The C-SNP Opportunity Is Growing. Is Your Medicare Advantage Plan Ready for 2028?

The Medicare Advantage landscape continues to shift, and Chronic Condition Special Needs Plans (C-SNPs) are increasingly part of the conversation.

Recent activity from UnitedHealthcare is one indication of the growing attention on this market. As one of the nation’s largest Medicare Advantage organizations continues to focus on products designed for members with chronic and complex conditions, other health plans should be asking an important question:

Does a C-SNP belong in our growth strategy?

For organizations considering a C-SNP for Contract Year 2028, now is the time to answer it.

Why C-SNPs Are Getting Attention

C-SNPs are Medicare Advantage plans designed specifically for individuals with certain severe or disabling chronic conditions. This gives health plans an opportunity to create a more targeted experience by aligning benefits, clinical programs, pharmacy strategies, provider networks, and member engagement around the needs of a defined population.

When designed and managed effectively, that alignment can create opportunities not only for growth and differentiation, but also for improved financial performance. A more targeted approach to managing high-need populations can provide plans with greater opportunities to coordinate care, manage utilization, improve quality outcomes, and address the drivers of total cost of care.

For plans operating in an increasingly challenging Medicare Advantage environment, that potential makes C-SNPs particularly compelling. But improved margins are not inherent to the product. They depend on selecting the right population and market—and building the clinical and operational model necessary to manage that population effectively.

Market growth alone doesn't make a C-SNP the right strategy.

Organizations need to understand where the opportunity exists, which populations they are positioned to serve, the financial potential, and whether their existing capabilities can support the requirements of a specialized product.

For 2028, the Planning Window Is Already Here

While 2028 may sound distant, the Medicare Advantage development cycle makes the planning window much shorter.

With the 2028 Notice of Intent anticipated in November 2026 and the application cycle following in February 2027, organizations considering a C-SNP should be evaluating the opportunity now.

Before moving toward an application, leadership should have confidence in several fundamental areas:

• Market and financial opportunity: Is there a sufficiently attractive eligible population, what does the competitive landscape look like, and can the opportunity support the plan's growth and financial objectives?

• Product strategy: Which chronic population should the plan serve, and how can the product differentiate?

• Clinical and Model of Care readiness: What Model of Care will work specifically for the health plan and the needs of its targeted C-SNP population?

• Network and provider strategy: Does the existing network have the right capabilities and relationships?

• Pharmacy: How should pharmacy strategy and benefits support the targeted chronic population?

• Operational readiness: What changes to systems, workflows, staffing, vendors, and compliance processes will be required?

These decisions are interconnected. A compelling market opportunity means little if the organization isn't operationally prepared to execute against it.

Look Beyond the Application

One of the biggest mistakes an organization can make is treating C-SNP development primarily as an application exercise.

The application is a milestone. The strategy—and the operating model behind it—comes first.

That is especially true of the Model of Care (MOC). The MOC should not simply be developed to satisfy an application requirement. It needs to reflect the health plan's targeted population, clinical strategy, provider relationships, internal capabilities, and approach to managing members with complex chronic conditions.

Developing a MOC that works specifically for the organization and its intended C-SNP members is critical because that model ultimately needs to translate into day-to-day operations. The people, processes, technology, providers, and vendors responsible for delivering it must be able to execute it effectively.

The strongest approach therefore begins with understanding the market and determining whether the opportunity aligns with the organization's broader growth and financial strategy. From there, plans can assess their current capabilities, identify gaps, develop the right Model of Care, and establish a realistic roadmap for implementation.

C-SNPs touch multiple areas of the organization. Product, clinical, pharmacy, operations, compliance, quality, risk adjustment, network, and member experience all need to work together. That cross-functional alignment is also what allows the organization to move from simply offering a C-SNP to managing the population effectively and realizing the potential financial value of the product.

Starting that work early gives organizations time to make thoughtful decisions rather than trying to solve strategic and operational questions while simultaneously navigating application deadlines.

How Rebellis Can Help

At Rebellis, we approach Special Needs Plan development from the perspective of the entire health plan.

Our cross-functional team brings together expertise across Product and Financial Strategy, Clinical Operations, Pharmacy, Compliance, Quality and Stars, Risk Adjustment, Operations, Sales and Marketing, and provider and vendor strategy.

For organizations considering a 2028 C-SNP, we can help evaluate the market and financial opportunity, assess organizational readiness, and identify the path forward.

That can include market and competitive analysis, financial feasibility, product and benefit strategy, network and pharmacy considerations, and the development of a Model of Care tailored to the plan and its targeted C-SNP members, along with operational and compliance readiness, vendor evaluation, and implementation planning.

The objective is straightforward: help leadership make an informed go/no-go decision and, when the answer is go, build a practical roadmap for a C-SNP that is not only compliant and operationally ready, but positioned to deliver value for members and the health plan.

Is C-SNP Part of Your 2028 Strategy?

C-SNPs represent an increasingly important opportunity within Medicare Advantage—but the right strategy will look different for every organization.

For the right plan, market, and population, a well-designed C-SNP can create an opportunity to grow membership, better manage chronic populations, improve outcomes, and strengthen financial performance. Capturing that opportunity requires thoughtful planning and disciplined execution.

The plans best positioned for 2028 will be those that start asking the right questions before the application cycle begins.

Is there an opportunity in our market? Are we positioned to serve this population? Can we build a Model of Care that works for our organization and our members? And what will it take to get ready?

With the 2028 planning cycle approaching, now is the time to find out.

Considering a C-SNP for 2028? Rebellis can help you evaluate the opportunity, assess your readiness, develop the right Model of Care, and build a roadmap from strategy through implementation.

Contact us