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Enrollment & timing

Starting in 2027, New Enrollees in Many Dual-Eligible Special Needs Plans Must Also Be in an Affiliated Medicaid Plan

A CMS rule taking effect January 1, 2027, closes a category of Medicare Advantage plans designed for dual-eligible members to anyone not already enrolled in the plan sponsor's affiliated Medicaid program. A full alignment deadline follows in 2030.

By the Goodsurance editorial teamOctober 6, 2026

With the Medicare Annual Enrollment Period opening October 15, a federal rule will narrow who may newly join a class of Medicare Advantage plans specifically designed for people who have both Medicare and Medicaid coverage.

Dual Eligible Special Needs Plans, known as D-SNPs, are Medicare Advantage plans built for beneficiaries who qualify for both programs. They are intended to coordinate Medicare and Medicaid benefits in a single plan, and enrollment in them has grown to nearly one in four Medicare Advantage members in 2026.

Have both Medicare and Medicaid? A new 2027 rule changes which special D-SNP plans you can join during open enrollment.

Under a rule finalized in April 2026, D-SNPs that are operated by a Medicare Advantage organization that also runs an affiliated Medicaid managed care organization in the same service area must limit new enrollment to individuals who are enrolled in, or in the process of enrolling in, that affiliated Medicaid managed care plan. The restriction applies to all enrollment with an effective date on or after January 1, 2027.

For a dual-eligible person shopping during open enrollment, the practical effect is that joining one of those D-SNPs for 2027 requires also being covered by the same company's Medicaid product. A person enrolled in a different Medicaid plan, or one with no Medicaid managed care enrollment, would not be permitted to newly join the affiliated D-SNP.

Existing D-SNP enrollees are not immediately required to change. However, a separate 2030 deadline will extend the aligned-only requirement to all covered members, not just new enrollees, meaning current members whose Medicaid coverage is not aligned will eventually face a transition.

CMS describes the policy as a step toward deeper integration of Medicare and Medicaid benefits for dual-eligible beneficiaries, a population that advocates have long identified as underserved by fragmented coverage arrangements. The agency's D-SNPs guidance page was updated October 2, 2026.

In plain words

Some people have both Medicare and Medicaid. There are special health plans just for them called D-SNPs. Starting January 1, 2027, not everyone can join any D-SNP they want. If a D-SNP is run by the same insurance company that also runs a Medicaid plan in your area, you must be in that company's Medicaid plan to join their D-SNP. This rule only affects new enrollments. If you are already in a D-SNP, you can stay for now. But by 2030, everyone in those D-SNPs will need to match their Medicaid plan to the same company. If you have both Medicare and Medicaid and are shopping for a plan this fall, check which Medicaid plan you are enrolled in before picking a D-SNP.

Understand the basics first

Source: CMS
Read at the source →

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