C-SNPs Plans May Be Jeopardizing Medicare-Medicaid Integration

Something different today. C-SNP is a Chronic Condition Special Needs Plan; C-SNP plans provide Medicare Advantage benefits tailored to individuals with specific chronic conditions by offering personalized care coordination, condition-specific treatments. Better definition to follow. MA plans are more expensive than Traditional Medicare plans and more profitable. There is a lack of evidence showing that C-SNPs provide higher quality or more efficient care for beneficiaries than other MA plans or Traditional Medicare..

Growth of C-SNPs May Be Jeopardizing Medicare-Medicaid Integration | Health Affairs

Despite policy makers’ continued efforts to integrate care for beneficiaries dually eligible for Medicare and Medicaid, more than half of dual-eligible beneficiaries are still enrolled in Medicare plans without any form of Medicare-Medicaid integration. State and federal regulators are increasingly trying to understand which non-integrated Medicare Advantage (MA) plans dual-eligible beneficiaries may be enrolling in over integrated plans. One rapidly growing type of non-integrated MA plan that is seeing increased enrollment among dual-eligible individuals is the Chronic Condition Special Needs Plan (C-SNP).

C-SNPs are MA plans that enroll Medicare beneficiaries with specific chronic conditions—such as diabetes, heart failure, and dementia. In total, there are 15 chronic conditions for which C-SNPs can be offered, focusing on conditions that are substantially disabling or ones that place individuals at high risk of hospitalization or significant adverse health outcomes. While these plans are meant to coordinate disease management and health care services for Medicare beneficiaries, to date, there is a lack of evidence showing that C-SNPs provide higher quality or more efficient care for beneficiaries than other MA plans. However, dually eligible individuals—many of whom have multiple chronic conditions that qualify them for C-SNPs—may choose to enroll in these plans due to the specialized benefits they can provide.

Additionally, unlike integrated care plans—which have been shown in prior work to be modestly more effective at reducing long-term nursing home stays, improve outpatient care, and be associated with better patient experience compared to non-integrated plans—C-SNPs are not federally required to coordinate or financially integrate care between Medicare and Medicaid for those who are dual eligible. In a recent Health Affairs article, we observed significant enrollment growth of dual-eligible beneficiaries into C-SNPs between 2011 to 2024. These results raised early concern that C-SNPs may pose a future threat to Medicare-Medicaid integration efforts if their growth continued unchecked.

In this Forefront piece, with the new availability of Medicare enrollment data for 2025, we examine ongoing enrollment growth of C-SNPs overall and among the dual-eligible population. We also provide recommendations for consideration to ensure federal efforts to integrate Medicare-Medicaid care is not further compromised as C-SNPs continue their rapid expansion.

Rapid Growth Of C-SNPs in 2025

Within the past year alone, there was a notable increase in the number of C-SNPs being offered, from 303 in 2024 to 372 in 2025 (22.7 percent growth), and in the total number of Medicare beneficiaries enrolled in C-SNPs, from 629,560 to 1,069,660, respectively (69.9 percent growth) (see exhibit 1). These numbers are substantially higher than in 2016, when there were only 137 C-SNPs with 315,200 beneficiaries.

Importantly, the number of dual-eligible beneficiaries enrolling in C-SNPs also continues to increase (see exhibit 2). In 2016, there were only 84,874 dual-eligible beneficiaries in C-SNPs, of which 42,056 (49.6 percent) were full-benefit dual-eligible individuals and 42,818 (50.4 percent) were partial dual-eligible users. By 2025, there are now 212,453 dual-eligible beneficiaries in C-SNPs, of which 125,638 (59.1 percent) are full-benefit dual-eligible individuals and 86,815 (40.9 percent) are partial dual-eligible users. Between 2024 and 2025 alone, this reflects a 54.4 percent increase in full-benefit dual-eligible beneficiaries and 68.1 percent increase of partial dual-eligible users enrolling in C-SNPs.

Source Of Prior Enrollment For New Dual-Eligible C-SNP Beneficiaries

To determine the extent to which C-SNPs are enrolling beneficiaries from plans offering some level of Medicare-Medicaid integration, we examined 2024 plan enrollment of full-benefit dual-eligible beneficiaries newly enrolled in C-SNPs in 2025 (see exhibit 3). We found that 27.5 percent of these 2025 full-benefit-dual-eligible beneficiaries were previously enrolled in a plan that offered some form of integration in the prior year.

Specifically, 4.7 percent were previously enrolled in plans that offered a high level of Medicare-Medicaid integration, 4.5 percent in plans that offered a moderate level of integration, and 18.3 percent that offered a low level of Medicare-Medicaid integration. These results demonstrate consistent growth in the proportion of new full-benefit dual-eligible C-SNP enrollees who have switched into C-SNPs from plans with some level of integration, which was about 25 percent of newly enrolled full-benefit dual-eligible beneficiaries in the 2024 C-SNPs. These results confirm concerns that C-SNP growth is increasingly jeopardizing federal efforts to integrate Medicare and Medicaid care for dual-eligible beneficiaries.

Many C-SNPs Would Be Terminated If The D-SNP “Look-Alike” Regulation Applied To All Special Needs Plans

Beginning in January 2023, the Centers for Medicare and Medicaid Services (CMS) stopped contracting with D-SNP “look-alike” plans—non-integrated, conventional MA plans in which 80 percent or more of their enrollees were dual-eligible users. These look-alike plans were not subjected to the same federal and state regulations to integrate care between Medicare and Medicaid as other Dual-Eligible Special Needs Plans (D-SNPs), despite enrolling mostly dual-eligible individuals. CMS further revised the dual-eligible enrollment threshold for look-alike plans to 70 percent in 2025 and then 60 percent in 2026 and beyond.

C-SNPs, however, are exempted from the CMS look-alike regulation, even if the dual-eligible enrollment of an individual C-SNP exceeds the stated dual-eligible thresholds. To determine the number of C-SNPs that could potentially be eliminated if the look-alike regulation applied to all special needs plans, we examined the number of C-SNPs from 2023 to 2026 that exceeded each year’s look-alike threshold based on their dual-eligible enrollment share in the prior year.

The total number of C-SNPs that would have been terminated each year has increased from 11 plans in 2023 and 14 plans in 2024 (when the 80 percent threshold applied) to 23 plans in 2025 (when the 70 percent threshold applied) (see exhibit 4). By 2026, when the look-alike threshold further drops to 60 percent, 45 C-SNPs would be terminated if look-alike regulation applied to C-SNPs, which represents 15 percent of all 2025 C-SNPs with at least 100 enrollees. These results suggest that C-SNPs are becoming the new look-alike plans for dual-eligible beneficiaries.

Addressing Potential Issues with Dual-Eligible Enrollment Growth In C-SNPs

The rapid expansion of C-SNPs among dual-eligible beneficiaries in recent years should be a major concern for policy makers and relevant stakeholders invested in Medicare-Medicaid integration. In our Health Affairs paper, we cautioned that the observed C-SNP enrollment trend through 2024 warranted close attention. Now, just a year later, we feel that the ongoing growth in dual-eligible enrollment into C-SNPs represents a significant threat to national integration efforts.

While C-SNPs currently enroll only a small proportion of the total dual-eligible population, the speed at which these plans are increasing in size and number indicates that it may be time for more regulatory oversight. This is particularly pressing, since more than one in four new C-SNP enrollees in 2025 were previously enrolled in plans that offered some level of Medicare-Medicaid integration in 2024. Furthermore, our data suggest that C-SNPs may be emerging as the new look-alike plans, given that a considerable number of C-SNPs are disproportionately enrolling dual-eligible beneficiaries, yet they are exempted from meeting regulatory requirements to integrate care between Medicare and Medicaid.

In fact, in 2013, the Medicare Payment for Advisory Committee (MedPAC) recommended Congress allow almost all C-SNPs, then part of a temporary demonstration, to end, with the exception of a small number of C-SNPs that target people with end-stage renal disease, HIV/AIDS, or disabling mental health conditions. Instead, Congress ended up permanently authorizing C-SNPs in 2018, and now, more than 90 percent of C-SNPs in the market are actually focused on cardiovascular conditions and diabetes, while very few focus on the three MedPAC-recommended conditions.

So, what can be done by policy makers and federal agencies to preserve ongoing integration efforts for dual-eligible beneficiaries? One potential strategy is for CMS to consider applying the look-alike regulation to C-SNPs as well. By 2026, this would potentially translate to terminations of about 15 percent of the C-SNPs with at least 100 enrollees. Our recent work suggest that exemption from the look-alike regulation may partially explain the recent upward trend in dual-eligible enrollment into C-SNPs over the past three years. This change could help steer dual-eligible beneficiaries into more integrated care plans instead of being funneled into C-SNPs following the termination of current look-alike plans.

Furthermore, with C-SNPs gaining traction among dual-eligible enrollees, research into the quality of care and beneficiary experience among dual-eligible users in C-SNPs versus in integrated plans will be more important than ever. To date, there has been limited research evaluating quality and efficiency of care among dual-eligible beneficiaries with specific chronic conditions enrolling in C-SNPs versus other forms of integrated care plans. Lack of comprehensive, linked Medicare and Medicaid data is part of the problem. Currently, the limited evaluations are based on MA encounter and Medicaid administrative claims data with known quality issues. Moving forward, CMS and MedPAC should consider formal evaluations under these different models of care for dual-eligible beneficiaries to help guide policy efforts.

Conclusion

The rapid growth of C-SNPs among dual-eligible beneficiaries raises urgent concerns about the future of Medicare-Medicaid integration. With a significant share of new enrollees transitioning from more integrated plans and many C-SNPs now enrolling high proportions of dual-eligible beneficiaries without being subject to integration requirements, these plans risk becoming the next wave of look-alike plans previously targeted by CMS. Policy makers can consider extending regulatory oversight—such as the D-SNP look-alike regulation—to C-SNPs to prevent further erosion of integration efforts. Additionally, robust evaluation of care quality and outcomes for dual-eligible users in C-SNPs versus integrated plans is essential to inform future policy efforts and ensure that care for this medically complex, socially vulnerable population is both effective and coordinated.

Growth Of C-SNPs May Be Jeopardizing Medicare-Medicaid Integration | Health Affairs