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 four times a year ended. Two monthly SEPs replaced it. One lets any dual eligible leave Medicare Advantage for Original Medicare. 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 two further points: how the three D-SNP types differ, and the enrollment rules that have applied since 2025.
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.
The enrollment rules got tighter in 2025
Before 2025, dual eligibles and Extra Help recipients had a quarterly Special Enrollment Period. They could change Medicare Advantage plans up to four times a year outside the regular enrollment windows. CMS ended that SEP on January 1, 2025, in its final 2025 Medicare Advantage rule. Two narrower SEPs replaced it, and both still apply in 2026.
| 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. 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 rules, a dual eligible can use an SEP during the year for two kinds of move only: out to Original Medicare, or into an integrated D-SNP. Partial-benefit duals and people with Extra Help only cannot change from one Medicare Advantage plan to another by SEP at all. Their one special enrollment option is to leave Medicare Advantage.
CMS made the change to move dual eligibles toward integrated plans and to cut down on frequent switching among plans that do not coordinate with Medicaid. Everyone can still change plans during the Annual Enrollment Period, October 15 to December 7.
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
A plan over the threshold loses its contract and leaves the market. If you are in one, you will get a notice and will need to choose other coverage.
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 in any month. Partial duals can only leave for Original Medicare outside the regular enrollment periods.
- Get free help. A SHIP counselor can tell you which integrated plans are available in your county.
Frequently Asked Questions
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 switch between Medicare Advantage plans by SEP during the year. Their one special enrollment option is to leave a Medicare Advantage plan for Original Medicare and a standalone Part D plan.
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).