SNP enrollment has tripled since 2018 to more than 8 million. Between 2024 and 2025, C-SNPs grew 71% in a single year. And the lead generation industry still routes every Medicare prospect through the same undifferentiated funnel.
Special Needs Plans are no longer a niche. They are the growth engine of Medicare Advantage. Since Congress made SNPs a permanent part of the MA program in 2018, enrollment has tripled—from 2.6 million to more than 8 million beneficiaries as of February 2026. SNPs now represent 23% of all MA enrollment, up from 13% in 2018, and they accounted for 83% of all MA enrollment growth in 2026.
But SNP is not one product. It is three fundamentally different products serving three distinct populations, each with unique eligibility criteria, care requirements, and enrollment economics:
D-SNPs (Dual-Eligible Special Needs Plans) serve beneficiaries enrolled in both Medicare and Medicaid—typically lower-income individuals with higher rates of functional and cognitive impairment. As of 2025, more than 80% of all SNP enrollees were in D-SNPs. Through 2024, D-SNPs drove more than 90% of all SNP enrollment growth, expanding from 2.2 million enrollees in 2018 to 5.8 million in 2024. However, D-SNP growth slowed markedly in the 2024–2025 cycle, adding just 159,400 new enrollees—a fraction of prior-year gains.
C-SNPs (Chronic Condition Special Needs Plans) serve beneficiaries with specific severe or disabling chronic conditions. Nearly all C-SNP plans—97%—are designed for individuals with diabetes or cardiovascular conditions, though they can also cover conditions like end-stage liver disease, chronic lung disorders, and multiple sclerosis. In the 2024–2025 enrollment cycle, C-SNP enrollment surged 71%, adding 476,300 new enrollees—triple the D-SNP increase. C-SNPs accounted for 75% of total SNP enrollment growth that year, a dramatic reversal from prior years when D-SNPs dominated.
I-SNPs (Institutional Special Needs Plans) serve beneficiaries who require a nursing home or institutional level of care. I-SNP enrollment remained flat, representing approximately 2% of total SNP enrollment.
Source (2024–2025 C-SNP/D-SNP breakdown): KFF – A Closer Look at the Growing Role of Special Needs Plans in Medicare Advantage (September 2025)
Note: KFF’s February 2026 enrollment update confirmed 8 million+ total SNP enrollees and 83% of MA growth from SNPs, but has not yet published a 2026-specific C-SNP vs. D-SNP breakdown. The granular C-SNP/D-SNP figures above reflect the 2024–2025 enrollment cycle. Given that the regulatory dynamics driving C-SNP acceleration—the D-SNP look-alike threshold dropping to 60% in 2026 and continued D-SNP integration mandates—have intensified, the structural trend is expected to continue or accelerate.
The acceleration of C-SNP growth is not organic demand alone—it is a direct consequence of regulatory incentives. Starting in 2022, CMS began phasing out “D-SNP look-alikes”—conventional MA plans that enrolled predominantly dual-eligible members without meeting D-SNP integration requirements. The threshold for look-alike designation was lowered to 70% dual-eligible enrollment in 2025 and is scheduled to drop to 60% in 2026. Simultaneously, CMS imposed new integration and coordination requirements on D-SNPs, increasing the operational burden of serving dual-eligible populations.
C-SNPs are not subject to these look-alike thresholds or integration mandates. As KFF noted, this regulatory asymmetry may incentivize insurers to enroll dual-eligible individuals—many of whom also have qualifying chronic conditions—into C-SNPs rather than D-SNPs, since C-SNPs carry a lighter regulatory load.
For FMOs and agencies, this creates a lead routing problem of the first order. A prospect who is dual-eligible and has diabetes may qualify for both a D-SNP and a C-SNP. The right plan depends on the member’s specific needs, the plan designs available in their geography, and the regulatory structure governing each product. Standard lead forms don’t capture this distinction. Standard lead routing doesn’t make it. And standard lead scoring doesn’t even attempt it.
SNP enrollment is highly concentrated. UnitedHealth Group and Humana together account for 54% of total SNP enrollment. UnitedHealth alone controls roughly half of all C-SNP enrollees and 38% of D-SNP enrollees. Only 14% of SNP enrollees are in plans administered by nonprofit insurers.
Source: Healthcare Finance News – KFF: Enrollment in MA Special Needs Plans on the Rise (2025)
But this concentration is shifting. UnitedHealth told investors it expects to lose 1.3 to 1.4 million MA members during 2026 as it raises premiums and narrows networks to improve margins. When large national carriers exit markets, smaller regional and provider-sponsored plans frequently enter—particularly those with existing Medicaid managed care programs and local provider networks. For FMOs serving these emerging plans, the ability to identify, score, and route SNP-eligible leads is the differentiator that makes the relationship valuable.
RiskLync’s Sequential Intelligence Pipeline is the only system designed to address the SNP scoring gap—with each model in the sequence handling a distinct layer of the product-matching problem.
ZipLync (Pre-Purchase – Geographic Product Density): Before a lead is purchased, ZipLync’s socioeconomic and geographic model identifies not just conversion probability but product-specific opportunity across 32,000+ ZIP codes. ZIPs with high concentrations of dual-eligible beneficiaries signal D-SNP density. ZIPs with elevated prevalence of diabetes and cardiovascular conditions signal C-SNP opportunity. An FMO evaluating a lead list can see, before spending a dollar, which geographies are standard MA markets and which are SNP markets.
ProLyncMA (Post-Purchase, Step 1 – General MA Scoring): After purchase, ProLyncMA applies Behavioral Predictive Modeling with 3,000+ attributes to score for general Medicare Advantage fit. Leads that score well for standard MA are routed to the appropriate agent queue. Leads that show indicators of higher-acuity needs proceed to the next scoring layer.
ProLyncC (Post-Purchase, Step 2 – Chronic SNP Scoring): Leads with chronic condition indicators—particularly diabetes and cardiovascular markers—are evaluated by ProLyncC for C-SNP qualification. In the 2024–2025 cycle, C-SNP enrollment grew 71%—making it the fastest-accelerating segment in Medicare. As of 2025, C-SNPs represented 16% of all SNP enrollees, up from 10% just one year prior. This model addresses the segment where growth and regulatory momentum are most concentrated.
ProLyncD (Post-Purchase, Step 3 – Dual-Eligible SNP Scoring): Leads whose income, benefits profile, and demographic attributes indicate potential Medicaid-Medicare dual eligibility are scored by ProLyncD for D-SNP fit. With D-SNPs still comprising over 80% of total SNP enrollment as of 2025, and enrollment varying dramatically by state—from 5% of dual-eligibles in Nevada to 58% in Hawaii as of 2021, the most recent state-level data available—this geographic and demographic precision matters enormously.
Source (state-level D-SNP variation, 2021 data): KFF – 10 Things to Know About D-SNPs (August 2025)
In RiskLync’s retrospective Medicare study, this sequential approach—geographic scoring before purchase, then product-specific Behavioral Predictive Modeling after—delivered 62% more expected enrollments on the same $1M budget. The improvement came not from finding more leads, but from answering the question the industry has been ignoring: which product does this lead actually belong to?
As of February 2026, more than eight million Americans are enrolled in Special Needs Plans. That number grew by nearly 900,000 in a single year. In the prior enrollment cycle, C-SNPs alone added more members than most individual MA plans did in total. And not a single lead generation platform is scoring for SNP product fit at the pre-purchase stage.
That gap is RiskLync’s market. ZipLync identifies where the SNP opportunity lives. ProLync—in its MA, C, and D variants—determines which product each lead belongs to. Together, they turn the fastest-growing segment in Medicare into the most precisely served one.