The Centers for Medicare and Medicaid Services (CMS) has released its “Final Rule” for 2025, which makes significant changes to Dual Eligible Special Needs Plans (D-SNPs). The changes impact benefit management, enrollment, and access to information. 

These changes will affect you if you currently have a D-SNP or are interested in enrolling. Still, resources are available to give you greater insight into the changes and how they can impact your healthcare coverage.

What does D-SNP mean?

A Dual Eligible Special Needs Plan, also known as a D-SNP, is a Medicare Advantage plan accessible to those who are entitled to Medicare and qualify for medical assistance from a state plan under Medicaid. DSNP plans have specific eligibility requirements. It’s important for beneficiaries to understand those requirements as they’ve changed in 2025. Here is more on what you need to know.

What are the CMS changes for D-SNP for 2025?

The Centers for Medicare and Medicaid Services (CMS) issued a final rule for 2025 Medicare Advantage and Prescription Drug Plans that altered aspects of the plan for current and future beneficiaries.

The most significant changes  affect the Special Enrollment Period (SEP). This dictates when an individual can join/leave a Medicare Advantage plan, choose a new Prescription Drug Plan, or return to Original Medicare. Before 2025, any D-SNP eligible beneficiary was afforded an SEP that allowed them to change plans once a quarter. In 2025, that SEP was eliminated and replaced with a more restrictive monthly SEP:

• The new monthly SEP only allows beneficiaries with full Medicaid benefits to enroll into an integrated D-SNP plan, aligning enrollment between their D-SNP and Medicaid coverage. 
• Beneficiaries without full Medicaid still have access to a monthly SEP, however it only allows them to leave their current plan and return to Original Medicare or a standalone Part D plan.

Additional D-SNP changes for 2025 include the following:

• How the D-SNPs manage Special Supplemental Benefits for the Chronically Ill (SSBCI). Starting in October 2024, plans began to make eligibility clearer. Additionally, Medicare Advantage plans now (starting January 1, 2025) cannot change eligibility criteria in the middle of a plan year. SSBCI approval and denials need to be recorded, and evidence of the effectiveness of SSBCI must be reported to the CMS. Finally, enrollees who qualify should be contacted starting in January 2026.
• How the Medicare Plan Finder works. It will now allow dually eligible individuals to see all benefits open to them, including both Medicaid and Medicare services (including certain D-SNPs) as available within the zip code provided.

Worried about your plan? Let SmartMatch help

The good news for those with D-SNP plans is that these changes won’t happen all at once. Changes to the SEP started January 1, 2025, but additional changes will continue to occur through 2030 (pending any regulatory changes).

Navigating changes to D-SNP enrollment and ensuring you have the coverage you need can be complicated, but there is help available. If you are worried about your plan or would like more information on how the changes affect you, reach out to SmartMatch.