Special needs plans (SNPs) may be overhauled through streamlining or potentially by combining the various plans types. The Centers for Medicare and Medicaid Services (CMS) appears to be in an info-gathering stage when it comes to the future of SNPs, using requests for information (RFI), discussions with experts and other avenues to inform the agency’s direction on policymaking.
The agency ultimately seeks to strike a balance between beneficiaries’ diverse needs in SNPs while also creating consistent quality standards and measurements even as enrollment continues to grow, said Rose Mollitor, managing director with ATI Advisory. The impact of possible consolidation is unclear, but stakeholders are wondering if model effectiveness – designed to help specific patient populations – would be lost in the process.
SNPs are many times boiled down to one category, but there are distinct models, including those that serve dual eligible (D-SNPs), chronic (C-SNPs) and institutional (I-SNPs) beneficiaries; sometimes beneficiaries qualify for more than one type of SNP.
“CMS is wrestling with the question of whether SNPs are delivering value, and to whom, and are the existing SNPs, specifically the dual plans versus the chronic needs plans versus the I-SNPs, are they delivering care in a differentiated enough way to be different products,” said Mollitor.
As the sector approaches the 2027 annual enrollment period and subsequent plan bidding cycles, SNP growth will remain a significant focus for policymakers. However, the pace and direction of such growth isn’t clear at this time.
“We support efforts to streamline [SNPs] and have strong relationships with national health plans that position us to adapt,” Ben Lerer, CEO of Longevity Health, told Skilled Nursing News. “However, we believe streamlining cannot come at the expense of the specificity that makes each model effective.”
Combining models could affect how members access and receive care that supports strong outcomes, Lerer said.
“While C-SNPs and D-SNPs may serve portions of a similar population, I-SNPs are designed specifically for individuals living in institutional settings,” said Lerer. “The future of [SNPs] should preserve the distinctions that make each model successful, including the specialized, facility-based infrastructure that allows I-SNPs to bring proactive, coordinated care directly to some of Medicare’s most vulnerable members.”
And at the same time that CMS is considering SNP changes, Medicare beneficiaries are becoming more informed and sophisticated in their healthcare choices, Mollitor said, meaning they are more likely to seek plans that more specifically address their individual needs, supporting the underlying purpose of SNPs to offer flexibility and targeted programs to patients.
The 2028 MA and Part D proposed rule due to be released in the fall may have relevant SNP policy changes if there are any, she said. Unlike the Skilled Nursing Facility Prospective Payment System (SNF PPS), the MA and Part D payment rule isn’t required by statute and is more along the lines of a recommendation.
SNPs are designed to offer more customized, targeted care models and benefit designs, complete with a specialized network and flexibility for particular populations. But recently, questions have been raised by the agency and in states looking to implement integration requirements.
Possible integration at the federal, state level
“Members who may be appropriate for an I-SNP oftentimes are also dual eligible,” said Mollitor. “Is there value that they would receive from being in an integrated product? Do the integration requirements and the higher level of integration between Medicare and Medicaid provide more of a benefit in a D-SNP, or does the I-SNP care model provide the greater value? There’s been a lot of discussions around this.”
Aside from CMS, special needs plans have also been a huge focus of industry experts, advocates and beneficiary groups, Mollitor said. All of these stakeholders are working on proving the value of SNPs, the value they bring to different patient populations.
It all comes back to striking a balance between serving residents with complex needs while also delivering value, she said.
States are looking to prepare for possible integration requirements by activating different mechanisms like default enrollment or certain requirements to more easily move residents into aligned coverage.
“But with that, policymakers need to think about the different types of individuals who have dual coverage, whether they have full Medicaid coverage, or if they’re fully dual or if they’re partially dual,” said Mollitor. “Are they a dual eligible individual who is actively using and has long-term supports needs, are they using LTSS, or are they full dual because they were on Medicare for a long time and they have spent down and are considered medically needy and now have Medicaid coverage?”
These care structures need to be preserved, and policymakers need to recognize that the dually eligible population isn’t homogenous, she said.
How CMS aims to handle each SNP
D-SNPs, I-SNPs and C-SNPs are all at different points in their journey too, Mollitor said.
C-SNPs are expected to have the most evolution over the next few years – the sector has seen pointed questions about C-SNPs in its last RFI, all while exponential growth has been happening for such plans, an 11.5% increase since January, according to ATI data.
“Any time you have exponential growth in a product that wasn’t as common a few years ago, it invites a lot of attention,” said Mollitor. “CMS raised questions, they want to understand what the value is that’s being delivered by C-SNPs and how C-SNPs are impacting state efforts around integration.”
CMS is currently gathering information on who is enrolling in C-SNPs, and if such plans can be offered to members with more commonly diagnosed conditions like cardiovascular disease and diabetes.
C-SNPs currently serve a very narrow, targeted subset of beneficiaries, Mollitor said.
“It is likely that we will see some proposals to help CMS monitor what C-SNPs look like, but I also think we’re seeing a lot of demand for them,” said Mollitor. “Beneficiaries are able to self-identify as having a chronic condition, and these plans are offering benefits and care models around their conditions. That’s really valuable when you’re thinking about an individual who wants to manage their health.”
D-SNPs are a product for a defined population and areis offered by large and small carriers, standalone plans and integrated payers, or ‘payviders.’ The evolution of this plan type may involve streamlining payment, bringing Medicare and Medicaid pieces together more holistically, said Mollitor.
As for I-SNPs, there’s already bifurcation happening there with some plans catering to nursing home residents, and other plans that cater to patients meeting the same level of need but are still living in the community.
“I think that we will largely continue to see incremental growth in the offerings of I-SNPs. It’s a very high touch clinical model, and the ability to grow in that space is geographically concentrated in a way that D-SNPs and C-SNPs are not,” said Mollitor. “You need to be physically present where those [I-SNP] individuals are, and so I think that’s why we’ve been historically seeing growth with I-SNPs from provider-owned plans; I do expect that to continue.”
National carriers may try to scale their I-SNP offerings too, building off local partnerships.
Either way, Mollitor sees growth happening for I-SNPs considering growth of the aging population, more beneficiaries needing long-term care services and what opportunity that presents to CMS in terms of reforms and changes to strengthen or prepare I-SNPs for that growth.
Companies featured in this article:
ATI Advisory, Centers for Medicare & Medicaid Services, CMS, Longevity Health Plan
