How The 2025 CMS Ruling Impacts Dual Eligible Special Needs Plans & Insurance Providers

The Center for Medicare & Medicaid Services plays a crucial role in shaping the healthcare landscape for vulnerable populations. One of the most significant upcoming changes for 2025 concerns Dual Eligible Special Needs Plans (D-SNPs). These plans cater to individuals who qualify for both Medicare and Medicaid, offering tailored coverage to meet their specific healthcare needs. The 2025 CMS final ruling introduces key changes that will reshape enrollment processes, coverage options and the way insurers must handle dual eligibility populations.

Overview Of The 2025 CMS Ruling

The 2025 CMS ruling introduced several major updates to the D-SNP landscape, focusing on enrollment changes, alignment with Medicaid Managed Care and new strategies for providing integrated care, including changes in: 

  • Special Enrollment Period (SEP): Beneficiaries will have more frequent opportunities to change their plans, providing increased flexibility and responsiveness to their evolving healthcare needs. This adjustment allows individuals to make changes to their coverage on a monthly basis, and enroll in standalone prescription drug plans with more freedom.  
  • Integrated Care SEP: Dually eligible individuals, as well as those who receive Low-Income Subsidy assistance, will now have the option to enroll in fully integrated Dual Eligible Special Needs Plans, Highly Integrated Dual Eligible Special Needs Plans or other applicable integrated plans on a monthly basis. This SEP allows for more streamlined transitions into integrated care models, which are designed to offer seamless coordination between Medicare and Medicaid coverage.
  • Alignment with Medicaid Managed Care: Another significant change is the requirement for dually eligible individuals to align their coverage with a Medicaid Managed Care Organization (MCO). This policy aims to create greater synchronization between Medicare Advantage and Medicaid programs, ensuring that individuals receive more cohesive care that is consistent with their Medicaid MCO.

How Does The Ruling Affect Insurance Shoppers?

The 2025 CMS ruling offers significant benefits for insurance shoppers, particularly those eligible for both Medicare and Medicaid. With the shift to monthly Special Enrollment Periods  and expanded enrollment opportunities, dually eligible shoppers can more easily switch to integrated care plans, enhancing their chances of receiving coordinated, comprehensive coverage that addresses both their Medicare and Medicaid needs. This increased flexibility allows beneficiaries to adjust their plans more frequently, ensuring their coverage aligns with evolving healthcare requirements and reducing the risks of gaps or delays in care. Additionally, the increase in Medicare Advantage payments from 2024 to 2025 provides insurers the ability to offer expanded benefits and services, enabling better care options and improved outcomes for dually eligible individuals.

What Does This Mean For Insurance Providers?

While the CMS ruling brings significant benefits for those who are dually eligible, it also poses challenges for insurance providers who must adjust their operations to align with the new requirements that started in January 2025. The shift to a monthly Special Enrollment Period will require insurance providers to adapt their enrollment processes to handle more frequent plan changes from dually eligible individuals. Beneficiaries will have less freedom to switch between Medicare Advantage plans since they must stay within a system that integrates both their Medicare and Medicaid benefits. This could result in fewer opportunities for insurers to enroll new customers or make changes to existing plans. However, the need for greater coordination between Medicare and Medicaid should encourage insurers to work more closely with Managed Care Organizations to provide more comprehensive, streamlined care. Although this alignment could limit short-term enrollment changes, it may help insurers improve the overall quality of care and foster better long-term relationships with their customers.

How Can DMS Help?

As insurers navigate the changes for D-SNPs introduced by the CMS ruling, Digital Media Solutions can provide crucial support with expert guidance. By partnering with DMS, insurers can expand their target audience, creating tailored strategies to engage diverse segments, including dually eligible individuals and those enrolled in Chronic Condition Special Needs Plans. This ensures that insurance shoppers are more likely to find the care plan that best suits their needs. By expanding outreach, insurers can maximize enrollment opportunities and strengthen their connections with niche segments who add to their existing customer base. Additionally, DMS can help insurers expand their offerings in the senior market, introducing options such as Final Expense coverage to meet the evolving needs of older life insurance shoppers.

Although the 2025 CMS ruling may present challenges for insurance providers, with the right guidance and approach, insurers can adjust their enrollment and segmentation strategies and seize new opportunities. DMS can support insurers in navigating this shift, generating high-intent leads to drive continued growth and engagement, while ensuring compliance with new requirements.

Partner With Digital Media Solutions

Digital Media Solutions (DMS) can help you connect with high-intent consumers, drive better business results and maximize your return on ad spend. By leveraging innovative digital strategies, you can make sure your Medicare Advantage health plans reach the right audiences. Contact DMS today to learn more about how we drive better business results for health insurance providers.

About the author

Chelsea Malcolm

Chelsea Malcolm is the Vice President of Health Marketplaces at DMS, a role she has held since April 2018. With 10 years of professional experience in digital marketing, Chelsea's expertise lies in the education and Medicare sectors. As the VP of Health Marketplaces and General Manager of the Edge division at DMS, Chelsea is responsible for overseeing Medicare sales, specializing in warm transfers, leads and inbound marketing services. Throughout her career, Chelsea has held various job titles, including VP of Growth and Strategy, Director of Client Services, Manager of Customer Success and Senior Assistant Director of Admissions. Before joining DMS, Chelsea worked at Avenue100, a smaller lead generation company focused on education. Prior to that, she served on the Board of Admissions for Boston University, where she managed a team of assistant directors. Coming from the education space, which shares similarities with the highly regulated and compliance-focused Medicare industry, Chelsea brings a valuable perspective to DMS. Her expertise in navigating complex regulatory environments has been instrumental in keeping DMS competitive and compliant. As a leader within the DMS Insurance division, Chelsea works to help DMS deliver customers and near customers to our nation’s largest insurers and their respective agent pools. By leveraging the DMS toolset, inclusive of the company’s first-party data asset, proprietary technology, expansive digital media reach and data-driven processes, DMS helps health insurance advertisers scale their customer bases with reliable advertising ROI.