What’s Changing with D-SNPs and C-SNPs

Special Needs Plans aren’t new, but recent federal and state-level changes are shifting how they’re offered and who can enroll.

• Eligibility isn’t automatic. Some D-SNP and C-SNP prospects may not qualify to enroll during AEP due to current plan status, Medicaid alignment, or changes in state-level rules. Pay close attention to these clients so you can follow up when enrollment opportunities reopen in Q1.
• State-level transformations are underway. State-level transformations are underway. States like Texas, Michigan, Kentucky, and Wisconsin are restructuring how D-SNPs operate in their Medicaid systems. Some are transitioning to Coordination-Only D-SNPs , Highly Integrated or Fully Integrated D-SNPs, with passive enrollment ending and service areas changing.
• Carriers are shifting. In states like Ohio and Kentucky, major carriers have exited the D-SNP market, leaving members to transition and licensed insurance agents scrambling to adapt. This kind of market instability could affect plan availability heading into 2026, making it critical for agents to stay informed and flexible.

Key States Experiencing D-SNP Market Changes

As previously mentioned, several states are undergoing major structural changes to their Special Needs Plan offerings, particularly D-SNPs. These shifts are being driven by both state-level programs and federal CMS policies set to take effect in 2026.

Here’s what Licensed Insurance Agents need to know:

Texas
Texas is transitioning its Dual Demonstration Medicaid-Medicare plans (MMPs) into fully integrated D-SNPs starting January 1, 2026. Passive enrollment for existing MMPs will end mid-2025, and the state plans to pause new enrollment in coordination-only D-SNPs in demonstration areas by 2027.

Michigan
Michigan is phasing out its MI Health Link program and rolling out a Highly Integrated Dual Eligible (HIDE) D-SNP model beginning January 2026, with full statewide implementation expected by 2027.

Ohio
Although not technically a 2026 change, Ohio experienced significant contract disruptions in late 2024. CVS/Aetna lost their “Next Generation MyCare” D-SNP contract, and UnitedHealthcare was not re-awarded, signaling ongoing market instability that may affect future plan availability.

Kentucky
Anthem announced it will withdraw all D-SNPs in Kentucky by the end of February 2025. Members must transition to other options, and UnitedHealthcare is stepping in to fill some of the gap.

Wisconsin
Wisconsin is reviewing and realigning its D-SNP offerings, focusing on Highly Integrated (HIDE) and Fully Integrated (FIDE) SNP structures. Strategic adjustments are expected to roll out starting April 2025.

Federal-Level Changes
CMS’s 2025 Final Rule, effective in 2026, includes:

• Out-of-network cost-sharing limits for D-SNP PPOs
• Expanded language access requirements
• Prior authorization transparency rules
• A limit on non-aligned Medicaid-Medicare plans operating across multiple service areas under one payer

What These Changes Mean for Licensed Insurance Agents

These aren’t small tweaks. The ripple effects will impact how you approach your book, your conversations, and your marketing.

• Leads are still valuable, even if they can’t enroll right now. You might meet a qualified D-SNP or C-SNP prospect during AEP who can’t make a change. That doesn’t mean they’re a dead end. It means you need a follow-up strategy for Q1, when those leads could become eligible.
• Use your CRM to track eligibility and future opportunities. Not every D-SNP or C-SNP lead will be ready to enroll during AEP, but that doesn’t mean the opportunity is lost. Make note of why they’re ineligible now and set reminders to follow up when enrollment windows reopen, especially in Q1. Staying organized helps you re-engage the right people at the right time.
• Your marketing should reflect what’s happening. This isn’t just about promoting plans. It’s about education. Make it clear who might qualify for a C-SNP or D-SNP, what eligibility changes are unfolding, and how you help clients navigate them. CMS allows more flexibility with C-SNP communication, especially when clients ask about them, during AEP, or within a scheduled Medicare Advantage meeting. Use this as a chance to lean into education-focused marketing that builds trust and drives interest.

Staying Compliant with the New Rules

Compliance is always part of the job, but with these changes, it’s even more critical.

• Be careful with assumptions around enrollment timing. Just because someone qualifies for a D-SNP or C-SNP doesn’t mean they can enroll today.

• Check carrier updates often. Many are still releasing clarification around eligibility and service area availability.
• Use CMS-approved, carrier-provided materials. And make sure your team knows how to talk about these changes correctly.

Always check with compliance before launching any outreach that discusses specific plans or conditions.

Mastering SNPs is a Competitive Advantage

Licensed Insurance Agents who understand how to work with D-SNP and C-SNP clients are building trust, loyalty, and long-term retention.

Since 2019, SNP enrollment has doubled, and C-SNP plans continue to see year-over-year growth. That momentum isn’t slowing down.

By staying informed, using every lead wisely, and having a clear re-engagement plan, you set yourself apart in a market that many licensed insurance agents still don’t fully understand. Focus on education, consistency, and strategy and you’ll be ready to grow your impact in any season.

Final Takeaway

D-SNP and C-SNP opportunities are growing, but so is the complexity. The licensed insurance agents who stay informed, organized, and proactive will be the ones who make the most of every lead, whether it converts now or in Q1.