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CMS recently released information about CY2025MAplanofferings,including D-SNPs.2The remainder of this paperdiscusses key takeaways from a review of CY2025D-SNP planofferingdataand Milliman’s Medicare AdvantageCompetitiveValue Added Tool (MillimanMACVAT®).1.TheD-SNP marketgrowth ratecontinues to slowThe number of D-SNPsisincreasingby6%in CY2025.Figure2shows the growth in D-SNPs over the past five years.FIGURE2:NUMBER OF D-SNPS(CY2020–CY2025)In CY2025, the pace of growthof offeredD-SNPs(6.3%)remainsrelativelyhigh,butCY 2025is the lowest year of growthsince 2016 and represents a continuedmoderationrelative to thefive consecutive years of double-digit growth from 2019 to 2023.While maintaining strong positive growth, this pattern somewhatmirrors recent general enrollment plan offering trends, where the01002003004005006007008009001,000 March 2025790852906202320242025 540598700202020212022 Key insights into2025Medicare Advantage D-SNP landscapegrowth rate hasslowedin each of the pastsixyears. Unlike D-SNP plan growth,which remains positive, general enrollmentplan growth has been negative fortwo consecutive years,withdecreasesof1.1%and 6.2%in 2024 and 2025, respectively.Figure 3 shows the averageannualgrowth in MA plans by yearfrom2020through2025separately for D-SNPs, C-SNPs,andgeneral enrollment plans.C-SNPs are included to illustrate thehigh growth in 2025(20% increase in plan offerings). C-SNPenrollment grew by 66% from January2024 to January2025.Some ofthe C-SNPplan and enrollmentgrowthmay be a resultof carriers finding new avenues to offer plans that are attractiveto dualeligiblebeneficiariesin response to state and federalpolicies,such as prohibition ofgeneral enrollment D-SNP look-alike plans.These policies are discussed further in Section 6.FIGURE3:ANNUAL GROWTH IN NUMBER OF PLANS BY PLAN TYPE(CY2020–CY2025)FIGURE4:CHANGE INNUMBER OFMAOSOFFERINGD-SNPSBYSTATE(CY2024–CY2025)-10%0%10%20%30%40%202020212022202320242025General EnrollmentD-SNPC-SNP March 2025In2025,13states had an increase in the number of MAOsofferingD-SNPsfrom2024,while12stateshad reductions—doublethe number in 2024.Figure4shows thechange innumber ofunique MAOsoffering D-SNPs in each statefrom2024 to 2025.States with the largestchanges include:Indiana:The number of organizations offering D-SNPs wasreduced from six to three(Elevance, Humana, andUnitedHealthcare)as the state now limits D-SNPs to onlythose offered by MAOs with a companion Medicaid managedlong-term services and supports (MLTSS)contract.North Dakota:D-SNPs will be offered for the first time inNorth Dakota in2025with four market entrants(Humana,Medica, Sanford, and UnitedHealthcare).Texas:Three organizations (Alignment, Devoted, andShared Health) willnowbe offering D-SNPs in Texas.Like all MAplans,D-SNP service area is defined at the countylevel.Consistent with recent years,D-SNP availabilityat thelocallevelcontinues to be strong.Based on our analysis of theplandata and CMS dual eligible beneficiary enrollmentdata,over98% of full benefit dual eligible beneficiaries have access to a D-SNP orMedicare-Medicaid Plan (MMP)in2025,and96% haveaccess to at least three D-SNPor MMPoptions.3MMPs areplantypesdistinct from D-SNPs and are excluded from D-SNP totalsthroughoutthispaper,buttheyshare many characteristics withD-SNPs,includingenrolling onlydual eligible beneficiaries.These amounts both increased by less than 1% from2024.Bycomparison, 95% of full benefit dual eligible beneficiaries hadaccess to a D-SNP in 2020,and 80% had access to at leastthree D-SNPor MMPoptions.© GeoNames, Microsoft, TomTomPowered by Bing-30+4 March 2025Centene(Allwell)offers D-SNPs in30states (three fewerthanCY2024,entering Iowa andexiting Alabama, Indiana,NewMexico, and Rhode Island).Aetna(CVS Health)offers D-SNPs in31states(onefewerthan inCY2024,entering Oklahoma and exiting Indianaand Kansas).Other MAOsofferingD-SNPs in at least10states include Elevance,Molina, and CIGNA.CIGNA has a pending mergerwith HCSC,which would expand their D-SNP portfoliointo two additional states,New Mexico and Oklahoma.Figure5shows thefourMAOsmentioned abovewith the largest D-SNP footprints.Shadedstates represent current footprint,anddarkest shading indicatesmost recent additions (2022 through 2025).Despite relatively minimal expansionat the state levelfor thelargest D-SNP MAOs, these MAOshave historically drivenincreases inthe number of D-SNPs by offering D-SNPs in© GeoNames, Microsoft, TomTomPowered by BingCVS/Aetana D-SNP Footprint© GeoNames, Microsoft, TomTomPowered by BingCentene D-SNP Footprint Key insights into2025Medicare Advantage D-SNP landscape2.National MAOscontinue todominate landscape, buttheirfootprintsareshrinkingUnitedHealthcare continues to offer D-SNPs in more statesandcover more D-SNPbeneficiariesthan any other MAO.The fourMAOs with the largest D-SNP footprints aredescribed below. Forthe first time since thisannualpaper has been published, all four areexiting at least one state relative to the previous year: