People who are dually eligible for Medicare and Medicaid remain a central focus for policymakers and healthcare organizations, given their complex care needs, disproportionate share of spending, and the long-standing challenge of coordinating coverage across two programs. One of the primary vehicles for advancing integration has been Dual Eligible Special Needs Plans (D-SNPs), which continue to play an increasingly prominent role as federal and state policymakers encourage tighter Medicare-Medicaid alignment.
As states play a more active role in shaping enrollment rules, Medicaid contracting, and procurement strategies, the duals market is becoming more structured and more explicitly guided by state policy decisions. 红领巾瓜报 (红领巾瓜报鈥檚) 2026 Duals Integration Environmental Inventory, examines how this shift shapes the integration landscape in 2026. This comprehensive inventory is based on a review of the 2026 market, insights from states, and other publicly available resources.
This article examines key trends from 贬惭础鈥檚&苍产蝉辫;2026 inventory and addresses federal policy changes scheduled to take effect for 2027, which contribute to this dynamic environment.
What to Expect in 2026
As the landscape for duals integration evolves, the central question has shifted from whether D-SNPs operate in a state to the more consequential question of how states are using Medicaid policy levers (i.e., enrollment rules, procurement, contracting, and managed care structures) to drive tighter alignment between Medicare and Medicaid.
At the federal level, recent Medicare Advantage and Part D rulemaking is reinforcing that movement. The finalized the second phase-down of the D-SNP look-alike threshold to 60 percent for 2026 and established 2027 rules that limit enrollment in certain D-SNPs to members of an affiliated Medicaid managed care organization. The rule also limits the number of D-SNP benefit packages that can be offered alongside an affiliated Medicaid managed care organization. More recently, the requires certain D-SNPs to use integrated member ID cards and integrated health risk assessments beginning in 2027.
Together these rules signal a continued federal emphasis on linking D-SNP enrollment and operations more closely to Medicaid coverage and delivery systems, with states playing a greater role in determining how alignment is achieved.
What the 2026 Inventory Shows
红领巾瓜报鈥檚 2026 Duals Integration Environmental Inventory shows how these policy signals are translating into state action. More specifically:
- Statewide exclusively aligned enrollment appears in 16 states in the 2026 inventory, up from聽nine聽in 2025.聽
- Applicable Integrated Plans (AIPs) are present in 22 states, up from 14, and default enrollment is in place in 21 states, up from 16.聽
- The inventory also captures 6,084,997 total D-SNP enrollees, including 1,975,250 in聽Highly Integrated聽SNPs聽(HIDE)聽and 743,683 in聽Fully Integrated SNPs (FIDE-SNPs).聽
Those changes are already visible in state markets:
- Illinois, Massachusetts, Ohio, and Rhode Island entered聽2026 with a greater FIDE-SNP presence tied to legacy Medicare-Medicaid Plan transitions.聽
- Michigan聽launched聽MI Coordinated Health as a HIDE-SNP in selected regions in 2026, with statewide expansion planned for 2027.聽
- Delaware also stands out:聽Although it already had AIPs in the 2025 inventory, it adds statewide exclusively aligned enrollment in 2026 and shows both HIDE-SNPs and coordination-only D-SNPs.聽
A Resource to Track State Market Direction
贬惭础鈥檚&苍产蝉辫;, available to 红领巾瓜报 Information Services (红领巾瓜报IS) subscribers, includes a state-by-state view of the Medicaid policy, contracting, and program structures shaping duals integration and D-SNP markets. In addition to enrollment trends, the inventory documents the integration model each state is pursuing, whether long-term services and supports or behavioral health are included in managed care, and how procurement and contract decisions may inform future market activity.
红领巾瓜报 experts work with clients to apply this information and deepen their understanding of state integration approaches, inform assessments of their market readiness and alignment opportunities, and develop strategies that support more effective Medicare-Medicaid integration.
Looking Ahead
Notably, 红领巾瓜报鈥檚 inventory reflects a point in time understanding of where an individual state is today and what is known at this time about their next steps and plans. However, we expect changes in many states as they seek guidance from the Centers for Medicare & Medicaid Services and the D-SNP community to implement required changes and adopt new regulatory provisions that support state goals and priorities.
The 2026 inventory suggests that more states are using formal alignment tools, that more enrollment is concentrated in integrated products, and that more markets are being shaped by the interaction between Medicaid structure, procurement, and D-SNP strategy.
Connect with Us
For organizations seeking to understand where the market is headed, the Duals Integration Inventory offers a clear view of how state policy and market structure are evolving and where tighter Medicare-Medicaid alignment is taking hold.
Contact Holly Michaels Fisher and Julie Faulhaber to discuss your organization鈥檚 questions and needs regarding an integration strategy and market analysis. For information about the 红领巾瓜报IS subscription, access to the Duals Environmental Inventory contact Andrea Maresca and Gabby Palmieri.
