ATI expert Rose Mollitor recently joined Health Tech Nerds to unpack the 2026 Medicare Advantage (MA) enrollment data. The conversation explored what the topline numbers tell us and what’s happening beneath the surface.
CMS projected enrollment at approximately 34 million beneficiaries, anticipating relative stability year over year. ATI’s analysis landed in a similar range. “Our top-line number is right around 35 million,” Mollitor explained. “Based on our methodology, it is right around 51%, which is fairly stable… just under a 1% increase in overall enrollment.” While this growth is markedly slower than the sustained growth MA has experienced over the past decade, Mollitor emphasized that this top-line stability is concealing movement under the surface.
Shifts in Enrollment by Plan Type
Special Needs Plans (SNPs) — particularly Chronic Condition SNPs (C-SNPs) — show continued growth in 2026.
“I think the story across the board really is the C-SNPs,” Mollitor explained. “When you start breaking it down… general MA and even the retiree plans are fairly stable. But really, where there was shifting movement is the growth in the SNPs.”
Mollitor pointed to:
- Approximately 14% growth in C-SNP enrollment
- Roughly 4% growth in D-SNP enrollment
- A slight decline in I-SNP enrollment off a small base
- Essentially flat general MA enrollment
The magnitude of C-SNP growth stands out. Even as overall MA growth moderates, condition-specific products are expanding rapidly. On the D-SNP side, growth was concentrated in exclusively aligned, more integrated products, correlating with federal and state policy momentum toward Medicare-Medicaid integration.
“There’s been a lot of regulatory effort to drive toward integrated D-SNPs,” Mollitor noted. “So that increase is showing some of the success of those policies.” With 2027 and 2030 integration requirements approaching, the data suggest that both plans and states are preparing for what lies ahead.
Carrier Strategy: Regional and Local Plans Gain Ground
The enrollment data also reflect shifting carrier dynamics. “Our official numbers were around a 1% decrease across the board for enrollment in what we colloquially refer to as ‘jumbo plans,’” Mollitor observed, “with an increase of around 3.5% in regional carriers… and a little bit over 9% in small local carriers.”
These trends track with public statements from large national carriers that signaled retrenchment in certain markets to prioritize profitability. Where those pullbacks occurred, beneficiaries frequently selected another MA plan rather than returning to fee-for-service Medicare.
The growth patterns vary by product line:
- In C-SNPs, certain national carriers expanded enrollment despite broader contraction.
- In D-SNPs, Medicaid-focused carriers such as CareSource and Molina were among the top gainers.
- In I-SNPs, growth skewed toward smaller, specialized plans.
“You are continuing to see, everywhere you peek under the hood, this refocusing of the large carriers,” Mollitor noted. “And this increasing white space and opportunity… now we’re seeing it in the enrollment numbers for those regional and smaller carriers.”
Premium and Network Trends
Enrollment choices also reflect evolving benefit strategies. Despite a modest decline in the availability of $0 premium plans, enrollment in $0 premium products increased. “Members are really continuing to look for those $0 premiums,” Mollitor explained, “even with the tightening that we’ve seen.”
The data also show a shift from PPO to HMO enrollment, consistent with tighter cost management strategies and the inherent structure of SNP products, which are typically offered on an HMO chassis.
Rural Stability
Given recent attention to MA sustainability in rural markets, Mollitor compared trends in rural and urban areas. Enrollment in rural areas remained relatively stable, without dramatic declines.
The Advance Notice: Where Policy Meets Enrollment
When asked how 2026 enrollment trends might intersect with CMS’ Advance Notice proposals, Mollitor highlighted two areas of potential impact: chart review policy and risk model updates.
CMS has proposed eliminating diagnoses from chart reviews that are not linked to encounters for risk adjustment purposes. “This is a strategy used by almost all carriers in certain situations,” Mollitor explained, “but one of the largest use cases is when an individual is new to the plan.”
Given elevated switching during AEP, particularly toward regional carriers, this proposal could have uneven effects. “The question we’re trying to answer,” Mollitor explained, “is whether there are unintentional consequences; if there is a disproportionate impact on regional plans that have a higher-than-expected level of new-to-plan enrollment.”
CMS has also proposed updating the MA risk adjustment model using more recent data, including changes to certain coefficients. “There’s been a lot of conversation… that there could be a disproportionate impact on C-SNP members,” Mollitor noted. “You potentially have a situation where the vast majority of increased MA enrollment occurs in a plan type where you have a payment cut.”
Although the model does not differentiate by product type, the risk composition of C-SNP populations may make those plans more sensitive to coefficient adjustments. For Medicare Advantage plans, the combined impact of enrollment shifts and proposed policy changes creates significant strategic questions for 2027 bid development.
Conclusion
The 2026 MA enrollment data tell a story of stability at the top and strategic recalibration beneath the surface. Between enrollment shifts, rate proposals, STAR ratings updates, and evolving regulatory requirements, plans are navigating an increasingly complex environment.
As we await the Final Rate Notice, ATI will continue to monitor these trends and analyze how policy and market dynamics intersect to shape the future of Medicare Advantage.