D-SNP Growth Stalls as Plans Shift Dual Eligibles to C-SNPs to Avoid State Medicaid Contracts

Milliman's analysis of 2026 Medicare Advantage data reveals that D-SNP enrollment growth remains minimal outside of states transitioning Medicare-Medicaid Plans, while plans increasingly use C-SNPs to enroll dual eligibles and sidestep state Medicaid agency contracting requirements. The trend reflects MAO responses to tightening CMS integration requirements and state policies limiting D-SNP availability, with implications for how dual eligibles access coordinated Medicare-Medicaid benefits. The shift raises questions for state Medicaid agencies about care coordination oversight and whether dual eligibles in C-SNPs receive comparable integration as those in contracted D-SNPs.

Managed Care · Long-Term Care

This is outside commentary from Milliman, not part of Medicaid Monitor's independently scored news coverage.

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