Thursday SNaP Shot from SNP Alliance | |
Defining the Critical Role of Special Needs Plans Growing Demand with High Quality Services
We're excited to invite you to join us for the SNP Alliance Spring Members-Only Roundtable, taking place April 16th & 17th, 2026 in Washington, DC at the Yours Truly Hotel. This year's meeting brings our community together in a focused, collaborative setting to dive deep into the evolving policy landscape and share insights on strategies that strengthen SNPs' Value. Please click the links below for registration and to learn more about our upcoming Spring Roundtable. If you have any questions, please contact Sam Amaya at samaya@snpalliance.org.
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Day 1
During the April members-only meeting, the membership will hear from CMS officials and experts in complex chronic care about policy and practices strengths, weaknesses, opportunities and threats during day one. Each panel will conclude with a concrete set of action steps for plans and SNP Alliance policy development as well as advocacy.
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Day 2
During the second day, April 17, based upon the expert panels, the membership will develop, or refine, SNP Alliance policy and strategy as well as identify needed technical assistance resources. The discussion will focus upon expanding SNP Request of Information responses, broad positioning strategies with CMS divisions, as well as CMMI, and proactively addressing unfolding Congressional policy discussions.
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Takeaways from 2026 SNP Enrollment
On February 16, CMS released long-awaited 2026 SNP enrollment data. SNP enrollment has been a key driver of Medicare Advantage growth, with notable shifts in recent years. As of February 1, 2026, Medicare Advantage enrollment reached 35 million beneficiaries, up 1.1 million (about 3% year-over-year) from February 2025 (KFF). This growth was largely driven by increased SNP enrollment, even as total Medicare Advantage plan availability for general enrollment plans declined. Individual plans saw slower growth than in prior years, but SNP offerings expanded, attracting more beneficiaries (KFF). Key takeaways from the CMS data include: a) SNP enrollment has outpaced general Medicare Advantage growth in recent years, especially in C-SNPs. Growth is concentrated in condition-specific plans (cardiovascular, diabetes). However, C-SNPs targeting previously untouched condition categories are emerging – neurological, additional behavioral health, substance abuse, and dementia; b) geographic patterns vary, with some states leading in D-SNP adoption primarily related to MMP phase down; and c) benefit design and value-added measures are influencing enrollment and retention, particularly in D-SNPs. The Special Needs Plan Alliance provides quarterly and annual enrollment data, including state-level breakdowns by SNP type and dual eligibility status (SNP Alliance). These maps and reports show variation in enrollment growth across states, with some states seeing rapid SNP adoption due to targeted benefit designs and care coordination.
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MedPAC Health Affairs Article Highlights Ongoing Coding Intensity and Other Research
In a February 18 article, MedPAC highlights continued challenges with coding intensity and points out additional opportunities for CMS to address the issue. Using the V28 implementation as the study focus, MedPAC articulates in its summary, “Both CMS’ and MedPAC’s analyses indicate that uncorrected coding intensity is substantially lower under V28 relative to what would have occurred under v24. MedPAC’s estimate of uncorrected coding intensity under the first full year of V28 implementation in 2026 is 4 percent. This is about 2 percentage points higher than CMS’s estimate of uncorrected coding intensity under a hypothetical scenario where V28 had been used as the sole risk model to adjust MA plan payments for 2022. The main difference between the estimates is that MedPAC’s estimate accounts for the upward trend in coding intensity.” To view the article, click here.
On February 19, JAMA Network published a study projecting that approximately 10% of MA enrollees will lose their MA plan in the 2026 plan year due to plan withdrawal from their market. Researchers from Johns Hopkins University and Georgetown University found that the mean “forced disenrollment” rate increased from 1% between 2018 and 2024 to 6.9% in 2025. The study reported that beneficiaries enrolled in preferred provider organization plans, those covered by smaller insurers, and individuals in rural areas are more likely to be affected.
On February 23, ATI Advisory released an article entitled “High Needs Populations, Long-Term Care ACOs and the New LEAD Model.” The SNP community has been analyzing the LEAD ACO model and its implications for SNPs since the December 2025 release of the model. Of particular interest is the Medicare and Medicaid Integration option under LEAD. LEAD is one of CMMI’s array of ACO approaches and targets outcome-focused, value-based care, emphasizing equity, access, and community health. Providers participating in LEAD will need strong data, risk management, and care coordination capabilities to succeed, while benefiting from financial predictability and flexibility to meet patient needs. The LEAD ACO model is a long-term, voluntary program designed to expand accountable care participation, particularly for smaller and rural providers, while improving care for high-needs populations and supporting sustainable, value-based healthcare delivery. In highlighting these areas in its design, CMS is attempting to solve for past ACO challenges. LEAD ACO targets the same high-needs Medicare population as SNPs but the market implications are not yet fully understood.
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Special Needs Plan Alliance Submits CY 2027 Advance Notice Comments
The Special Needs Plan Alliance is pleased to submit constructive, collaborative Advance Notice Comments to CMS. To view the Comments, click here. To inform our comments, the Special Needs Plan Alliance contracted for two independent documents. An ATI Advisory Issue Brief (click here), supported by the SNP Alliance, provides an overview of Special Needs Plan operational requirements as well as beneficiary characteristics and needs. An independent study was prepared by Milliman on the proposed payment policy provisions of the Advance Notice. To view the Milliman study, click here.
For more information on the documents above, contact Mike Cheek at mcheek@snpalliance.org
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Congressional Legislation Impacting SNPs in Discussion
Of interest to SNPs are three pieces of legislation. First, Senator Cassidy’s (R-LA) Delivering Unified Access to Lifesaving Services Act (DUALS Act) is on hold at least until May or June. Senator Cassidy has a challenger for his seat, and the primary is top priority for him. Second, Rep. Arrington’s (R-TX) Improving MA SNP Act of 2026 (H.R. 6974) would permit additional CMS-approved and deemed accreditors to approve the MA SNP Models of Care (MOCs). Current statute only allows one accreditor, the National Committee for Quality Assurance (NCQA), to approve MOCs. Finally, discussions are rebooting on one of the array of integration legislative proposals dating back to 2022 (click here for a Health Affairs overview). The Advancing Integration in Medicare and Medicaid (AIM) Act (S. 4264), sponsored by Senators Scott (R-SC), Casey (D-PA), and Cassidy (R-LA), was one of three legislative proposals that would have driven integration planning at the state level. Based on a June 2022 MACPAC Report, the AIM Act would have required states to develop plans for integrating Medicare and Medicaid.
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SNP Alliance Integrations AI into its 2026 Strategic Plan
The SNP Alliance Board has targeted understanding the use of Artificial Intelligence (AI) in complex care as a 2026 priority area. Key focus areas for SNP Alliance research include beneficiary experience, balancing AI utility, and beneficiary customization with the need for ongoing interaction with plan staff, particularly Care Coordinators, workforce – specifically understanding when and where the technology can augment staff, and AI bias. At a higher level, the SNP Alliance will be analyzing bigger picture aspects of AI in healthcare to identify additional SNP-specific opportunities and issues. For an overview on AI in healthcare, click here for a Harvard Gazette article dated January 12, 2026.
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Engage with the SNP Alliance – Upcoming Opportunities
On a monthly basis, the SNP Alliance schedules a week of highly targeted Hill visits, CMS meetings, as well as meetings with federal commissions and think tanks. These weeks are structured much like traditional association fly-ins. In February, the SNP Alliance met with 16 Hill offices and Committee staff members, as well as an array of other CMS and commission meetings. If you would like to participate in upcoming SNP Alliance monthly meeting weeks, please join us for March 9 – 13 and April 13 – 17, the week of our Spring Members-Only Meeting held on April 16 – 17. To participate in our meetings, contact Kate Henry at khenry@snpalliance.org
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| | | The Special Needs Plan Alliance (SNP Alliance) issues a monthly newsletter with original content tailored to the SNP community developed by the SNP Alliance policy team and membership. If you have questions on, or suggestions for, newsletter content, please contact Mr. Sam Amaya at samaya@snpalliance.org. | | | | |
