Dual Eligible Special Needs Plans (D-SNPs) have become the primary vehicle for advancing Medicare-Medicaid integration for beneficiaries who are dually eligible for both programs. Federal policy has increasingly moved D-SNPs toward greater integration, with requirements aimed at strengthening care coordination, aligning enrollment, improving beneficiary protections, and increasing coordination between Medicare Advantage organizations and state Medicaid agencies.
Beginning in 2027, additional CMS requirements will further align D-SNP enrollment with affiliated Medicaid managed care plans. Against this backdrop, recent enrollment data provide an important look at how the D-SNP market is changing and show that the path toward greater integration is influenced by trends in the public and private sectors.
Using CMS Monthly SNP Comprehensive Reports and D-SNP Integration Status files, we examine how the D-SNP market has evolved from 2021 through 2026. We focus on national integration trends, the transition from Financial Alignment Initiative (FAI) demonstrations into D-SNPs, and differences in integration strategies across major parent organizations.
We distinguish among coordination-only (CO) D-SNPs, which coordinate Medicare and Medicaid benefits without meeting higher integration standards; highly integrated D-SNPs (HIDE SNPs), which provide Medicaid behavioral health services and/or long-term services and supports through qualifying Medicaid arrangements; and fully integrated D-SNPs (FIDE SNPs), which integrate a […]
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Dr. Lanlan Xu is a dynamic, results-driven health policy executive with over a decade of experience advancing national healthcare reforms in payment and delivery system innovation, Medicare Advantage, and Medicare & Medicaid alignment. She brings proven expertise in health services research, legislative and regulatory strategy, and cross-sector collaboration, and is a recognized leader in advising senior policymakers on value-based care models and healthcare financing reform. Most recently, Dr. Xu served as Deputy Director of the Division of Health Care Financing Policy (HFP) within the Office of the Assistant Secretary for Planning and Evaluation (ASPE) at the U.S. Department of Health and Human Services. In that role, she led a team of economists and policy analysts focused on Medicare and broader health financing strategies, while overseeing ASPE’s Medicare Advantage portfolio. Previously, at the CMS Innovation Center (CMMI), Dr. Xu led evaluations of large-scale health care delivery models, including the Financial Alignment Initiative for dual eligibles and the Initiative to Reduce Avoidable Hospitalizations among Nursing Facility Residents. Earlier in her career at IMPAQ International (now part of AIR), she led Medicare-focused policy research and evaluations, directed the development of care coordination and quality measures, and supported major CMS models and demonstrations. Dr. Xu holds a Ph.D. in Public Policy from Indiana University and a Ph.D. in German Literature from Georgetown University. |