Dual-Eligible D-SNP Plans: What the New Enrollment Rules Actually Mean
"D-SNP" gets used like it's one thing. It isn't — and the rules for switching into or out of one changed in ways that catch even people who've been dual eligible for years.
D-SNPs (Dual Eligible Special Needs Plans) come in three integration levels — coordination-only, Highly Integrated (HIDE), and Fully Integrated (FIDE) — and how well yours actually combines your Medicare and Medicaid benefits depends entirely on which one it is. Separately, as of January 1, 2025, the quarterly Special Enrollment Period that let dual eligibles switch Medicare Advantage plans four times a year was eliminated. In its place are two narrower monthly SEPs: one lets any dual eligible drop Medicare Advantage and return to Original Medicare, and a second, for full-benefit duals only, allows switching into an integrated D-SNP that matches their Medicaid plan. Neither lets you freely switch between ordinary Medicare Advantage plans anymore.
This site's Dual-Eligible Checker covers the basics well — full versus partial dual eligibility, what D-SNPs are in general, and automatic Extra Help enrollment. What it doesn't get into is what actually determines whether a D-SNP delivers on its promise of coordinated care, and the enrollment rule changes that took effect starting in 2025 and are still reshaping how dual eligibles can move between plans in 2026. Both matter more than the basic definition suggests.
D-SNPs aren't one thing — there are three integration levels
Every D-SNP holds a contract with the state Medicaid agency, but how much that contract actually knits Medicare and Medicaid together varies enormously.
- Coordination-only (CO D-SNP): The lowest integration level. The plan coordinates with Medicaid on paper, under a State Medicaid Agency Contract, but Medicare and Medicaid benefits and financing largely stay separate systems.
- Highly Integrated (HIDE-SNP): Covers Medicare benefits plus at least some Medicaid benefits — typically behavioral health or long-term services and supports — under the same parent organization, even if not through a single combined contract.
- Fully Integrated (FIDE-SNP): The deepest integration. A single plan entity holds one capitated contract covering essentially all Medicaid services, including long-term services and behavioral health, alongside Medicare — one plan, one set of contacts, one combined benefit design.
Which types are even available depends on the state — some states have pushed hard toward FIDE-SNPs (Illinois, for instance, is adding them for the first time in 2026), while others still mostly offer coordination-only plans. The name "D-SNP" on a marketing brochure doesn't tell you which of the three you're looking at; that has to be asked directly.
CO D-SNP
Lowest integration. Coordinates with Medicaid on paper; 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 at all — an ordinary MA plan with a high share of dual-eligible enrollees but none of the coordination requirements. Being phased out.
The enrollment rules changed — and got more restrictive, not less
Before 2025, dual eligibles and Extra Help recipients had a quarterly Special Enrollment Period, letting them change Medicare Advantage plans up to four times a year outside the normal enrollment windows. CMS's Final 2025 Medicare Advantage Rule eliminated that SEP starting January 1, 2025, and replaced it with two narrower ones that are still in effect for 2026:
- The dual/Extra Help SEP — open to any dual eligible (full or partial) and Extra Help-only recipients. It allows one change per month, but only to disenroll from a Medicare Advantage plan, return to Original Medicare, and enroll in a standalone Part D plan. It cannot be used to move to a different Medicare Advantage plan.
- The integrated care SEP — open only to full-benefit dual eligibles. It allows one election per month into a FIDE-SNP, HIDE-SNP, or other CMS-designated "applicable integrated plan" that matches the person's Medicaid managed care enrollment. It cannot be used to enroll in a non-integrated Medicare Advantage plan.
The practical effect is narrower than it might sound: dual eligibles no longer have a standing SEP to freely move between ordinary Medicare Advantage plans during the year. The only moves the new SEPs support are exiting to Original Medicare, or moving toward a more integrated D-SNP. Partial-benefit duals and Extra Help-only recipients lost MA-to-MA switching entirely — their only special enrollment option now is leaving Medicare Advantage altogether. CMS designed it this way deliberately, to steer dual eligibles toward integrated plans rather than plan-hopping among unintegrated options — but it means the flexibility many duals had grown used to is genuinely gone, not just relabeled.
Why CMS is cracking down on "look-alike" plans
A separate but related change: some Medicare Advantage plans have historically enrolled a disproportionately high share of dual-eligible members without being D-SNPs at all — meaning none of the care-coordination requirements applied, even though the enrollee mix looked just like a D-SNP's. CMS calls these look-alike plans, and it's phasing them out by progressively lowering the dual-eligible enrollment percentage that triggers non-renewal of the plan's Medicare Advantage contract: 80% for 2024, 70% for 2025, and 60% starting in 2026. A plan that crosses the threshold doesn't get its contract renewed, which functionally removes it from the market. The goal is to close a gap where dual eligibles were being enrolled in plans that had every appearance of specialized dual-eligible coverage without the coordination obligations that actually come with being a true D-SNP.
What this means if you're dual eligible right now
Two practical takeaways. First, if you're already in a D-SNP, it's worth confirming which integration level it actually is — a coordination-only plan and a FIDE-SNP can both be marketed as "a D-SNP for dual eligibles" while delivering very different levels of actual benefit coordination. Second, if you're thinking about switching plans, know which SEP applies to your situation before assuming you have the flexibility you may have had in past years: the quarterly switch option is gone, and what replaced it is narrower and, for full-benefit duals, specifically points toward integrated plans rather than open switching.
Frequently Asked Questions
Are all D-SNPs the same?
No. D-SNPs range across three integration levels: coordination-only (CO D-SNPs), which mainly coordinate benefits with minimal financial integration; Highly Integrated (HIDE-SNPs), which combine Medicare benefits with Medicaid behavioral health or long-term services under the same parent organization; and Fully Integrated (FIDE-SNPs), single plans holding one combined contract to deliver essentially all Medicare and Medicaid benefits together.
Can dual eligibles still switch Medicare Advantage plans every quarter?
No. That quarterly Special Enrollment Period was eliminated starting January 1, 2025. It was replaced with two more restrictive monthly SEPs: one that lets any dual eligible or Extra Help recipient drop a Medicare Advantage plan and return to Original Medicare with a standalone Part D plan, and a separate one, for full-benefit duals only, that allows switching into an integrated D-SNP matching their Medicaid managed care plan. Neither can be used to switch freely between ordinary Medicare Advantage plans.
What is a D-SNP look-alike plan?
A regular Medicare Advantage plan that enrolls a disproportionately high share of dual-eligible members without being a true D-SNP, meaning it isn't bound by D-SNP care-coordination requirements. CMS is phasing these out by progressively lowering the dual-eligible enrollment percentage that triggers non-renewal of the plan's contract: 80% for 2024, 70% for 2025, and 60% starting in 2026.
Did partial dual eligibles lose any enrollment options in the 2025 changes?
Yes. Partial-benefit dual eligibles and Extra Help-only recipients lost the ability to switch between Medicare Advantage plans during the year entirely. Their only remaining special enrollment option is to leave a Medicare Advantage plan for Original Medicare plus a standalone Part D plan, not to move to a different Medicare Advantage plan.
How do I find out my own D-SNP's integration level?
Ask the plan directly whether it holds a State Medicaid Agency Contract and whether it's designated coordination-only, HIDE, or FIDE, or check your state's Medicaid managed care or ombudsman resources, since integration levels and which D-SNP types are even available vary significantly by state.
This article explains general D-SNP integration categories and Medicare Advantage enrollment rules as of August 2026. Which D-SNP types are available, and the specific plans that qualify for an integrated care SEP, vary by state and by Medicaid managed care enrollment. This is general educational information, not insurance or legal advice — confirm your own SEP eligibility and plan options directly with Medicare (1-800-MEDICARE) or your State Health Insurance Assistance Program (SHIP).