Dual-Eligible D-SNP Plans: What the New Enrollment Rules Actually Mean
D-SNPs come in three levels of Medicare and Medicaid integration, and since 2025 dual eligibles can no longer switch Medicare Advantage plans every quarter. Here are the current rules.
A D-SNP (Dual Eligible Special Needs Plan) can be coordination-only, Highly Integrated (HIDE) or Fully Integrated (FIDE). The level decides how much of your Medicare and Medicaid coverage one plan handles. On January 1, 2025, the quarterly Special Enrollment Period that let dual eligibles change Medicare Advantage plans once in each of the first three quarters of the year ended. Two monthly SEPs replaced it, and both still apply in 2026. One lets any dual eligible or Extra Help recipient leave Medicare Advantage for Original Medicare with a standalone drug plan. The other lets full-benefit duals join an integrated D-SNP that matches their Medicaid plan. Neither allows a move from one ordinary Medicare Advantage plan to another.
Our Dual-Eligible Checker covers full and partial dual eligibility, what a D-SNP is, and automatic Extra Help. This article covers who can join a D-SNP, how the three D-SNP types differ, and the enrollment rules that have applied since 2025. For the other two kinds of plan, C-SNPs and I-SNPs, see our guide to Medicare Special Needs Plans.
Who Is Eligible for a D-SNP
You are eligible for a D-SNP if you have Medicare Part A and Part B, have Medicaid from your state, and live in the plan's service area. You also have to meet the plan's own eligibility rules, which can be set in its contract with your state Medicaid agency.
- Medicare: You must be entitled to Part A and enrolled in Part B, the same as for any Medicare Advantage plan.
- Medicaid: D-SNPs are only for people who are entitled to Medicaid under their state's plan.
- Where you live: You must live in the plan's service area.
- The plan's own rules: Each D-SNP can have extra eligibility requirements in its contract with the state. Some only enroll full-benefit dual eligibles, people the state finds eligible for full Medicaid benefits. Since 2025, a FIDE-SNP only enrolls full-benefit dual eligibles who get their Medicaid through the same company's Medicaid plan. Federal rules do not bar partial-benefit dual eligibles from some other D-SNPs, but states can limit who joins.
Meeting these rules does not mean you can join at any time of year. When you can enroll depends on which Special Enrollment Period you qualify for, covered below.
D-SNPs come in three integration levels
Every D-SNP has a contract with the state Medicaid agency. How far that contract combines Medicare and Medicaid differs from plan to plan.
- Coordination-only (CO D-SNP): The lowest level. The plan coordinates with Medicaid under a State Medicaid Agency Contract, but Medicare and Medicaid benefits and funding stay mostly separate. You may still deal with two sets of cards and phone numbers.
- Highly Integrated (HIDE-SNP): Covers Medicare benefits and some Medicaid benefits, usually behavioral health or long-term services and supports, through the same parent organization. The two may be under separate contracts.
- Fully Integrated (FIDE-SNP): The highest level. One plan holds one capitated contract covering nearly all Medicaid services, including long-term services and behavioral health, together with Medicare. You have one plan and one member services line.
The types on offer depend on the state. Some states have moved toward FIDE-SNPs. Illinois, for example, is adding them for the first time in 2026. Others still offer mainly coordination-only plans. Marketing material often says only "D-SNP," so ask the plan which type it is.
CO D-SNP
Lowest integration. Coordinates with Medicaid; benefits and financing stay largely separate.
HIDE-SNP
Covers Medicare plus some Medicaid benefits (often behavioral health or LTSS) under the same parent organization.
FIDE-SNP
Fullest integration. One plan, one combined contract covering nearly all Medicare and Medicaid benefits together.
Look-Alike Plan
Not a D-SNP. An ordinary MA plan with a high share of dual-eligible enrollees and none of the coordination requirements. Being phased out.
D-SNP Enrollment in 2026: What Changed From 2025
The enrollment rules for dual eligibles are the same in 2026 as in 2025. The big change came on January 1, 2025. Through 2024, dual eligibles and Extra Help recipients had a quarterly Special Enrollment Period. They could make one change in each of the first three quarters of the year (January to March, April to June, July to September), including a move from one Medicare Advantage plan to another. CMS replaced that SEP with two narrower monthly SEPs in its final 2025 Medicare Advantage rule, for enrollments starting on or after January 1, 2025. Both still apply in 2026.
| Rule | 2024 | 2025 and 2026 |
|---|---|---|
| SEP for dual eligibles | One quarterly SEP | Two monthly SEPs |
| How often | Once per quarter, January through September | Once a month, in any month |
| Switch to another Medicare Advantage plan by SEP | Yes | Only into an integrated D-SNP that matches your Medicaid plan (full-benefit duals only) |
| Leave Medicare Advantage for Original Medicare and a drug plan | Yes | Yes, in any month |
The one D-SNP rule that did change for 2026 is the look-alike plan limit, which dropped to 60%. That is explained in the next section. Here is what each of the two current SEPs allows.
| SEP | Who can use it | How often | What it allows |
|---|---|---|---|
| Dual/Extra Help SEP | Full and partial dual eligibles, and people with Extra Help only | Once a month | Leave a Medicare Advantage plan, return to Original Medicare and join a standalone Part D plan, or switch standalone Part D plans. Cannot be used to join a different Medicare Advantage plan. |
| Integrated care SEP | Full-benefit dual eligibles only | Once a month | Join a FIDE-SNP, HIDE-SNP or other CMS-designated applicable integrated plan that matches your Medicaid managed care enrollment. Cannot be used to join a non-integrated Medicare Advantage plan. |
Under these two SEPs, a dual eligible can make two kinds of move during the year: out to Original Medicare, or into an integrated D-SNP. Partial-benefit duals and people with Extra Help only cannot use either one to change from one Medicare Advantage plan to another. Other SEPs still apply to anyone who qualifies, for example when you move out of your plan's service area or your plan leaves Medicare. If you gain, lose or have a change in Medicaid or Extra Help, you also have 3 months after the change, or after you are told about it if that is later, to make a Part D election.
CMS made the change to move more dual eligibles into plans that also cover their Medicaid benefits, and to cut down on year-round marketing to dual eligibles by all types of plans. Everyone can still change plans during the Annual Enrollment Period, October 15 to December 7, and anyone in a Medicare Advantage plan can make one change from January 1 to March 31.
Why CMS is phasing out "look-alike" plans
Some Medicare Advantage plans enroll mostly dual-eligible members without being D-SNPs. They do not have to meet D-SNP care-coordination requirements. CMS calls them look-alike plans.
CMS will not renew a non-D-SNP plan's contract when dual eligibles make up too large a share of its enrollment. The threshold has been lowered in steps:
- 80% for 2024
- 70% for 2025
- 60% from 2026
CMS will not renew a plan over the threshold. If you are in one, the company may move you into another of its plans, including a D-SNP if you qualify, and must explain the change in your Annual Notice of Change. You can also choose a different plan yourself during the Annual Enrollment Period.
What to do if you're dual eligible now
- Find out which type of D-SNP you have. Call the number on your card and ask whether the plan is coordination-only, HIDE or FIDE. A coordination-only plan and a FIDE-SNP can carry the same "D-SNP for dual eligibles" label and work very differently.
- Check which SEP you can use before you plan a switch. Full-benefit duals can move into an integrated plan that matches their Medicaid plan in any month. Partial duals and Extra Help recipients can leave for Original Medicare in any month, but a move to another Medicare Advantage plan has to wait for an enrollment period or another SEP.
- Get free help. A SHIP counselor can tell you which integrated plans are available in your county.
Frequently Asked Questions
Who is eligible for a D-SNP?
You are eligible for a D-SNP if you have Medicare Part A and Part B, have Medicaid from your state, live in the plan's service area, and meet any extra rules in the plan's contract with your state Medicaid agency. Some D-SNPs only enroll full-benefit dual eligibles. Since 2025, a FIDE-SNP only enrolls full-benefit dual eligibles who get their Medicaid through the same company's Medicaid plan.
What changed for D-SNP enrollment in 2026 compared with 2025?
The enrollment rules stayed the same. The big change came on January 1, 2025, when two monthly SEPs replaced the quarterly SEP that applied in 2024. One lets dual eligibles and Extra Help recipients leave Medicare Advantage for Original Medicare with a standalone drug plan, or switch drug plans, in any month. The other lets full-benefit dual eligibles join an integrated D-SNP that matches their Medicaid plan in any month. Both still apply in 2026. What did change for 2026 is the look-alike plan limit, which dropped to 60%.
Are all D-SNPs the same?
No. There are three integration levels. Coordination-only plans (CO D-SNPs) coordinate benefits but keep Medicare and Medicaid funding separate. Highly Integrated plans (HIDE-SNPs) cover Medicare plus Medicaid behavioral health or long-term services under the same parent organization. Fully Integrated plans (FIDE-SNPs) hold one contract covering nearly all Medicare and Medicaid benefits.
Can dual eligibles still switch Medicare Advantage plans every quarter?
No. The quarterly Special Enrollment Period ended on January 1, 2025. Two monthly SEPs replaced it. One lets any dual eligible or Extra Help recipient leave a Medicare Advantage plan for Original Medicare with a standalone Part D plan. The other, for full-benefit duals only, allows joining an integrated D-SNP that matches their Medicaid managed care plan. Neither can be used to move between ordinary Medicare Advantage plans.
What is a D-SNP look-alike plan?
It is a regular Medicare Advantage plan that enrolls a very high share of dual-eligible members without being a D-SNP, so it does not have to meet D-SNP care-coordination requirements. CMS is phasing these plans out by not renewing contracts above an enrollment threshold: 80% for 2024, 70% for 2025 and 60% from 2026.
Did partial dual eligibles lose any enrollment options in the 2025 changes?
Yes. Partial-benefit dual eligibles and people with Extra Help only can no longer use the dual/Extra Help SEP to move from one Medicare Advantage plan to another. That SEP now lets them leave a Medicare Advantage plan for Original Medicare with a standalone Part D plan, or switch drug plans, in any month. They can still change Medicare Advantage plans during the Annual Enrollment Period, during the Medicare Advantage Open Enrollment Period from January 1 to March 31, or when another SEP applies, such as a move out of the plan's service area.
How do I find out my own D-SNP's integration level?
Ask the plan whether it is designated coordination-only, HIDE or FIDE. You can also ask your state's Medicaid managed care office, ombudsman or SHIP. The types available differ by state.
This article explains general D-SNP integration categories and Medicare Advantage enrollment rules as of October 2026. Available D-SNP types and the plans that qualify for the integrated care SEP vary by state and by Medicaid managed care enrollment. This is general educational information, not insurance or legal advice. Confirm your SEP eligibility and plan options with Medicare (1-800-MEDICARE) or your State Health Insurance Assistance Program (SHIP).