides to doctor's appointments, pharmacies, grocery stores and elsewhere, she said.
“In most of our markets, 12% of the population is diabetic. If you cater a program around that, then you can get adoption,” Maroney said. “It’s a growing population.”
The insurer’s C-SNP enrollment more than doubled to 40,700, or nearly 20% of its total membership.
SCAN Health Plan likewise invested in new benefits to capture C-SNP members. The company added fresh groceries as a benefit for diabetic enrollees, said Karen Schulte, president of Medicare.
Growth in the program could partially be attributed to more companies feeling comfortable administering special supplemental benefits to chronically ill policyholders, Schulte said. Special supplemental benefits are non-medical services like food and transportation that insurers offer members. The insurer added nearly 9,000 new C-SNP enrollees in 2025, up 48%.
“We have leaned into the highest risk,” Schulte said.
Insurers' focus on C-SNPs could provide a windfall for companies that offer home-based care to older adults with chronic conditions.
WellBe Senior Medical, HarmonyCares, Patina Health and DispatchHealth partner with health insurers to help Medicare Advantage members stay on top of chronic conditions and avoid unnecessary hospitalizations.
The companies provide in-home assessments, medication management and urgent care. They also help connect members to supplemental benefits that address social determinants of health, such as food and transportation. That could be an especially useful service for insurers because CMS for the first time in 2025 requires carriers to notify members of any unused benefits in their Medicare Advantage plans, including C-SNPs.
While none of the insurers WellBe Senior Medical had partnerships with last year offered C-SNPs, a spokesperson said a few are offering them this year. The Chicago-based company has contracts with several insurers across nine states, including CVS Health's Aetna, Clover Health and Medical Mutual of Ohio.
Meghann Jordan, WellBe’s director of strategic partnerships, said the company’s model aligns with C-SNP requirements, so growth in those plans could be advantageous as WellBe looks to expand to more states and partner with more insurers.
“As we continue to partner, we can certainly align across their priorities and the goals that they might be setting for the member,” Jordan said.
C-SNPs could also help HarmonyCares expand its pool of patients, CEO Matthew Chance said. The Troy, Michigan-based company provides home-based care to approximately 70,000 older adults across 15 states covered under three national Medicare Advantage plans.
Like WellBe Senior Medical, Chance said HarmonyCares helps patients address many of the chronic conditions that C-SNPs are also targeting, so the company could attract more patients if more older adults enroll in those plans.
Chance said the enrollment flexibility of C-SNPs could be a good marketing tool for health insurers that could also be beneficial to HarmonyCares. Unlike D-SNPs and traditional Medicare Advantage, consumers can enroll in plans for the chronically ill anytime through the year.
“There is an opportunity for payers to be marketing all year long to patients who may be in another plan with another payer. Insurers can say they have a plan designed to that population,” Chance explained. “We are a great model of care for that group and a pretty powerful model of care.”
