Integrated D-SNPs Explained: FIDE, HIDE and the 2027 and 2030 Changes

Since 2021, every D-SNP has had to meet at least one integration standard. The baseline, usually called “coordination-only,” requires the plan to notify the state about hospital and nursing-home admissions. “Coordination-only” is not a term defined in the regulation itself; CMS uses it in its guidance for a D-SNP that is neither HIDE nor FIDE.

Under the federal definition, one organization holds both the Medicare Advantage contract and the state Medicaid managed care contract. The plan covers primary and acute care, Medicare cost sharing, long-term services and supports (including nursing-facility care for at least 180 days a year), behavioral health, home health and medical equipment. It coordinates care for high-risk members and integrates member materials, enrollment, grievances and appeals. Since plan year 2025, a FIDE SNP must have exclusively aligned enrollment and a Medicaid contract that covers its whole service area.

Your Medicaid benefits come through a capitated contract between the state and the D-SNP's organization, its parent or an entity it owns. That contract must cover long-term services and supports (including some nursing-facility days) or behavioral health. Since plan year 2025, the Medicaid contract must cover the D-SNP's entire service area. A HIDE SNP does not have to limit enrollment to its own Medicaid members unless the state requires it.

Aligned enrollment means a full-benefit dual has their Medicaid health plan with the same company (or its parent or an owned entity) as their D-SNP. When state policy limits a D-SNP to people with aligned enrollment, that is called exclusively aligned enrollment.

An applicable integrated plan is the federal term for the most aligned arrangements: a FIDE or HIDE SNP with exclusively aligned enrollment together with its matching Medicaid plan, or a D-SNP limited by the state to members of its affiliated Medicaid plan whose Medicaid contract covers primary and acute care, Medicare cost sharing and certain other services. These plans replace the separate Medicare and Medicaid appeal and grievance processes with one integrated process. Where a state requires certain exclusively aligned D-SNPs to use a state-only contract, plans must also use combined member documents covering both programs.

The Contract Year 2025 rule (CMS-4205-F) ended the old quarterly enrollment option for people with Medicaid or Extra Help. Since January 1, 2025 there are two once-a-month options:

Neither option lets anyone move between regular Medicare Advantage plans. For other changes, the usual windows apply: the Initial Enrollment Period, the Annual Enrollment Period (October 15 through December 7), the Medicare Advantage Open Enrollment Period (January 1 through March 31) and other Special Enrollment Periods. The Contract Year 2027 rule confirmed that both monthly options remain in effect.

Where a company (or its parent or a sister company) offers a D-SNP and also a state Medicaid managed care plan that enrolls full-benefit duals in an overlapping area, two limits apply from January 1, 2027:

• It may offer only one D-SNP for full-benefit duals in that area, even if the service areas only partly overlap. This applies to every D-SNP type, including coordination-only plans under the same owner.
• That D-SNP may newly enroll only people who are in, or are enrolling in, the company's Medicaid plan.

Federal rules allow some exceptions:

• the state contract separates D-SNPs by age group or by Medicaid benefit design;
• one HMO D-SNP and one PPO D-SNP may both exist if the one that is not aligned is closed to new enrollment;
• added by the Contract Year 2027 rule: where a state does not require Medicaid managed care for all full-benefit duals, a company may offer additional HIDE or coordination-only D-SNPs for full duals in Medicaid fee-for-service;
• also added in 2027: U.S. territories without Medicare Savings Programs are exempt.

Partial duals may still have a separate D-SNP where state policy allows. CMS also notes that in some states, the Medicaid plan is matched to the D-SNP a person chooses.

Existing members who are not aligned may stay in these D-SNPs until 2030. Someone who joins while aligned and later changes Medicaid plans may also stay until then.

Starting January 1, 2030, D-SNPs subject to the 2027 limit may enroll or keep only people who are in the matching Medicaid plan. Plans may still use deemed continued eligibility for members who temporarily lose Medicaid. A member who is not aligned would be disenrolled from the D-SNP. According to the rule's explanation, that person is not removed from their Medicaid plan: they stay in their other Medicaid managed care plan under state rules.

The Contract Year 2027 final rule, published April 6, 2026, did not change the 2027 or 2030 dates. It added the two exceptions above and continuity-of-care requirements for D-SNPs that receive members through passive enrollment.

Indiana launched Indiana PathWays for Aging, its Medicaid managed long-term services program for Hoosiers 60 and older, on July 1, 2024. On January 1, 2026 it added PathWays Dual Care, a voluntary program for full-benefit duals 60 and older delivered through FIDE SNPs. The state describes integrated materials, one ID card and an integrated appeals and grievance process, and members can enroll or disenroll in any month.

Indiana also says that people newly eligible for Medicare who are already in a PathWays Medicaid plan are default-enrolled by the state into the matching dual plan, while keeping the freedom to choose. People under 60 with full Medicaid, and all partial duals, use coordination-only D-SNPs. See our Indiana guide.

Michigan ended its MI Health Link demonstration on December 31, 2025. Its replacement, MI Coordinated Health, is a HIDE SNP program that started January 1, 2026, and the state says MI Health Link members moved over automatically with no break in coverage.

Michigan's eligibility manual limits the program to people 21 and older with Medicare Parts A, B and D and full Medicaid; the partial-benefit groups are not eligible. In 2026 it serves the Upper Peninsula (except Chippewa, Gogebic and Menominee counties), eight southwest Michigan counties, Macomb County and Wayne County. The state has said a statewide expansion is planned for January 1, 2027, contingent on budget approval, while its draft 2027 waiver application still lists the 2026 areas. See our Michigan guide.