Medicare Fully Integrated Dual Eligible Special Needs Plan (FIDE-SNP)

If you or a family member has both Medicare and Medicaid, the rules governing how those two programs work together changed materially on 1/1/2026. The Centers for Medicare & Medicaid Services (CMS) ended its Financial Alignment Initiative (FAI) at the end of 2025, closing the Medicare-Medicaid Plan (MMP) demonstrations still running in seven states. Those enrollees moved to integrated dual eligible special needs plans (D-SNPs).1 The most tightly integrated of them is the Fully Integrated Dual Eligible Special Needs Plan, the FIDE-SNP: one company holding both the Medicare Advantage contract and the Medicaid managed-care contract.2

This guide explains what a FIDE-SNP is, how it differs from a standard D-SNP, what changed on 1/1/2026, what changes again in 2027 and 2030, and what to compare when you shop for a plan.

In This Guide

• 60-Second Version
• Sources Used
• Where a FIDE-SNP Fits: D-SNP, HIDE-SNP, CO-D-SNP
• What a FIDE-SNP Means for You
• Why the Old Medicare-Medicaid Plans Went Away
• What Changes in 2026, 2027, and 2030
• State-by-State Landscape
• Star Ratings and Plan Quality
• What FIDE-SNPs Cover and What You Pay
• Care Coordination Architecture
• 10 Common Family Pitfalls
• H.R. 1 and the Retroactive Coverage Sunset
• Three Worked Examples
• What to Watch in 2026-2027
• Where to Get Help
• Learn More

60-Second Version

On 1/1/2026 the seven states still running capitated MMPs moved those enrollees to integrated D-SNPs, and MMPs with no successor plan ended.1 The state table below has the per-state result.

On 1/1/2027 an organization that also runs a Medicaid managed-care plan in a service area may, with limited exceptions, offer only one D-SNP there for full-benefit duals, with new enrollment limited to members of its Medicaid plan, and applicable integrated plans must issue one member ID card and run one combined health risk assessment.3 H.R. 1 (Public Law 119-21) also shortens retroactive Medicaid coverage that day: one month before the application month for the ACA-expansion group, two months for most others.4

On 1/1/2030 those D-SNPs may only cover duals who are in the affiliated Medicaid plan, apart from a deemed continued-eligibility period.3

Sources Used

Regulatory framework: 42 CFR 422.2 (plan-type definitions), 422.107 (CMS-approved exceptions to FIDE-SNP benefit coverage) and 422.561 (integrated grievances and appeals).2 The D-SNP integration rules sit at 42 CFR 422.101(f), 422.514(h) and 422.52(d).3 The three SNP types appear at 42 CFR 422.4.5

Key rulemakings: CMS ended the MMP demonstration through rulemaking it finalized in 2022.1 The April 2024 CY2025 MA and Part D Final Rule (CMS-4205-F) set the D-SNP enrollment-alignment timeline.3 The retroactive-coverage change is in H.R. 1 / Public Law 119-21.4 This guide also draws on state Medicaid agency materials and MACPAC's analysis of the MMP transition.

Where a Medicare Fully Integrated Dual Eligible Special Needs Plan (FIDE-SNP) Fits: D-SNP, HIDE-SNP, and CO-D-SNP

A Special Needs Plan (SNP) is a Medicare Advantage plan that restricts enrollment to one category of beneficiary. There are three types: D-SNPs for dual eligibles, C-SNPs for people with a severe or disabling chronic condition, and I-SNPs for institutionalized people.6 The C-SNP conditions are the 22 categories 42 CFR 422.2 lists today.5 For a walkthrough of all three, see how Medicare Special Needs Plans work.

Within the D-SNP category, CMS ranks plans by how tightly they integrate with the state Medicaid program.

Coordination-Only D-SNP (CO-D-SNP)

Covers Medicare benefits only. Medicaid benefits, LTSS included, are reached separately through Medicaid fee-for-service or a different managed-care plan. The plan coordinates with the state Medicaid program, but financial integration is minimal.

Highly Integrated Dual Eligible SNP (HIDE-SNP)

A D-SNP whose parent organization (or an affiliate) holds a capitated Medicaid contract for primary and acute care plus either LTSS or behavioral health, not necessarily both. Medicare and Medicaid stay under separate contracts. Examples in 2026: Michigan's MI Coordinated Health7 and South Carolina's HIDE D-SNPs.8

Fully Integrated Dual Eligible SNP (FIDE-SNP)

Under 42 CFR 422.2, a FIDE-SNP is a D-SNP delivered through a single entity holding both an MA contract with CMS and a capitated Medicaid managed-care contract with the state. To the extent the state's Medicaid program covers them, and except where CMS approves otherwise under 42 CFR 422.107, that Medicaid contract must cover primary and acute care (including Medicare cost-sharing for plan year 2025 and later), Medicaid LTSS including at least 180 days of nursing-facility coverage during the plan year, and, for plan year 2025 and later, behavioral health, home health, and medical supplies and equipment. For 2025 and later the plan must also run Exclusively Aligned Enrollment (EAE), so every member is also in the affiliated Medicaid plan, with no mismatched enrollment. FIDE-SNPs are "applicable integrated plans" under 42 CFR 422.561, which merges Medicare and Medicaid grievances and appeals into one process instead of two.2

In practice that also means one Care Manager for both programs, one member-services line, and combined member materials. Two clarifications worth holding onto: every FIDE-SNP is a D-SNP but most D-SNPs are not FIDE-SNPs, and a FIDE-SNP is not PACE, which is a separate program under 42 CFR Part 460.9

What a Medicare Fully Integrated Dual Eligible Special Needs Plan (FIDE-SNP) Means for You

Strip out the regulation and the member experience is the point. A FIDE-SNP enrollee gets one plan card, one member-services number, one Care Manager who can see both the Medicare and the Medicaid side, one integrated appeal when something is denied, and, if they are in the QMB group, $0 Part A and Part B deductibles, coinsurance, and copays, because Medicare providers are not allowed to bill a QMB enrollee for services and items Medicare covers.2

Contrast that with the coordination-only world: a Medicare D-SNP card from one company, a Medicaid managed-care card from another, two prior-authorization queues, two appeal clocks, and no one person accountable for the gap between them.

The trade-off is a narrower network, because the plan has to align a Medicare network and a Medicaid network at once.

Why the Old Medicare-Medicaid Plans Went Away

The Financial Alignment Initiative was a CMS demonstration for dual eligibles. Most participating states used its capitated model, the Medicare-Medicaid Plan: one plan under a three-way contract among CMS, the state Medicaid agency and the health plan.1

In rulemaking finalized in 2022, CMS ended the FAI, letting states keep their MMPs through the end of 2025 only if they planned to move those enrollees into integrated D-SNPs.1 The most integrated form of D-SNP is the FIDE-SNP, a Medicare Advantage plan type defined at 42 CFR 422.2: one company holds both the Medicare Advantage contract with CMS and the Medicaid managed-care contract with the state.2

Some states left early. New York's FIDA demonstration ended 12/31/2019, and its enrollees moved to Medicaid Advantage Plus plans paired with aligned D-SNPs.10

What Changes for Dual-Eligible Plans in 2026, 2027, and 2030

Alongside sunsetting the demonstration, CMS used the CY2025 MA and Part D Final Rule (CMS-4205-F) to set a multi-year march toward a tightly aligned D-SNP market.3

Already in effect. Every FIDE-SNP must run Exclusively Aligned Enrollment; it is written into the 42 CFR 422.2 definition for plan year 2025 and later. In parallel, the D-SNP "look-alike" threshold, the share of a non-SNP Medicare Advantage plan's enrollment that is dually eligible, at or above which CMS will not enter into or renew the plan's contract, stepped down from 80% for plan year 2024 to 70% for plan year 2025 and to 60% for plan year 2026 and later. It is not written as a nationwide rule: 42 CFR 422.514(d) applies the limitation "in any state where there is a dual eligible special needs plan" or another plan CMS has authorized to enroll only people entitled to Medicaid.11

1/1/2027. Under 42 CFR 422.514(h), an MA organization (or its parent, or a commonly owned entity) is capped on how many D-SNP benefit packages it may offer in a service area alongside an affiliated Medicaid plan: in practice, one D-SNP per service area for full-benefit duals, with new enrollment limited to people in that Medicaid plan. The rule has narrow exceptions, for example where the state's Medicaid contract splits D-SNP enrollment by age group, or where the state does not require Medicaid managed care for all full-benefit duals and allows extra D-SNPs for people in Medicaid fee-for-service. Separate provisions require applicable integrated plans to carry one member ID card for both plans and one integrated health risk assessment by contract year 2027.3

1/1/2030. Under 42 CFR 422.514(h), those D-SNPs may only enroll or keep covering people who are also in the affiliated Medicaid plan, so continued coverage, not just new enrollment, turns on the match. The one carve-out is a deemed continued-eligibility period for a member who temporarily loses eligibility.3

If your loved one is in a CO-D-SNP today, expect fewer choices as organizations consolidate, expect to move either the D-SNP or the Medicaid plan if different companies run them, and read each annual notice of change.

State-by-State Landscape

This is the picture as of 1/1/2026. The federal definition each state builds on sits at 42 CFR 422.2.2

Plus other states' dual-eligible plan arrangements:

For each state's program in detail, see its state guide.

Star Ratings and Plan Quality

CMS rates Medicare Advantage plans, D-SNPs included, on a 1-to-5 star scale, and a contract at 4, 4.5, or 5 stars earns a 5% quality bonus payment added to its county rates (doubled in certain qualifying counties). A higher rating also lets a plan keep a larger share of its rebate, the money plans can spend on extra benefits, lower cost sharing, or a lower premium. Ratings appear in the Medicare Plan Finder at Medicare.gov. A five-star plan also carries its own enrollment right, usable once between December 8 and November 30 the following year.18

Ratings belong to a plan's contract, not to the plan type, so check the specific plan you are considering rather than assuming a FIDE-SNP scores well because of its category.

Also watch for the "low performing" icon, which Medicare Plan Finder puts on contracts with consistently low-quality ratings.18

What FIDE-SNPs Cover and What You Pay

On the Medicare side the plan pays for what Original Medicare would. That includes Part A inpatient hospital care, short-term skilled nursing facility care, hospice and some home health care,19 and Part B doctors' services, outpatient care, durable medical equipment and mental health services.20 It also covers Part D drugs through its own formulary. Most add the usual Medicare Advantage extras: dental, vision, hearing, an over-the-counter card, transportation, and meals after a hospital stay.

On the Medicaid side, under the capitated Medicaid contract, the same plan pays for LTSS (nursing-facility care plus home- and community-based services such as personal care attendants, adult day health, and assisted-living waiver services where a state offers them), behavioral health, and Medicaid-only extras such as routine non-emergency transportation.

What a full-benefit dual eligible actually pays:

• A $0 monthly premium, where a plan offers one, is a plan-design feature that varies by plan and state, not a legal guarantee, so confirm it plan by plan.2
• $0 Part A and Part B deductibles, coinsurance, and copays for someone in the QMB group, because Medicare providers are not allowed to bill a QMB enrollee for services and items Medicare covers. And for plan year 2025 and later, a FIDE-SNP's own capitated Medicaid contract must cover Medicare cost-sharing whether or not the member is in the QMB group.2
• Part D drugs are cheap but not always free. Extra Help (the Part D Low-Income Subsidy, administered by the Social Security Administration) sets three copay tiers for 2026. A full-benefit dual eligible pays $0 for every covered drug if they live in an institution or receive home and community-based services. One with income at or below 100% of the federal poverty level pays no more than $1.60 for a generic and $4.90 for a brand-name drug. One with income between 100% and 150% of poverty pays up to $5.10 per generic and $12.65 per brand-name drug, the same ceiling as other Extra Help enrollees. Copays drop to $0 once out-of-pocket drug costs reach the $2,100 annual threshold.21,2

The big exception: nursing-facility residents must contribute most of their monthly income, less a personal needs allowance, toward their care. That holds in any plan, or none.

A second exception is geographic. Extra Help is not available in Puerto Rico, the U.S. Virgin Islands, Guam, the Northern Mariana Islands, or American Samoa, so the Extra Help drug figures above do not describe what a dual eligible pays there. Call your State Medical Assistance (Medicaid) office about the other programs available in those areas.21

Care Coordination Architecture

The operational heart of a FIDE-SNP is a single accountable Care Manager, working inside the single-entity, exclusively aligned structure 42 CFR 422.2 requires.2 The title varies by state and plan: Care Coordinator, Service Coordinator, Geriatric Service Coordinator, Lead Care Manager. The job typically covers a comprehensive health assessment after enrollment, an individualized care plan spanning medical, behavioral health, LTSS and social needs, an interdisciplinary team that includes the member and family caregiver alongside the clinicians, hospital and nursing-facility discharge transitions, and authorization of waiver services.

LTSS authority is the sharpest difference from a CO-D-SNP. In a coordination-only plan, waiver authorizations come from a separate Medicaid case manager with no relationship to the Medicare plan. In a FIDE-SNP, the Care Manager holds authority across both. Behavioral health usually sits inside the same structure, which matters for a population with elevated rates of serious mental illness, depression, and dementia.

Massachusetts runs a variant: in SCO and One Care, a member with HCBS needs is assigned an Independent Living LTSS (ILLTSS) coordinator, usually based at an Aging Services Access Point, who authorizes the LTSS side. See Massachusetts SCO and One Care.

10 Common Family Pitfalls

1. Assuming every D-SNP is integrated. A coordination-only D-SNP covers Medicare only. Ask which tier a plan is, FIDE, HIDE, or coordination-only, before enrolling.
2. Confusing a FIDE-SNP with PACE. PACE is a separate program under 42 CFR Part 460, open only to people 55 or older who need a nursing-facility level of care, live in a PACE organization's service area, and can live safely in the community when they enroll.9
3. Assuming you can switch to any plan whenever you like. Dual eligibles get generous special enrollment rights, but they have limits. Since 1/1/2025, a full-benefit dual eligible can join an integrated D-SNP in any month only to line it up with their Medicaid managed-care plan, and can pick a standalone Part D drug plan in any month.7 For any other change, confirm your window with your State Health Insurance Assistance Program first.
4. Trading a FIDE-SNP for a less integrated plan and losing the Care Manager. A switch almost always breaks that relationship, and the new plan's coordination duties are weaker.
5. Checking only the doctors. FIDE-SNP networks are narrow. Check the physicians and the LTSS providers: the personal care agency, the adult day program.
6. Assuming the nursing facility is in network. It usually is. Confirm it anyway; FIDE-SNPs contract with specific facilities.
7. Letting Medicaid renewal lapse. Losing Medicaid, even briefly, can get a member involuntarily disenrolled. If the plan expects the member to regain eligibility within six months, it keeps them through a deemed-continued-eligibility period it sets anywhere from 30 days to six months. Ask how long yours runs.22
8. Not using the integrated appeal. FIDE-SNP appeals follow the applicable-integrated-plan rules at 42 CFR 422.561, combining Medicare and Medicaid into one process instead of two. That is a member protection, so use it.2
9. Enrolling two dual-eligible spouses in different plans. The same plan means a shared Care Manager and far less coordination work.
10. Not asking about supplemental benefits. Integrated capitation usually funds richer dental, vision, hearing and transportation benefits than a standalone D-SNP. Ask specifically.

H.R. 1 (2025) and the Retroactive Coverage Sunset

Federal law today requires every state Medicaid program to cover services furnished as far back as the third month before the month of application, if the person would have been eligible then. The statute is section 1902(a)(34) of the Social Security Act, implemented at 42 CFR 435.915(a). That is an outer boundary, not a start date: 435.915(c) leaves each state's plan to set the exact effective date inside the window, and a Section 1115 demonstration can shorten what a state provides. Confirm your own state's window with its Medicaid agency. H.R. 1, the 2025 reconciliation law (Public Law 119-21), shortens that window for applications made on or after 1/1/2027: to two months before the application month for most enrollees, and one month for the ACA Medicaid expansion adult group.4

Most dual eligibles qualify through an aged or disabled pathway, so the two-month limit is the one that will bite. Apply as early as you reasonably can: the three-month cushion is going away, and an application that takes weeks to process no longer has as much room behind it. For state timelines, see the state guides, such as Massachusetts income limits.

Three Worked Examples

Maria, 78, Massachusetts SCO member (integrated D-SNP)

Maria is a Spanish-speaking widow in East Boston with Medicare Parts A, B and D, MassHealth Standard, congestive heart failure, and mild cognitive impairment. Through 2025 she carried a Medicare D-SNP card from one company, a MassHealth managed-care card from another, and HCBS services authorized by an ASAP case manager, with no single point of contact.

On 1/1/2026, every SCO enrollee had to hold both Medicare Parts A and B plus MassHealth Standard to stay in a SCO plan; members who lacked both parts moved to MassHealth fee-for-service that day, keeping MassHealth Standard. That move is not a one-way door: MassHealth says a member who later gets Parts A and B can call (800) 841-2900, or a SCO plan directly, to weigh going back. But fee-for-service assigns no care coordinator, and MassHealth points members who need one to the Frail Elder Waiver through their local ASAP.12 SCO runs for 2026 as an applicable integrated plan jointly overseen by CMS and the state,23 not a designated FIDE-SNP; that requirement sits in the One Care contract, for duals who enroll between ages 21 and 64.10 Maria had both parts, so she now has one plan card, one Geriatric Service Coordinator, an ILLTSS coordinator at her ASAP for personal-care authorizations, member services in Spanish at one number, and one appeals process. When she was hospitalized in March 2026 for a heart-failure exacerbation, the coordinator convened a discharge meeting two days ahead with her physicians, the rehab facility, the ILLTSS coordinator, and her daughter Carmen. Under the old split arrangement, those transitions had gone badly every time.

James, 67, California Medi-Medi Plan member (EAE D-SNP)

James lives in one of the 29 California counties where Medi-Medi Plans first became available in 2026, with Medicare Parts A, B and D and full-scope Medi-Cal, on dialysis for end-stage renal disease. Through 2025 his D-SNP and his Medi-Cal plan came from different companies. A Medi-Medi Plan is an exclusively aligned D-SNP: its members must also be in its affiliated Medi-Cal plan, and it provides care coordination and integrated member materials. If James ever loses Medi-Cal, the plan must keep him for at least a three-month deeming period.13 His personal care hours still flow through county-run In-Home Supportive Services.

Robert, 71, Ohio Next Gen MyCare member (FIDE-SNP)

Robert is an Air Force veteran in Cleveland with Medicare Parts A, B and D, Ohio Medicaid, COPD, and depression. On 1/1/2026 his MyCare Ohio MMP ended and he moved into Next Gen MyCare, Ohio's FIDE-SNP architecture.2 Little changed from his side: same plan brand, same Care Manager, same providers, a new ID card and member-services number. His daughter did notice one thing: the Part D formulary shifted at the transition and one of his inhalers moved tiers. The Care Manager helped her file a formulary exception.

What to Watch in 2026-2027

• The look-alike threshold. The look-alike ladder codified at 42 CFR 422.514(d) still reads 60% for plan year 2026 and subsequent years.11
• H.R. 1 implementation. The shorter retroactive-coverage limits apply to Medicaid applications made on or after 1/1/2027.4
• State Medicaid contract cycles. What a FIDE-SNP actually covers is written into each state's Medicaid contract, so watch state RFPs and amendments.
• The 2030 alignment. From 2030, these D-SNPs may only enroll or keep covering people who are also in the affiliated Medicaid plan, so read every notice your plan sends before then.3

Where to Get Help

• Your State Health Insurance Assistance Program (SHIP) gives free, unbiased Medicare counseling, including side-by-side D-SNP comparison. Find yours through the locator at shiphelp.org, which also lists 877-839-2675, or the per-state phone directory in the back of Medicare & You 2026. Many states run theirs under another name, such as HICAP, SHINE, SHICK, or VICAP.24
• Medicare Plan Finder at Medicare.gov lets you view and compare plans' star ratings before you enroll.18
• The CMS Medicare-Medicaid Coordination Office (the Federal Coordinated Health Care Office) owns federal dual-eligible and D-SNP policy.2
• National organizations publishing free consumer or policy material on dual-eligible issues: the Medicare Rights Center, Justice in Aging, the Center for Medicare Advocacy, MedPAC and MACPAC, and the SNP Alliance.

Learn More

Find personalized help comparing Medicare and Medicaid dual-eligible coverage 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.