Medicare D-SNP Look-Alike Transitions for 2026: Key Guidance
Relevant to: Enrollment and Payment Systems, Part D
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.
Click here for the full Fact Sheet.
Introduction
The Centers for Medicare & Medicaid Services (CMS) have issued updated guidelines for Medicare Advantage Organizations with Dual Eligible Special Needs Plan (D-SNP) “look-alikes” for the contract year 2026. This new guidance outlines procedural steps for transitioning enrollees from these plans, detailing specific requirements and conditions that organizations must follow, including options for transition and compliance with anti-discrimination laws. These changes are crucial for ensuring a smooth transition process and maintaining consistent coverage for affected beneficiaries.
Key Dates and Deadlines
- Memo Date: April 9, 2025
- D-SNP Enrollment Transition Request Deadline: May 9, 2025 (11:59 PM Pacific Time)
- CMS Preliminary Determination: Late May 2025
- Final Determination by CMS: August 2025
- POVER Process Scheduled: October 2025
- D-SNP Look-Alike Enrollment Transition Effective Date: January 1, 2026
PACE Compliance
Required Actions
1. Review the eligibility criteria for the transition of D-SNP look-alike enrollees as outlined in the memorandum and ensure that your Medicare Advantage (MA) organization meets these criteria.
2. Prepare and submit an email to your Account Manager and the CMS Medicare-Medicaid Coordination Office (MMCO) at MMCO_DSNPOperations@cms.hhs.gov by May 9, 2025, indicating your intent to use the transition process under 42 CFR 422.514(e). Include the required information in the provided Excel spreadsheet template.
3. Complete the necessary steps in the Health Plan Management System (HPMS) as described in the forthcoming crosswalk and crosswalk exceptions process instructions, to finalize the transition of enrollees. Ensure to select the applicable D-SNP look-alike transition category when submitting your CY 2026 bids.
FAQs
- “What is the process for transitioning D-SNP look-alike enrollees for 2026?”
- “How does CMS determine if a plan qualifies as a D-SNP look-alike?”
- “What are the notification requirements for MA organizations during transitions?”
- “Which MA plans can receive D-SNP look-alike enrollees?”
- “What is the difference between the transition process and the crosswalk process for D-SNP look-alikes?”
