SNPs are a type of Medicare Advantage (MA) coordinated care plan designed for individuals with special needs. Initially authorized with the passage of The Medicare Modernization Act of 2003 , SNPs established an type of MA coordinated care plan specifically designed to provide targeted care to individuals with special needs. These individuals’ conditions were defined as as: 1) institutionalized individuals; 2) ‘dual eligibles’ (for Medicare and Medicaid); and/or 3) individuals with severe or disabling chronic conditions, as specified by the Centers for Medicare and Medicaid Cervices.
The Medicare Modernization Act initially gave the SNP program the authority to operate until December 31, 2008. The program was extended in 2007, but a moratorium was imposed that prohibited CMS from approving new SNPs after January 1, 2008.
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) lifted the Medicare, moratorium on approving new SNPs and extended the SNP program through December 31, 2010, while also increasing oversight and SNP program requirements specified. CMS regulations that implement and further detail MIPPA application requirements for SNPs are located at 42 CFR 422.501-504.
In 2010, The Affordable Care Act extended the SNP program through December 31, 2013; subsequent legislation extending the program through December 2018. SNPs were permanently reauthorized with the passage of The Bipartisan Budget Act of 2018–a cause championed by the SNP Alliance and other organizations.
To be defined as ‘special needs’, a beneficiary must meet any of the following conditions to be defined as a special needs individual:
As of April 2020, CMS had approved 379 MA contracts offering 872 Special Needs Plans (SNPs) with a total enrollment of 3,407,406 beneficiaries.
Of these 872 Special Needs Plans:
Institutional Special Needs Plan (I-SNP)
I-SNPs enroll Medicare Advantage-eligible individuals who, for 90 days or longer, have had or are expected to need the level of services that are provided in LTC SNFs, LTC NFs, SNFs and NFs, intermediate care facilities for the developmentally disabled, and inpatient psychiatric facilities.
I-SNPs that serve residents in LTC facilities are required to have contracts with those facilities that include adherence to the I-SNPs approved MOC.
Chronic Condition Special Needs Plan (C-SNP)
C-SNPs enroll Medicare beneficiaries with a single CMS-approved chronic condition, a group of CMS-approved chronic conditions, or a group of chronic conditions customized by an MAO that are selected from the CMS-approved list.
Dual Eligible Special Needs Plan (D-SNP)
Special Needs Plans (SNPs) offered by Medicare Advantage organizations (MAOs) that enroll individuals dually eligible for Medicare and Medicaid.
MAOs must have existing, executed contract(s) with state Medicaid agencies (SMAs), and the D-SNP (Dual Eligible SNP) must coordinate all services, including FFS benefits and grievance and appeals, in addition to specifying a process to share information with the SMA on hospital and SNF admissions for at least one group of high-risk individuals who are enrolled in the D-SNP.
Highly Integrated Dual Eligible Special Needs Plan (HIDE-SNP)
HIDE SNPs have increased integration with Medicaid. In addition to having an existing, executed contract with the SMA, the SMA contract may be with a different legal entity if that legal entity is under the same parent organization as the D-SNP.
HIDE SNPs must have a capitated contract with the SMA to provide coverage for LTSS and/or BH services, and coordinate all services, including Medicaid FFS and grievance and appeals.
Finally, HIDE SNPs must use the unified grievance and appeals procedures if the D-SNP meets the definition for exclusively aligned enrollment.
Fully Integrated Dual Eligible Special Needs Plan (FIDE-SNP)
FIDE SNPs are the D-SNPs most integrated with Medicaid. In addition to having an existing, executed contract with the SMA, the SMA contract must be with the same legal entity offering the D-SNP, meet the requirements of an MCO, and have a contract with the SMA to provide coverage of LTSS.
FIDE SNPs must have capitated contracts with the SMA to provide coverage of a minimum of 180 days of nursing facility services during the plan year, coordinate all services, including Medicaid FFS and grievance and appeals, use unified appeals and grievance procedures if enrollment is exclusively aligned, coordinate the delivery of covered Medicare and Medicaid services using aligned care management and specialty care network methods for high-risk beneficiaries, and integrate beneficiary communication materials, enrollment, communications, grievance and appeals, and quality improvement.
Congress intended for SNPs to exclusively or disproportionately enroll persons with serious chronic conditions to more effectively serve high-risk populations through specialization. SNPs must offer Medicare Parts A, B, and D benefits.
SNPs function under most of the same Medicare Advantage regulations, with some exceptions, and use the same payment methodology as other MA plans.
Key differences between SNPs and standard MA plans include the following:
Medicare Advantage applications, including SNP applications, and Part D applications typically are due in February of the year preceding the contract year. Application guidance for both Part C Medicare Advantage and Medicare Prescription Drug Plans is available on the CMS website.
CMS includes a timeline outlining submission dates for various components of the application and SNP approval process such as drug formularies and bids in the annual Call Letter. The most recent Call Letter is available on CMS’ website.