Federally, your dual eligible special needs plan (D-SNP) and Medicaid plan have to match in 2027 only if the D-SNP's company runs Medicaid managed care for full-benefit dual eligibles in your area. Even then, the federal 2027 limit only restricts who can newly join: a member already in an unmatched D-SNP can stay until 2030. Your state can move faster, though. TennCare, Tennessee's Medicaid program, says a member whose BlueCare, UnitedHealthcare or Wellpoint D-SNP doesn't match their TennCare plan by December 31, 2026 will be disenrolled from the D-SNP.

In This Guide

Does the 2027 D-SNP Rule Apply to You?

A D-SNP (dual eligible special needs plan) is a Medicare Advantage plan built for people who have both Medicare and Medicaid. The "must match" talk you're hearing comes from the Centers for Medicare & Medicaid Services (CMS), whose April 2026 answers to plans' questions explain whom the 2027 and 2030 limits reach. Four questions sort out most people.

1. Do you have full Medicaid, or only help with Medicare costs? The 2027 limits turn on Medicaid plans that enroll full-benefit dual eligibles, and CMS says a company covered by them may also run a separate coordination-only D-SNP just for partial-benefit dual eligibles, if state policy allows. If your only Medicaid help is paying Medicare costs, see the section for you below.

2. Does your D-SNP's company run a Medicaid plan where you live? The federal 2027 and 2030 D-SNP enrollment limits apply when your D-SNP's company, its parent company or a sister company also contracts with your state as a Medicaid managed care plan for full-benefit dual eligibles, in a service area that overlaps the D-SNP's even partly. A D-SNP whose company runs no such Medicaid plan in your state isn't affected. The quickest way to find out is to ask your D-SNP directly whether its company offers a Medicaid plan in your county. Virginia's Medicaid agency points its members to the Medicare Plan Finder to see which D-SNPs their Medicaid plan's company offers.

3. Is your Medicaid through a managed care plan, or fee-for-service? The contract year 2027 rule added an exception for people in Medicaid fee-for-service. Where your state doesn't require all full-benefit dual eligibles to join Medicaid managed care, and the state's contract with the plan allows it, a company may enroll full-benefit dual eligibles in Medicaid fee-for-service in a coordination-only or highly integrated (HIDE) D-SNP. That fee-for-service exception continues in 2030 and beyond unless your state switches to mandatory Medicaid managed care. The fee-for-service exception doesn't reach someone enrolled in a Medicaid plan run by a different, unaffiliated company.

4. Are you already in the D-SNP, or joining it new? The 2027 limit applies to new enrollment. A member already in a D-SNP whose company runs a different Medicaid plan from theirs can stay in that D-SNP until 2030.

If you answered "full Medicaid," "yes, the company runs a Medicaid plan here," "managed care" and "joining new," the 2027 limit is about you: that D-SNP can only take you if you're in, or joining, its company's Medicaid plan.

What Changes in 2027, and What Waits Until 2030

Here's the federal timeline in order, and what each date means for you. If you're already enrolled, the federal limits let you stay in your D-SNP until 2030, though your state may have its own rule (next section).

  • 2027, if you're joining a D-SNP: a D-SNP covered by the federal limits can only take you as a new member if you're enrolled in, or in the process of enrolling in, its company's Medicaid managed care plan. That goes for every kind of D-SNP, including coordination-only D-SNPs tied to such a Medicaid plan.
  • 2027, if you're shopping for a plan: a company family that also runs a Medicaid managed care plan for full-benefit dual eligibles in your area may offer only one D-SNP for full-benefit dual eligibles there, apart from a few exceptions. If your plan's company has several D-SNPs near you now, see what happens when plans combine.
  • 2027, if your plan is an "applicable integrated plan": your D-SNP must give you a single member ID card for both Medicare and Medicaid and have you complete one combined health risk assessment, no later than contract year 2027.
  • 2030, if you're already enrolled and your plans don't match: a D-SNP covered by the federal limits may only enroll or keep covering members of its company's Medicaid plan, and the company must disenroll D-SNP members who aren't also in that Medicaid plan. This is the date the federal rule reaches current members.

An "applicable integrated plan" is the most tightly tied kind: fully integrated (FIDE) SNPs, HIDE SNPs whose members all get Medicaid from the same company, and D-SNPs whose enrollment state policy limits to the company's Medicaid plan, when that Medicaid contract covers primary and acute care (including Medicare cost-sharing) plus at least one of home health, medical equipment and supplies, or nursing facility care. Applicable integrated plans run one combined grievance and appeal process for Medicare and Medicaid instead of two.

One more exception covers U.S. territories that haven't adopted the Medicare Savings Programs. CMS says no territory has, and Puerto Rico is currently the only territory with D-SNPs, so a company operating there is exempt from the one-D-SNP limit.

When Your State Says the Plans Must Match Sooner

States run their own rules on top of the federal one, and they don't all point the same way. So when someone tells you "the plans must match," the right follow-up is "under which rule?" Here's what five states have said.

State What the state says Who it covers
Tennessee The D-SNP and TennCare plan must match by December 31, 2026, or the member is disenrolled from the D-SNP, moved to Original Medicare and needs a Part D drug plan Full-benefit dual eligibles in a BlueCare, UnitedHealthcare or Wellpoint D-SNP
Virginia Since January 1, 2025, choosing a D-SNP assigns you to the same company's Medicaid plan Full-benefit dual eligibles in Medicaid managed care; not partial dual eligibles, people excluded from managed care, or people in Original Medicare or a non-D-SNP Medicare Advantage plan
Arizona Members of an ALTCS Elderly and/or Physically Disabled plan who have a fully integrated D-SNP must align the two, as AHCCCS restated in May 2026 ALTCS E/PD members with a FIDE D-SNP
Wisconsin A full dual in a Medicaid managed care plan can only join a D-SNP from that plan's parent organization; one in fee-for-service Medicaid can join any D-SNP that accepts full Medicaid Full-benefit dual eligibles, per the Wisconsin Department of Health Services
Kansas An October 2024 update for a legislative committee said dual eligibles weren't required to pick the same company for their D-SNP and their KanCare plan Kansas dual eligibles, as of that 2024 update

If you live in Tennessee, the December 31 deadline is real. TennCare says you can make the plans match by changing your D-SNP to match your TennCare health plan, including during Medicare Open Enrollment, October 15 through December 7, and that dual eligibles have a special enrollment period every month to move into a fully integrated dual special needs plan (FIDE SNP). If you'd rather change your TennCare health plan instead, TennCare's special enrollment period for that runs June 1 through October 31, 2026, so don't wait for the December deadline. Our Tennessee BlueCare Plus guide covers the Tennessee plans in detail.

The Kansas statement describes 2024. Whether the federal 2027 limits change things for new Kansas enrollees whose D-SNP company also runs a KanCare plan is something to ask the plan before you switch.

Matching isn't free of trade-offs, and Virginia says so plainly. When a member changes either their D-SNP or their Medicaid plan, Virginia's Medicaid agency warns that the member's current providers aren't guaranteed to be in the new network (especially for Medicaid-only services like home and community-based services and non-emergency medical transportation), and that the member could lose a care coordinator they know or see their extra benefits change. That warning is worth reading wherever you live. Check your doctors and your home care before you switch either plan.

For the state-by-state picture of which integrated plans exist, see our guide to integrated Medicare-Medicaid plans by state, and the Virginia, Arizona and Wisconsin guides.

If You Only Get Help With Medicare Costs

Some people's only Medicaid help is one of the Medicare Savings Programs: Qualified Medicare Beneficiary (QMB)-only, Specified Low-Income Medicare Beneficiary (SLMB)-only or Qualifying Individual (QI). CMS lists those groups among dual eligibles who don't have full Medicaid benefits.

That matters in two directions. A person whose only Medicaid help is QMB-only, SLMB-only or QI can't enroll in a FIDE SNP, or in any other D-SNP with exclusively aligned enrollment (a D-SNP that state policy limits to full-benefit dual eligibles who get their Medicaid through the same company's plan), because federal rules define aligned enrollment only for full-benefit dual eligibles. But that bar doesn't close every D-SNP. CMS says the one-D-SNP rule doesn't stop a company from offering a separate D-SNP for partial-benefit dual eligibles in the same area, as state policy allows. Whether one exists where you live is a state-by-state question, so check the plans in your county.

Partial-benefit dual eligibles can't use the monthly integrated care special enrollment period described below, but they can use the monthly Dual/LIS special enrollment period to move to Original Medicare with a standalone drug plan or switch drug plans.

How to Make Your D-SNP and Medicaid Plan Match This Fall

You have three federal windows on the Medicare side, plus whatever your state allows on the Medicaid side. Here's how they compare.

Window When Who can use it What it lets you do Takes effect
Medicare Open Enrollment October 15 to December 7 each year; the plan must get your form by December 7 Anyone with Medicare Join, drop or switch Medicare Advantage plans, or move between Original Medicare and Medicare Advantage January 1
Monthly integrated care special enrollment period Once a month, since January 1, 2025 Full-benefit dual eligibles only, lining up their D-SNP with the same company's Medicaid managed care plan Join a FIDE SNP, a HIDE SNP or an applicable integrated plan First day of the next month
Monthly Dual/LIS special enrollment period Once a month, since January 1, 2025 Full-benefit and partial-benefit dual eligibles, and people with Extra Help Leave Medicare Advantage for Original Medicare plus a standalone Medicare Part D drug plan, or switch drug plans First day of the next month

If you have full Medicaid and want your plans to match, the monthly integrated care special enrollment period lets you do it in any month, as long as the move lines up your D-SNP with the same company's Medicaid managed care plan. You can't use the monthly integrated care special enrollment period if you're staying in Medicaid fee-for-service or in a different company's Medicaid plan. But being in Medicaid fee-for-service today doesn't rule you out of the monthly integrated care special enrollment period if you're eligible for, and want to join, the matching Medicaid plan. It also depends on where you live: Medicare describes the right as joining an integrated D-SNP if one's available in your area, and which plans qualify is set each contract year, so check the plan list for the year your change takes effect. A D-SNP that CMS doesn't mark as eligible for the integrated care special enrollment period can't be joined through it. Most coordination-only D-SNPs fall in that group, though CMS lists some coordination-only D-SNPs in California that are applicable integrated plans as eligible. Neither monthly special enrollment period lets you join an ordinary Medicare Advantage plan.

The monthly Dual/LIS special enrollment period isn't open to you if you've been identified as a potential at-risk or at-risk beneficiary under a Part D drug management program. And if you're happy with your current plan, you don't need to do anything during Medicare Open Enrollment, because your coverage continues automatically.

Changing the Medicaid side is your state's process, not Medicare's. Tennessee's December 31 deadline and Virginia's automatic assignment in the table above are two very different examples, so call your state Medicaid agency or your Medicaid plan before you assume either way. In Virginia, a member who wants to keep their current Medicaid plan can switch to that company's D-SNP, or choose Original Medicare with a Part D drug plan, or another Medicare Advantage plan that isn't a D-SNP.

For every other Medicare enrollment window, see our guide to Medicare special enrollment periods.

If Your Plan Writes That It's Combining D-SNPs

Some companies will fold several D-SNPs in your area into one to meet the one-D-SNP limit. For contract year 2027 and later, CMS lets a company family that consolidates down to a single D-SNP under one contract move members into the surviving plan, which CMS calls a crosswalk.

A crosswalk has limits that protect you:

A crosswalk is something CMS permits a plan to do, not a promise about where you'll land. If a letter says your D-SNP is ending or merging, call the plan and ask which plan, if any, you're eligible to be moved into, and compare it during Open Enrollment.

If You Lose Medicaid After Your Plans Match

Once your D-SNP and Medicaid plan match, a lapse in Medicaid can put the D-SNP at risk, and the grace period isn't fixed. Federal rules let a special needs plan treat you as still eligible for 30 days to 6 months if it expects you to qualify again within 6 months, and CMS lets each plan choose a length from one to six months. That grace period, called deemed continued eligibility, survives the 2030 rules: a D-SNP limited to its company's Medicaid members may still keep a member during it.

The deemed-eligibility period starts the first of the month after the plan learns of the loss and tells you. If you don't requalify in time, the plan should send a disenrollment notice at least 30 days ahead, and you get a special enrollment period that ends three months after the disenrollment takes effect. Ask your plan for its policy before a renewal deadline, not after.

Where to Get Free Help

Your State Health Insurance Assistance Program (SHIP) gives free, personalized and unbiased health insurance counseling to people with Medicare and their families, including help choosing a plan, and you can find your local SHIP at shiphelp.org. Bring both your Medicare plan card and your Medicaid plan card so the counselor can see both companies.

You can also call 1-800-MEDICARE (1-800-633-4227), the official Medicare line, open 24 hours a day, 7 days a week except some federal holidays; TTY users call 1-877-486-2048.

Frequently Asked Questions

Will I lose my D-SNP on January 1, 2027 if my Medicaid plan is a different company?

Not because of the federal rule, which lets a member already in an unmatched D-SNP stay until 2030 (see the federal timeline). Tennessee is stricter: TennCare says members of BlueCare, UnitedHealthcare and Wellpoint D-SNPs whose plans don't match by December 31, 2026 will be disenrolled.

Do I have to join my Medicaid plan's D-SNP?

Not under the federal rule. The federal 2027 and 2030 limits control whom a D-SNP may enroll. A dual eligible can use the monthly Dual/LIS special enrollment period to choose Original Medicare with a standalone drug plan instead of a D-SNP. In Virginia, the Medicaid agency lists Original Medicare with a Part D drug plan, or a Medicare Advantage plan that isn't a D-SNP, as options for a member who wants to keep their current Medicaid plan. A few state programs do tie the two together, so ask your state Medicaid agency before you decide.

Does matching my plans change how I appeal a denial?

Only if your matched plan is an applicable integrated plan, because applicable integrated plans combine Medicare and Medicaid grievances and appeals into a single process instead of two separate tracks. Our guide to fully integrated dual eligible SNPs explains how that works.

Does the 2027 rule affect me if I'm in a D-SNP and Medicaid fee-for-service?

Possibly not: the federal fee-for-service exception, which continues in 2030 and beyond, can let a coordination-only or HIDE D-SNP keep enrolling full-benefit dual eligibles in Medicaid fee-for-service when your state's Medicaid rules and contract allow it (question 3 has the conditions). Your SHIP or the plan can tell you whether your state allows it.

Learn More

Find personalized help sorting out whether your D-SNP and Medicaid plan need to match at brevy.com.


The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.

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