What You Need to Know About FIDE-SNPs (Dual-Eligible Plans)

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 and Medicaid Services (CMS) sunset its decade-long Financial Alignment Initiative (FAI) on 12/31/2025, ending the Medicare-Medicaid Plan (MMP) demonstration that roughly 235,000 dual-eligible Americans had been enrolled in. The successor architecture is the Fully Integrated Dual Eligible Special Needs Plan, the FIDE-SNP, which CMS has positioned as the "high-integration" tier of dual-eligible coverage going forward.

This guide explains what a FIDE-SNP is, how it differs from a standard D-SNP, what changed for families on 1/1/2026, what is changing again on 1/1/2027 and 1/1/2030, and what to look for when comparing FIDE-SNP plans in the state where your loved one lives. This is a federal-level reference; for state-specific details, see the linked state guides at the end of each section.

In This Guide

• 60-Second Version
• Sources Used
• The SNP Taxonomy: D-SNP, FIDE-SNP, HIDE-SNP, CO-D-SNP
• What "Fully Integrated" Actually Means: 42 CFR 422.2
• The Financial Alignment Initiative and Why It Ended
• The CY2025 D-SNP Final Rule and the EAE Timing Waterfall
• State-by-State Landscape (10+ States)
• Major National Plan Sponsors
• 2026 Star Ratings and Plan Quality
• Benefit Package Mechanics: What FIDE-SNPs Cover and How Cost-Sharing Works
• Care Coordination Architecture
• 10 Common Family Pitfalls
• H.R. 1 (2025) and the Coming Retroactive Coverage Sunset
• Three Worked Examples
• Pending Policy and What to Watch in 2026-2027
• Federal Advocacy and Help Resources
• Learn More

60-Second Version

Sources Used

This guide draws on federal regulations, CMS rulemakings, state agency policy memos, and analyses from MACPAC, ATI Advisory, Justice in Aging, the Medicare Rights Center, Center for Medicare Advocacy, the SNP Alliance, and the Integrated Care Resource Center (ICRC). The corresponding atomic fact (library/facts/medicare-dual-eligible/medicare-fide-snp-federal-2026.json) catalogs all 30+ source citations with confidence ratings.

Primary regulatory framework: 42 CFR 422.2 (definitions), 42 CFR 422.4 (MA plan types), 42 CFR 422.52 (D-SNP eligibility), 42 CFR 422.101(f) (D-SNP requirements), 42 CFR 422.107 (D-SNP integration with state Medicaid), 42 CFR 422.514(h) (Exclusively Aligned Enrollment), 42 CFR 422.561 (Applicable Integrated Plan definitions), 42 CFR 438.210/400/402 (Medicaid managed-care grievance and appeal). Statutory authority for the FAI demonstration was §1115A of the Social Security Act.

Key rulemakings: CY2023 MA/Part D Final Rule (87 FR 27704, May 9, 2022) terminated the FAI MMP demonstration. CY2025 MA/Part D Final Rule (89 FR 30448, April 23, 2024) established the EAE timing waterfall. CY2027 MA/Part D Proposed Rule (FR 2025-21456, November 28, 2025) declined to implement the EHO4All Health Equity Index. Statutory: H.R. 1 / Budget Reconciliation Act of 2025 (signed 7/4/2025).

The SNP Taxonomy: D-SNP, FIDE-SNP, HIDE-SNP, CO-D-SNP

A Special Needs Plan (SNP) is a type of Medicare Advantage plan that restricts enrollment to a specific category of beneficiary. Under 42 CFR 422.4, three SNP categories exist:

• D-SNP (Dual Eligible Special Needs Plan), restricts enrollment to dual eligibles
• C-SNP (Chronic Condition SNP), restricts enrollment to people with one of 15 CMS-listed chronic conditions
• I-SNP (Institutional SNP), restricts enrollment to people who reside in (or need the level of care of) a nursing facility for 90+ days

Within the D-SNP category, CMS has further subcategorized plans by their level of integration with the state Medicaid program. From least to most integrated:

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

Sometimes called a "C-SNP D-SNP" or simply "non-integrated D-SNP." These plans cover Medicare benefits only. Medicaid benefits, including LTSS, are accessed separately through Medicaid Fee-for-Service or a separate Medicaid managed-care plan (MCO). The plan must have a State Medicaid Agency Contract (SMAC) under 42 CFR 422.107 establishing minimum care-coordination requirements, but the financial integration is minimal.

This is the most common form of D-SNP nationally. As of 2026, most D-SNPs in most states are CO-D-SNPs.

Highly Integrated Dual Eligible SNP (HIDE-SNP)

Defined under 42 CFR 422.2 as a D-SNP whose parent organization (or a parent's affiliate) holds a capitated Medicaid managed-care contract for primary care and acute care, plus EITHER LTSS OR behavioral health (but not necessarily both). HIDE-SNPs are required to coordinate care across the two programs but operate under separate Medicare and Medicaid contracts.

Examples in 2026: Michigan Coordinated Health, South Carolina HIDE-SNPs, Texas STAR+PLUS-aligned HIDE-SNPs.

Fully Integrated Dual Eligible SNP (FIDE-SNP)

Defined under 42 CFR 422.2 as a D-SNP whose parent organization holds a capitated Medicaid contract that covers, at minimum: primary care, acute care, behavioral health, and Medicaid LTSS (institutional and home- and community-based services). The Medicare and Medicaid contracts must be operated by the same parent organization, with Exclusively Aligned Enrollment (EAE), meaning every enrollee is enrolled in both the Medicare D-SNP and the corresponding Medicaid managed-care plan operated by the same organization.

A FIDE-SNP must also meet structural requirements:

• A single Care Manager assigned to each enrollee with responsibility for both Medicare and Medicaid services
• Integrated grievance and appeals processes meeting the requirements of 42 CFR 422.561 ("Applicable Integrated Plan" rules)
• Integrated Member Services (a single 1-800 line covering both programs)
• An Integrated Summary of Benefits and Integrated Member Materials

FIDE-SNP is the most integrated tier CMS recognizes and is the architecture CMS is signaling will become the long-term standard for full dual-eligibles.

Quick disambiguation

• D-SNP vs FIDE-SNP: All FIDE-SNPs are D-SNPs. Not all D-SNPs are FIDE-SNPs.
• MMP vs FIDE-SNP: MMPs were a separate demonstration plan type that operated under §1115A (not Medicare Advantage). MMPs ended 12/31/2025. FIDE-SNPs are Medicare Advantage plans, which gives them a stable regulatory foundation that MMPs lacked.
• PACE vs FIDE-SNP: PACE (Programs of All-Inclusive Care for the Elderly) is a separate, smaller program for people 55+ who meet nursing-facility level of care. PACE is fully capitated for both Medicare and Medicaid like a FIDE-SNP, but operates under different statutory authority (42 CFR Part 460).

What "Fully Integrated" Actually Means: 42 CFR 422.2

"Fully integrated" is a legal term of art. To meet the FIDE-SNP definition under 42 CFR 422.2, a plan must satisfy all of the following:

1. Single parent organization holds both contracts. The Medicare Advantage contract (for the D-SNP) and the Medicaid managed-care contract (for the comprehensive Medicaid benefit) must be held by the same parent organization or affiliated entities under common ownership and control.

2. The Medicaid contract is comprehensive. It must cover primary and acute care, behavioral health (mental health and substance use disorder services), AND Medicaid long-term services and supports, both nursing-facility care and home- and community-based services (HCBS).

3. Exclusively Aligned Enrollment. Per 42 CFR 422.514(h), every member of the FIDE-SNP must be enrolled in the affiliated Medicaid managed-care plan, and every enrollee in the affiliated Medicaid plan who is also enrolled in Medicare must be in the FIDE-SNP. There is no mismatched enrollment.

4. Care management is integrated. A single Care Manager (sometimes called a Care Coordinator, Service Coordinator, or Geriatric Service Coordinator depending on the state) is responsible for the member's full care plan across Medicare and Medicaid.

5. Member services are integrated. A single phone line, a single ID card (or coordinated cards), an integrated formulary, an integrated explanation of benefits, and an integrated grievance process.

6. Appeals follow Applicable Integrated Plan rules under 42 CFR 422.561. A single appeals process for combined Medicare/Medicaid services, with the Medicare standards (which are more enrollee-protective) generally controlling.

The practical consequence: a member of a FIDE-SNP receives one bill for cost-sharing (typically $0 because most full duals have no Medicare cost-sharing under QMB or full-Medicaid status), one Member Services number to call, one Care Manager who knows their full picture, and one grievance/appeals process if something goes wrong.

This is a sharp contrast with the Coordination-Only D-SNP world, where a member might have a Medicare D-SNP plan card from one company, a Medicaid MCO plan card from a different company, separate prior authorizations, separate appeal deadlines, and no single person responsible for coordinating between them.

The Financial Alignment Initiative and Why It Ended

To understand the FIDE-SNP story, you need to understand what came before.

What was the FAI?

The CMS Financial Alignment Initiative (FAI) was a §1115A demonstration authorized by the Affordable Care Act and launched in 2013-2015 in 13 states. Its purpose was to test whether integrating Medicare and Medicaid financing for dual-eligibles could produce better outcomes at lower cost. Two integration models were authorized:

• Capitated Model (Medicare-Medicaid Plans, "MMPs"), Plans received a single capitated payment combining Medicare and Medicaid funding. CMS, the state, and the plan jointly managed risk. Operated in California, Illinois, Massachusetts, Michigan, New York (FIDA), Ohio, Rhode Island, South Carolina, Texas (Bexar/Dallas/El Paso/Harris/Hidalgo/Tarrant), and Virginia. Note: Each state's MMP demonstration had its own start and end dates; New York's FIDA terminated 12/31/2019 and Virginia's MMP terminated 12/31/2017, well before the FAI broadly sunset in 2025.
• Managed Fee-for-Service Model, States retained traditional Medicare FFS but received a share of Medicare savings for Medicaid coordination activities. Operated in Washington and Colorado.

At its peak, the capitated MMP demonstration served roughly 400,000 dual-eligibles. By mid-2025, ~235,000 enrollees remained.

Why CMS ended the demonstration

CMS announced in the CY2023 MA/Part D Final Rule (87 FR 27704, May 9, 2022) that it would not renew MMPs beyond 12/31/2025. CMS's rationale, summarized:

1. The FIDE-SNP framework had matured to the point where it could absorb most MMP enrollees with comparable integration, while sitting inside the more durable Medicare Advantage regulatory structure rather than a one-off §1115A demonstration that required periodic renewal.
2. MMPs created confusion. The same parent organization might offer an MMP, a D-SNP, and a Medicaid MCO in the same state, with overlapping but not identical benefit packages. Consolidating into FIDE-SNPs (or HIDE-SNPs in less-integrated states) reduced this complexity.
3. The §1115A demonstration authority was a temporary structure. Continuing to extend it created year-over-year operational uncertainty for plans, states, and members.

What happened on 12/31/2025

The ten remaining capitated MMP states had to make a decision. Each took a different path:

• Massachusetts moved its One Care program (under-65 duals) and Senior Care Options program (65+ duals) to the FIDE-SNP framework under a new five-year EOHHS contract through 12/31/2030.
• Illinois consolidated MMPs into FIDE-SNPs.
• Ohio transitioned MMPs to "Next Gen MyCare", a FIDE-SNP architecture.
• California shifted to "Medi-Medi Plans", Exclusively Aligned Enrollment D-SNPs that meet HIDE-SNP or FIDE-SNP thresholds depending on county. Expanded from 12 counties to 41 counties starting 2026.
• New York had already terminated FIDA in 2019; current Medicaid Advantage Plus (MAP) plans operate as FIDE-SNPs.
• Michigan transitioned to "Coordinated Health", a HIDE-SNP framework, not FIDE-SNP. (This was a deliberate state design choice; Michigan did not include LTSS in the capitated Medicaid product.)
• South Carolina transitioned to HIDE-SNPs.
• Texas transitioned to HIDE-SNPs aligned with STAR+PLUS for the Medicaid LTSS side.
• Rhode Island ended its Integrated Care Initiative MMP without a direct FIDE-SNP successor; some enrollees moved to standard D-SNPs.
• Virginia's MMP had already ended in 2017; the 2024 Appropriations Act now requires all Virginia D-SNPs to be FIDE-SNPs.

This is the single largest reorganization of dual-eligible coverage since Medicare Part D launched in 2006.

The CY2025 D-SNP Final Rule and the EAE Timing Waterfall

In parallel with sunsetting the MMP demonstration, CMS issued the CY2025 MA and Part D Final Rule (89 FR 30448, April 23, 2024) establishing a multi-year transition to a much more tightly aligned D-SNP landscape.

The three key dates

1/1/2025 (already in effect): All FIDE-SNPs must operate on Exclusively Aligned Enrollment. This was already largely the case as a definitional matter, but the rule made it explicit and added enforcement.

1/1/2027 (next major change):

• A parent organization may offer only one D-SNP per contracting state that limits enrollment to full-benefit dual eligibles (FBDE). Parent organizations with multiple FBDE-restricted D-SNPs in the same state must consolidate.
• The D-SNP look-alike threshold drops from 70% to 60%. (A "look-alike" is a Medicare Advantage plan that, while not formally a D-SNP, has a sufficiently high concentration of dual-eligibles that CMS treats it as one for certain regulatory purposes.)

1/1/2030 (final phase):

• Dual-eligibles enrolled in a D-SNP whose parent organization is not the same as their Medicaid managed-care plan parent organization will be disenrolled and offered an aligned alternative. This effectively forces the entire D-SNP market into Exclusively Aligned Enrollment over the next four years.

What this means for families

If your loved one is a dual-eligible currently enrolled in a Coordination-Only D-SNP, between now and 1/1/2030 you should expect that:

1. The set of available D-SNPs in your state will narrow as parent organizations consolidate to one D-SNP per state.
2. If your D-SNP and your Medicaid MCO are run by different parent organizations, you'll eventually need to either switch your D-SNP to an aligned plan or switch your Medicaid MCO. CMS will provide a transition window with default enrollment options.
3. The federal direction is clear: one parent organization, one Care Manager, one integrated plan. CO-D-SNPs as a category are being phased out in favor of HIDE-SNPs and FIDE-SNPs.

State-by-State Landscape (10+ States)

This table summarizes the FIDE-SNP architecture in each state with significant dual-eligible integration as of 1/1/2026.

Plus the "native FIDE-SNP" states, those that established FIDE-SNPs without an MMP predecessor:

For a more detailed write-up of each state's program, see the linked state guides.

Major National Plan Sponsors

The largest D-SNP sponsors operating FIDE-SNP or HIDE-SNP products across multiple states in 2026:

• UnitedHealthcare, the largest dual-eligible plan sponsor nationally. Operates D-SNP, HIDE-SNP, and FIDE-SNP variants in most integrated states.
• Humana, significant D-SNP footprint, particularly strong in Florida, Texas, Tennessee.
• Centene (Wellcare, Fidelis, etc.), major presence in New York (Fidelis MAP), California, Texas, and others.
• Anthem (Elevance Health), operates D-SNPs in California, New York, Virginia, and several others.
• Molina Healthcare, active in California, Michigan, South Carolina, Texas.
• Aetna / CVS Health, broad national D-SNP footprint.
• CareSource, strong presence in Ohio (Next Gen MyCare), Indiana, Kentucky.
• Regional plans, In many states, regional non-profits remain dominant: Commonwealth Care Alliance and Senior Whole Health (Molina) in Massachusetts, VNS Health and MetroPlus in New York, BlueCross BlueShield of Tennessee (BlueCare Plus) in Tennessee, etc.

The market is consolidating rapidly. The CY2025 Final Rule's "one D-SNP per state per parent" requirement will further compress the landscape between now and 1/1/2027.

2026 Star Ratings and Plan Quality

CMS rates Medicare Advantage plans (including D-SNPs and FIDE-SNPs) on a 5-star scale. Plans rated 4 stars or higher receive Quality Bonus Payments (QBPs) that they typically pass through as enhanced benefits.

The 2026 Star Ratings landscape (released October 2025) for D-SNPs:

• D-SNP Star Ratings have generally lagged non-SNP MA plans for structural reasons, the dual-eligible population has higher acuity, more social determinants of health barriers, and historically lower preventive-care quality scores.
• The Health Equity Index (HEI), added to Star Ratings calculations starting 2027 measurement year, was designed to give plans credit for serving low-income/disabled populations and was expected to materially improve D-SNP scores.
• However, the CY2027 MA/Part D Proposed Rule (FR 2025-21456, November 28, 2025) declined to implement the EHO4All version of the Health Equity Index. The future of HEI scoring beyond 2027 is uncertain.
• For 2026 plans, the average D-SNP Star Rating sits at approximately 3.5 stars; FIDE-SNPs average slightly higher (~3.75 stars) due to their care-coordination infrastructure and lower disenrollment rates.

What families should look for:

1. The plan's overall Star Rating (4+ is the typical "high-quality" benchmark).
2. The plan's member experience scores, specifically "Getting Care Quickly" and "Care Coordination."
3. The plan's complaint rate per 1,000 members. FIDE-SNPs with strong Care Manager infrastructure typically score better here.
4. The plan's Medicaid disenrollment rate, a high disenrollment rate often signals operational issues with the Medicaid side.

CMS publishes Star Ratings at medicare.gov/plan-compare. Each state's SHIP (State Health Insurance Assistance Program) can walk families through plan comparison at no cost.

Benefit Package Mechanics: What FIDE-SNPs Cover and How Cost-Sharing Works

A FIDE-SNP covers essentially everything a Medicare-Medicaid dual-eligible would otherwise need. Specifically:

Medicare side (paid by the FIDE-SNP)

• Medicare Part A, inpatient hospital, skilled nursing facility (SNF) care, hospice, some home health.
• Medicare Part B, physician services, outpatient care, durable medical equipment, lab work, mental health.
• Medicare Part D, prescription drugs through the plan's formulary. (Important: the FIDE-SNP must offer Part D; standalone Part D plans cannot be paired with a FIDE-SNP.)
• Supplemental MA benefits, typically including dental, vision, hearing, OTC card, transportation, fitness benefits (Silver Sneakers or equivalent), meals after hospital discharge.

Medicaid side (also paid by the FIDE-SNP under the capitated Medicaid contract)

• Long-term services and supports (LTSS), both nursing facility care and home- and community-based services (HCBS) including personal care attendant services, adult day health, assisted living waiver services where applicable.
• Behavioral health, mental health and substance use disorder treatment, often with broader coverage than Medicare alone provides.
• Medicaid-only services, services Medicare doesn't cover such as routine non-emergency medical transportation, expanded vision/dental/hearing, and over-the-counter items.
• Medicare cost-sharing, for most full-dual-eligibles, the Medicaid program covers Medicare deductibles, coinsurance, and copays (the QMB or "full-dual" benefit). Inside a FIDE-SNP, this happens automatically; the member sees $0 copays at the point of service.

What members typically pay

For a full-dual-eligible enrolled in a FIDE-SNP, the typical out-of-pocket cost is:

• $0 monthly Medicare premium (covered by Medicaid/Medicare Savings Program).
• $0 deductibles for Part A and Part B (covered by Medicaid).
• $0 to $1.55 for generic prescription drugs, $0 to $4.60 for brand-name drugs (2026 LIS copays).
• $0 copays for medical services.

The major exception: residents of nursing facilities are typically required to contribute most of their monthly income (other than a Personal Needs Allowance) toward the cost of their care. This is true regardless of whether they're enrolled in a FIDE-SNP, a HIDE-SNP, a CO-D-SNP, or no MA plan at all.

Care Coordination Architecture

The defining operational feature of a FIDE-SNP is integrated care management. The standard architecture:

The Care Manager

Each enrollee is assigned a Care Manager (sometimes titled Care Coordinator, Service Coordinator, Geriatric Service Coordinator, or Lead Care Manager, terminology varies by state and plan). Responsibilities typically include:

• Conducting an initial Comprehensive Health Assessment within 90 days of enrollment.
• Developing an Individualized Care Plan (ICP) that addresses medical, behavioral health, LTSS, and social-determinants needs.
• Convening an Interdisciplinary Care Team (ICT), usually including the Care Manager, primary care physician, behavioral health provider, LTSS coordinator, member, and family caregiver.
• Coordinating transitions of care, particularly hospital and SNF discharges, where dual-eligibles experience high readmission rates.
• Authorizing and arranging HCBS waiver services, personal care attendants, adult day health, home modifications, etc.
• Connecting members to social-determinants resources, food, housing, transportation, utility assistance.

LTSS coordination

LTSS coordination is the single most differentiated feature of a FIDE-SNP versus a CO-D-SNP. Inside a CO-D-SNP, the member's HCBS waiver authorizations are made by a separate Medicaid case manager who often has no direct relationship with the Medicare plan. Inside a FIDE-SNP, the Care Manager has authority across both programs.

Behavioral health integration

Most FIDE-SNPs integrate behavioral health into the same care-management infrastructure. This is critical for the dual-eligible population, which has elevated rates of serious mental illness, depression, substance use disorder, and dementia. Plans typically employ behavioral health Care Managers who collaborate with the medical Care Manager.

Massachusetts-specific: ILLTSS

In Massachusetts, SCO and One Care use a structure called Independent Living Long-Term Services and Supports (ILLTSS) coordination, every member with HCBS needs is assigned an ILLTSS coordinator (typically based at an Aging Services Access Point / ASAP) who serves as the primary LTSS authorizer. See /medicaid/massachusetts/sco-and-one-care for the full Massachusetts model.

10 Common Family Pitfalls

After working through hundreds of FIDE-SNP enrollment scenarios, the same handful of mistakes show up over and over. Here are the ten most common, and how to avoid them.

1. Assuming all D-SNPs are integrated. They are not. A Coordination-Only D-SNP (CO-D-SNP) covers Medicare benefits only; Medicaid services are accessed separately. Always confirm whether a plan is a FIDE-SNP, HIDE-SNP, or CO-D-SNP before enrolling.

2. Confusing FIDE-SNP with PACE. Both are fully capitated for Medicare and Medicaid, but PACE is a separate program (42 CFR Part 460), is restricted to age 55+ with NF level of care, and uses a fundamentally different care delivery model (the PACE day center). Most dual-eligibles cannot enroll in PACE and should look at FIDE-SNPs first.

3. Missing the FIDE-SNP enrollment window. Special Election Periods (SEPs) for dual-eligibles are generous, quarterly SEPs in the first three quarters of the year, plus an annual MA Open Enrollment Period (1/1-3/31), plus the Annual Enrollment Period (10/15-12/7). But there are still windows where you cannot switch.

4. Switching to a CO-D-SNP and losing your existing Care Manager. If your loved one has an established Care Manager through a FIDE-SNP, switching to a less-integrated plan will almost always disrupt that relationship. The new plan's care coordination obligations are weaker.

5. Not checking whether your provider is in the FIDE-SNP network. FIDE-SNP networks are typically narrower than non-SNP MA plans because they need to align with both Medicare and Medicaid networks. Always check both the medical provider and the LTSS provider (e.g., personal care agency).

6. Assuming the FIDE-SNP automatically covers your nursing facility. It probably does, but always confirm. FIDE-SNPs contract with specific NFs; if your loved one's NF is out-of-network, you may need to either change facilities or switch plans.

7. Failing to renew Medicaid eligibility on time. A member who loses Medicaid even briefly can be involuntarily disenrolled from the FIDE-SNP. Most FIDE-SNPs have a deemed-continued-eligibility period of 1-6 months, but this is not unlimited.

8. Not understanding the appeals process. FIDE-SNP appeals follow Applicable Integrated Plan rules (42 CFR 422.561), which combine Medicare and Medicaid appeals into a single process with Medicare-style timelines. This is a member protection, don't waive it.

9. Letting a non-aligned spouse enroll in a different plan. If both spouses are dual-eligible, enrolling them in the same FIDE-SNP gives them a shared Care Manager and easier care coordination. Different plans = different Care Managers = harder coordination.

10. Not asking about supplemental benefits. FIDE-SNPs typically offer richer supplemental benefits (dental, vision, hearing, OTC card, transportation) than standalone D-SNPs because the integrated capitation supports them. Ask specifically about flexible benefits.

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

A major legislative change to be aware of: H.R. 1, the Budget Reconciliation Act of 2025 (signed 7/4/2025), limits retroactive Medicaid coverage starting 1/1/2027:

• For ACA-expansion enrollees: retroactive coverage limited to 1 month before the application month.
• For aged/disabled enrollees (including most dual-eligibles): retroactive coverage limited to 2 months before the application month.

This replaces the longstanding 3-month retroactive window under 42 CFR 435.915. KFF estimates this change will result in approximately 1.3 million fewer dual-eligibles by 2034, primarily because some seniors who would have qualified retroactively will fall through the cracks during the application processing period.

For families: apply for Medicaid as soon as you reasonably can. Don't wait. The 3-month retroactive cushion that seniors have relied on for decades is going away.

For state-specific implementation timelines, see the relevant state Medicaid eligibility guides (e.g., /medicaid/massachusetts/eligibility-income-limits).

Three Worked Examples

Example 1: Maria, 78, Massachusetts SCO member (FIDE-SNP)

Maria is a Spanish-speaking widow living in East Boston. She has Medicare Parts A, B, and D and qualifies for MassHealth Standard. She has Type 2 diabetes, congestive heart failure, and mild cognitive impairment. Her daughter Carmen lives in Revere and helps her with appointments.

Before 2026, Maria was enrolled in a Coordination-Only D-SNP. She had:

• A Medicare D-SNP card from one company
• A MassHealth MCO card from a different company (for Medicaid services)
• Her HCBS waiver services authorized by an ASAP case manager
• No single point of contact

Effective 1/1/2026, Maria's plan converted to a FIDE-SNP under the new EOHHS five-year contract. Now she has:

• A single SCO plan card
• A single Geriatric Service Coordinator (GSC) at her plan
• An ILLTSS coordinator at her local ASAP for personal-care-attendant authorizations
• Integrated Member Services in Spanish at one phone number
• A single appeals process

Carmen reports that the difference is dramatic: when Maria was hospitalized in March 2026 for a CHF exacerbation, the GSC convened a discharge ICT meeting two days before discharge with Maria's PCP, cardiologist, the SNF that would receive her for short-term rehab, the ILLTSS coordinator, and Carmen. The hospital-to-SNF transition went smoothly. Under the prior fragmented arrangement, transitions of care had been a recurring nightmare.

Example 2: James, 67, California Medi-Medi Plan member (EAE D-SNP)

James lives in Fresno County. He has Medicare Parts A, B, and D and full-scope Medi-Cal. He has end-stage renal disease (on dialysis) and Type 2 diabetes.

In 2025, Fresno County was not part of the original 12-county Cal MediConnect demonstration (which ended 12/31/2022). James was enrolled in a CO-D-SNP and Fresno County Organized Health System Medi-Cal plan, run by different parent organizations.

Effective 1/1/2026, the California Medi-Medi Plan framework expanded from 12 to 41 counties, including Fresno. James's plan parent organization (UnitedHealthcare, in this hypothetical) now operates an aligned Medi-Medi Plan in Fresno. James's MA plan and his Medi-Cal plan now have the same parent organization.

The Medi-Medi Plan in Fresno meets the HIDE-SNP threshold but not full FIDE, California chose to phase in LTSS integration county-by-county. James will see most of the integration benefits (single Care Manager, integrated Member Services) but his LTSS authorizations still flow through county-administered IHSS rather than the plan.

Example 3: Robert, 71, Ohio Next Gen MyCare member (FIDE-SNP)

Robert is a U.S. Air Force veteran living in Cleveland. He has Medicare Parts A, B, D, and Ohio Medicaid. He has chronic obstructive pulmonary disease (COPD), depression, and was recently hospitalized for a hip fracture.

Before 1/1/2026, Robert was in MyCare Ohio, an MMP under the FAI demonstration. On 1/1/2026, MyCare Ohio terminated as an MMP and Robert was passively enrolled in Next Gen MyCare, Ohio's new FIDE-SNP architecture.

The transition was largely seamless from Robert's perspective:

• Same plan brand name (CareSource, in this hypothetical)
• Same Care Manager (transferred from MMP to FIDE-SNP under continuity rules)
• Same provider network
• Slightly different ID card and Member Services number
• New Annual Notice of Change reflecting CY2026 benefits

Robert's daughter, who navigates his care with him, noticed that his Part D formulary updated at the transition and one of his inhalers is now on a different tier. The FIDE-SNP Care Manager helped her file a formulary exception request.

Pending Policy and What to Watch in 2026-2027

Active rulemaking and policy issues that will shape the FIDE-SNP landscape over the next 24 months:

CY2027 Final Rule (expected April 2026)

The CY2027 MA/Part D Proposed Rule (FR 2025-21456, November 28, 2025) is currently in comment period. Key expected provisions:

• No EHO4All Health Equity Index implementation, per the proposed rule. This is consequential for D-SNPs because HEI was projected to materially boost D-SNP Star Ratings.
• Continued enforcement of the CY2025 timing waterfall (one D-SNP per state per parent for FBDE-only plans, look-alike threshold drop to 60%).
• Possible refinements to FIDE-SNP definition and EAE rules.

Final rule expected late spring 2026.

CY2028 Notice of Methodologies (NOM)

Released annually in early February. Will contain final 2027 D-SNP risk adjustment factors and any refinements to the FIDE-SNP / HIDE-SNP definitional thresholds.

State Medicaid contract renegotiations

Massachusetts's five-year EOHHS SCO/One Care contract runs through 12/31/2030. Other states have shorter contracting cycles. Watch for state-level RFPs and contract amendments, they materially shape what a "FIDE-SNP" looks like in each state.

H.R. 1 implementation

Federal CMS guidance on H.R. 1 retroactive-coverage limits is expected throughout 2026. State Medicaid agencies will issue conforming State Plan Amendments. The 1/1/2027 effective date is firm.

CY2030 disenrollment of non-aligned duals

This is the final phase of the CY2025 Final Rule's transition. Between now and 1/1/2030, CMS will issue subregulatory guidance on default-enrollment mechanics, member communications, and continuity-of-care protections.

Federal Advocacy and Help Resources

If you or your family member needs help navigating a FIDE-SNP issue, the following federal and national resources are available:

• CMS Medicare-Medicaid Coordination Office (MMCO), the federal office responsible for FIDE-SNP and HIDE-SNP policy. Publishes the SNP Comparison Chart, FAQ documents, and HPMS Chapter 16-B guidance. Website: cms.gov/medicare-medicaid-coordination/medicare-and-medicaid-coordination/medicare-medicaid-coordination-office
• State Health Insurance Assistance Program (SHIP), every state has a SHIP that offers free, unbiased Medicare counseling, including D-SNP and FIDE-SNP comparison. Find your state's SHIP at shiphelp.org or 877-839-2675.
• Medicare Rights Center, national consumer advocacy organization with a free Medicare helpline (800-333-4114).
• Justice in Aging, federal-level litigation and policy advocacy organization specializing in dual-eligible issues. Website: justiceinaging.org.
• Center for Medicare Advocacy, federal-level policy and individual-case advocacy. Website: medicareadvocacy.org.
• MACPAC (Medicaid and CHIP Payment and Access Commission), congressional advisory body. Annual reports include detailed FIDE-SNP and dual-eligible analyses. Website: macpac.gov.
• MedPAC (Medicare Payment Advisory Commission), congressional advisory body for Medicare. Annual June report typically includes D-SNP analyses. Website: medpac.gov.
• Integrated Care Resource Center (ICRC), CMS technical-assistance contractor for states implementing dual-eligible integration. Website: integratedcareresourcecenter.com.
• SNP Alliance, trade association of SNP plan sponsors. Useful for tracking industry developments. Website: snpalliance.org.
• ATI Advisory, health policy consulting firm that publishes detailed analyses of dual-eligible policy. Website: atiadvisory.com.

For state-specific advocacy resources, see the linked state guides at the bottom of this article.

Frequently Asked Questions

Learn More

• Dual-Eligible Special Needs Plans (D-SNP) Explained
• Dual Eligibles: Medicare and Medicaid Together
• Massachusetts SCO and One Care: The 2026 FIDE-SNP Transition
• Medicare Savings Programs: QMB, SLMB, QI, and QDWI
• Tennessee Medicare Savings Programs
• Medicaid Estate Recovery Explained

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.