State Approaches to Implementing Aligned Enrollment in D-SNPs

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ATI – Insights
02/03/2026
AUTHOR – ATI Advisory

With new federal requirements effective January 1, 2027, states where Dual Eligible Special Needs Plans (D-SNPs) share a parent organization with Medicaid plans in the same service area must decide how D-SNPs will achieve aligned enrollment for new D-SNP enrollees. States may choose a Medicare-driven or a Medicaid-driven approach to meet these requirements, with each approach having its own considerations.

Realizing the full potential of aligned enrollment requires deliberate planning, systems investment, and collaboration across state, federal, and plan partners. States implementing Medicare-driven aligned enrollment are navigating complex policy, operational, and systems changes to improve integration for dual eligible individuals.

ATI developed this report to support states subject to the impending 2027 (and 2030) D-SNP enrollment alignment requirements that will need to modify their enrollment policies and processes. We provide detailed insights based on a targeted literature review, interviews with state Medicaid officials, and ATI’s experience supporting states with both Medicare- and Medicaid-driven alignment approaches.

Read the full report for lessons learned, best practices, and implementation insights from states that have already launched aligned enrollment.

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