Special Needs Plan (SNP) enrollment grew 23% in two years. If you’re in a Medicare Advantage (MA) risk arrangement, that’s not a trend to monitor; it’s a contract assumption to revisit.
Over 8.2 million people are enrolled in MA SNPs, up from 6.6 million in February 2024. The headline number looks like straightforward market growth. What’s underneath it is more specific and more consequential for providers carrying MA risk.
Chronic Condition SNPs (C-SNPs) nearly tripled in that window, from roughly 549,000 members to over 1.65 million. Dual-eligible SNPs (D-SNPs) added over 730,000 enrollees, while Institutional plans (I-SNPs) were essentially flat. That concentration matters because C-SNP members are not the general MA population. They carry higher acuity, higher utilization, and cost profiles that most provider contracts and targets weren’t calibrated around. If your attributed panel has been shifting toward this mix, your contract may not reflect the population you’re actually accountable for today.
Here’s what the data shows and what providers with MA risk exposure should be doing about it.
Most beneficiaries are now in MA, and fee-for-service (FFS) enrollment is shrinking in absolute terms
MA crossed 50% of Medicare penetration in early 2024 and reached 51.6% by February 2026. Over that same stretch, FFS enrollment dropped roughly 470,000 in absolute terms, not just as a share. That’s a structural shift, not a year-over-year fluctuation.
For providers taking MA risk, this has two direct planning implications. First, organic panel growth: as Medicare beneficiaries continue choosing MA over FFS, your attributed population should grow even without active outreach. Second, and less obvious, every member who converts from FFS to MA enters the MA risk adjustment framework and immediately takes a step down in effective risk score because of the negative coding intensity adjustment. That transition affects your medical loss ratio (MLR). If you’re not modeling it as a budget input, you may be surprised mid-year.
C-SNP enrollment nearly tripled in two years
The C-SNP growth rate, roughly 200% between December 2023 and February 2026, is the number that should be getting the most attention in provider finance and contracting conversations. This is more than a gradual demographic shift. It’s a rapid concentration of high-acuity, condition-specific enrollees into a plan type that carries structural cost and risk implications most general MA contracts weren’t designed around.
If your performance target was set before this acceleration, it may not reflect your current population’s care management needs or support an accurate target MLR. The gap between what your target assumed about your member mix and what your attributed population actually looks like today is worth quantifying, and it’s better to know before you’re mid-performance-year trying to explain a variance.
Non-SNP MA growth is flat, and that’s the real story
General enrollment MA, the segment most provider contracts and benchmarks were historically built around, is essentially flat as a share of the total Medicare population. Non-SNP MA represented about 39% of total Medicare in December 2023, and it was still at roughly 39% in February 2026. All the net penetration gains are coming from SNP growth.
As a result, the MA market is not simply getting larger; it’s getting more complex, and the complexity is concentrating in the segments with the highest cost and clinical intensity. Providers planning as if general MA enrollment will continue to drive growth the way it did from 2010 to 2022 are working from an outdated model.
Three things providers with MA risk should do now
- Know your SNP mix and whether your contract targets reflect the changing population. If D-SNP or C-SNP members are a growing share of your attributed population, your per member cost and utilization profile has shifted. Ask your MA partner for a population breakdown by SNP type and compare it against the assumptions your performance targets were built on.
- Treat C-SNP growth as a target risk, not a market update. C-SNP enrollment tripled in under two years. If your target predates that acceleration, it’s worth stress testing your current targets against the population you’re actually seeing. The question isn’t whether this affects you — it’s by how much.
- Model FFS shrinkage as a planning input. At 51.6% MA penetration and rising, the FFS-to-MA conversion dynamic isn’t background noise anymore. It affects referral patterns, shared savings calculations, and the composition of your panel. If you’re not already planning for MA penetration in the 55% to 60% range over the next few years, do it now.
The Wakely Value-Based Payment (VBP) team works with provider organizations on exactly this kind of market to contract translation, including benchmarking, population mix analysis, and contract structure reviews. If the C-SNP shift is something your organization is navigating, we’re glad to talk through what it means for your specific arrangements. Reach out to our VBP practice to start the conversation.
