Here is what you’ll find in this week’s newsletter!

It’s only a 5 minute read, but it will make you 10x smarter.

DEEP DIVE 📚

Last year we asked whether the elimination of the quarterly Dual/LIS SEP was actually slowing down switching in the D-SNP market. At the time (a few months into the new rules) the answer was no clear evidence either way (link).

We now have data through June 2026. Eighteen months under the new SEP regime instead of six. Enough to give a real answer.

Quick reminder on the rule change, for anyone joining mid-series:

By Carrier, By Month: Who’s Gaining, Who’s Losing

Since the data we have access to only reports total enrollment counts by month at the Contract, Plan, State, County level, and not at the individual member level, there is no exact way of calculating sales and lapses. They are all mixed together in one number.

But by observing month-over-month changes from April through December, we can get a strong indication of switching activity between carriers.

We already know that the Annual Enrollment Period (AEP) drives significant movement, with some additional shifting during the Open Enrollment Period (OEP). But what about the rest of the year?

The table below displays month-over-month enrollment changes by carrier, highlighting which plans gained and lost the most members:

Here’s 2024:

Here’s 2025:

Here is 2026 (so far):

A few things stand out:

That carrier-level whiplash is the clearest sign that switching hasn't disappeared. It's just rotating between different winners each year.

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Individual Non-SNP plans are far more stable. When comparing D-SNPs to Individual Non-SNP plans, the latter sees lower volatility in enrollment, implying less frequent switching compared to D-SNPs.

One way of observing this is to look at the % change in enrollment each month. In particular, comparing Individual Non-SNP to D-SNP for the same Carriers.

Here’s 2024:

Here’s 2025:

Here’s 2026 (so far):

You can see by simply observing the top 5 carriers, that D-SNP month to month changes continue to be larger when compared to Individual Non-SNP plans.

But, both 2025 and 2026 have less drastic changes for D-SNP.

Another way we can compare the two is to calculate the standard deviation of month-over-month % change across the top 15 carriers. Or put another way, how spread out their growth rates are from each other in a given month. Higher dispersion means more redistribution between carriers; lower dispersion means carriers are moving together (or not moving much at all).

Here’s what that looks like:

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Bottom Line

D-SNP dispersion (indicator of lapse rates) in 2025 and 2026 is lower than it was in 2023 and 2024, but it's still running meaningfully higher than Non-SNP.

The quarterly SEP elimination did impact switching during the SEP period.

What it didn't do is bring D-SNP switching down to Non-SNP's level. Even in the calmest recent months, D-SNP carriers are still gaining and losing share from each other at 2–4x the rate Non-SNP carriers are. Some of that gap is probably the remaining monthly integrated-care SEP still doing its job for full-benefit duals in states with aligned D-SNPs. Some of it may just be structural as dual-eligible members churn more than the general MA population regardless of the election-period rules around them.

For carriers and distributors: retention in D-SNP has genuinely improved since the SEP change, but remains higher than Individual Non-SNP.

If you’re ready, here are some ways we can help you: