Dual Eligible Special Needs Plans, or D-SNPs, are Medicare Advantage (MA) plans that only enroll beneficiaries who are dually eligible and enrolled in both Medicare and Medicaid. D-SNPs are popular among both MA organizations (MAOs) and dual eligible beneficiaries because benefit designs can be tailored to the needs of this population.

Recent federal regulations and state Medicaid policies related to D-SNPs—largely guided by a goal of the Centers for Medicare and Medicaid Services (CMS) of promoting integrated care through aligned Medicare and Medicaid products—have helped shape the D-SNP landscape. As state Medicaid agencies have enacted policy decisions that limit D-SNP offerings in their states, and with CMS having curtailed the use of general enrollment plans to enroll dual eligible beneficiaries, some MAOs have responded by increasingly offering Chronic Condition Special Needs Plans (C-SNPs) that primarily enroll dual eligible beneficiaries. Unlike D-SNPs, C-SNPs do not generally need to maintain a contract with the state Medicaid agency to operate.

Calendar-year (CY) 2026 MA data show moderately increased growth in D-SNP enrollment and plan count, driven by transitioning Medicare-Medicaid Plans (MMPs). This white paper discusses historical and current growth, reviews recent policies impacting D-SNPs, and offers additional insights into the CY 2026 D-SNP landscape.

Key insights

• The D-SNP market growth rate increased due to MMP transitions.
• National MAOs continue to dominate the landscape.
• The value-based insurance design program ended, eliminating a way for D-SNPs to offer zero-dollar and Part D cost sharing.
• Rich D-SNP supplemental benefits decreased.
• The average star rating for D-SNPs increased in CY 2026.
• Integrated D-SNPs are growing, but integration requirements continue to largely be met through coordination rather than integration.
• Regulatory changes will continue to shape the D-SNP market.