Open enrollment begins Oct. 15, and the 2027 plan year brings the first federal limit on who enrolls in certain dual eligible special needs plans (D-SNPs). The limit applies to Medicare Advantage organizations whose parent company also runs a Medicaid managed care organization (MCO) serving full-benefit dual eligible members in the same area. Coverage of the rule has often framed the choice as aligning with Medicaid or losing members, but the regulation sets a narrower requirement for 2027 and a later date for disenrollment. Your teams need the timeline right, because risk adjustment, quality, sales, and operations each feel a different piece of the change.
Which plans the rule covers
Under 42 CFR 422.514(h), a D-SNP must limit new enrollment when the MA organization, its parent, or any entity sharing its parent also contracts with a state as a Medicaid MCO enrolling full-benefit dual eligible individuals in the same service area. Those D-SNPs enroll only people who are already in, or are in the process of enrolling in, the affiliated Medicaid MCO. Even partial service area overlap triggers the rule, and CMS applies the requirement across D-SNP types, including coordination-only plans. Organizations without an affiliated Medicaid MCO in the area face no limit under this provision, and plans serving partial-benefit duals stay outside the provision when state policy allows.
What changes on Jan. 1, 2027
Three changes take effect. New enrollment narrows to members of the affiliated Medicaid MCO. A parent organization offers one D-SNP for full-benefit duals in each service area shared with the affiliated Medicaid MCO. CMS also added a crosswalk exception, which lets organizations consoliate D-SNP plan benefit packages across different MA contracts held under the same parent.
The one-plan limit has exceptions. States differentiate D-SNPs by age group or program design in their Medicaid contracts, and CMS guidance describes room for HMO and PPO D-SNPs to coexist, with the non-aligned plan closed to new enrollment. Unaligned full-benefit members move to the surviving plan when they meet its eligibility rules, though members are not eligible to move into a plan operating under state-mandated exclusively aligned enrollment.
What waits until 2030
Members already enrolled in a D-SNP but not in the affiliated Medicaid MCO stay enrolled through 2029. Beginning Jan. 1, 2030, affected D-SNPs enroll and keep only aligned members, and remaining unaligned members disenroll unless the plan uses the deemed continued eligibility provisions in 42 CFR 422.52(d). No one loses D-SNP coverage on Jan. 1, 2027 because of this rule. The 2027 change governs who joins. The 2030 change governs who stays.
What this means for risk adjustment
New enrollment now comes from one source, the affiliated Medicaid MCO, so the unaligned share of your D-SNP membership shrinks each year through attrition. Members who stay unaligned through 2029 form a closed group with a fixed end date, and your risk adjustment team works two populations with different data access. Aligned plans hold Medicare and Medicaid data on the same member, which gives a fuller view of diagnoses, services, and care gaps than a plan with one side of the record. Members who move to another plan take their history with them, so a plan giving up members also gives up visibility into their open gaps.
What this means for quality and Stars
Star Ratings attach to the MA contract, and the crosswalk exception allows moves between contracts under one parent. A consolidation moves members, along with their quality measure and CAHPS survey experience, from one rated contract to another. Contracts absorbing members take on the results those members bring, and contracts giving up members lose them. As unaligned members leave over time, contract-level results reflect a more aligned population, which shifts the mix behind each measure.
What this means for marketing and sales
Open enrollment is the first test. A broker or agent enrolling a dual eligible client in a D-SNP in an affected area needs two facts, the plan’s parent organization and the client’s actual Medicaid enrollment, because a mismatch blocks new enrollment. CMS leaves “in the process of enrolling” undefined to preserve state flexibility, so verification steps differ by state. Enrollment, Medicaid operations, provider relations, and broker compensation are separate teams, and each communicates its part of the change on its own schedule, so brokers hear the rule in pieces.
The first open enrollment under the rule starts in weeks, and the results will show up in enrollment files, risk scores, and contract-level performance through 2027. RISE National 2027 brings risk adjustment, quality and Stars, and marketing and sales leaders together March 16 to 18 at Caesars Forum in Las Vegas. Join your peers to compare what the first months of alignment looked like across plans and states.