1. What actually changes in 2027
The rule lives at 42 CFR 422.514(h). In plain terms: where an insurance company offers a Dual Eligible Special Needs Plan — a D-SNP, the Medicare Advantage plan built for people who have both Medicare and Medicaid — and that same company, its parent, or a sister company under the same parent also runs a Medicaid managed care plan for full-benefit duals in the same area, then from January 1, 2027 that D-SNP may only newly enrolll people who are already in, or in the process of joining, its own Medicaid plan.1
There is a second half. The same company may offer only one D-SNP for full-benefit dual eligibles in that service area, rather than several competing versions of the same thing. Both parts are aimed at the same goal: fewer people holding a Medicare plan from one company and a Medicaid plan from another, with two sets of cards, two phone numbers and two appeals processes that do not talk to each other.
The word doing the work is “newly”
The 2027 restriction is on new enrollment. It is not a reshuffle of people already in a plan, and it is not a deadline you can miss this autumn. If you read a headline that suggested otherwise, it was compressing three years of phase-in into one sentence.
2. Whether it reaches your plan at all
This is the question worth answering first, because for a good number of people the answer is that nothing changes at all. The rule is conditional. It only bites where the same corporate family sits on both sides — a D-SNP and a Florida Medicaid managed care contract covering the same ground.
| Your situation | What the rule does |
|---|---|
| Your plan’s company does not run a Florida Medicaid plan where you live | Nothing changes. CMS says that plan may keep enrolling without these restrictions. |
| Your plan’s company also runs your Medicaid plan — same company both sides | Nothing changes for you. You are what CMS calls aligned, which is what the rule is steering towards. |
| Your plan’s company also runs a Medicaid plan here, but yours is with a different company | You may stay in your plan until 2030. From 2027 that plan may not newly enroll others in your position. |
| You are joining a D-SNP for the first time in 2027 or later | If the company runs a Medicaid plan in your area, you generally need to be in that Medicaid plan too, or joining it. |
CMS set this out in its own guidance with a table of scenarios, and the first line of it is the one most people need: a company that runs a D-SNP but no Medicaid plan in your service area may carry on enrolling without these restrictions. The rule also carries written exceptions, including for people on Medicaid fee-for-service in states that do not mandate managed care, and for U.S. territories.2
3. If you are already in a plan, nothing moves yet
This is the part worth saying slowly, because it is where the worry lands. If you are already enrolled in a D-SNP and your Medicaid happens to be with a different company, the rule does not reach in and move you. CMS said it directly in its guidance: affected plans may continue to serve existing enrollees who are unaligned until 2030.2
There is even a case for people who align and then change their mind. If you join one of these plans in 2027 while in the matching Medicaid plan, and later switch your Medicaid plan to a different company, CMS has said you may remain in the D-SNP until 2030 as well. The transition was written with the assumption that people’s circumstances move around.
If you are happy with your plan, you do not have to do anything about this rule in 2026
That is worth hearing plainly, because Annual Enrollment brings a great deal of noise and not all of it is urgent. Review your plan for the usual reasons — your doctors, your prescriptions, what changed in your Annual Notice of Change. This rule is not, by itself, a reason to switch.
4. 2030, and why it matters now
Three years is far enough away to feel irrelevant and close enough to matter. From 2030, the affected plans must operate with what CMS calls exclusively aligned enrollment, and the guidance is explicit about the consequence: a plan in that position must disenrolll members who are not also enrolled in its affiliated Medicaid plan.2
| When | What applies |
|---|---|
| Now, through 2026 | No change. Enrol, stay or switch exactly as before. |
| 2027, 2028 and 2029 | Affected plans may only newly enrolll people in their own Medicaid plan. Existing members, aligned or not, may stay. |
| 2030 onward | Affected plans must be exclusively aligned, and must disenrolll members who are not in the affiliated Medicaid plan. |
That is not a reason to act in a hurry. It is a reason to know which company is on each of your cards, so that if a letter does arrive one autumn it is a decision you have already thought about rather than a surprise. Plans are also required to tell you about changes through the Annual Notice of Change each year, which remains the single most useful envelope you will receive.
Free, no obligation
Bring both cards. We will tell you in ten minutes whether this rule touches you.
5. Why Florida sits differently
Florida is a state where this rule has more reach than it would elsewhere, for a straightforward reason: the Statewide Medicaid Managed Care program is mandatory for most people receiving full Medicaid benefits, and that includes full dual eligibles. In states where managed care is voluntary, a large share of duals sit in Medicaid fee-for-service and the alignment question barely arises. Here, almost everyone is already in a managed care plan run by some company or other — which means the question of which company is live for almost everyone.3
The numbers are not small either. Florida has roughly 959,000 people with both Medicare and Medicaid, of whom about half have full benefits. South Florida carries a substantial share of them, concentrated in exactly the communities where English is a second language and a letter about enrollment alignment is the last thing anybody needs to decode alone.4
6. What to check this Annual Enrollment
Annual Enrollment runs from October 15 to December 7 for coverage starting January 1. The ordinary reasons to review a plan have not changed, and they still matter more than this rule does for most people.5
- Find both cards and read the company names. Your Medicare Advantage card and your Florida Medicaid card. If the names match, you are aligned and this rule is simply not your problem. If they do not, you now know your position.
- Read the Annual Notice of Change. It arrived in September and it lists what changes about your plan in January — costs, drug list, network. This remains the document most worth your time.
- Check your doctors and your pharmacy. Networks shift every year, and a plan that drops a specialist you depend on costs you far more than any rule about alignment.
- Check your medication list against the plan’s formulary. Prices and tiers move annually. This is usually the largest number in the comparison.
- Ask whether your plan is affected at all. If the company behind your D-SNP does not run Medicaid where you live, you can set this subject down entirely.
If nothing in your plan has changed and your doctors are still in network, staying put is a perfectly good answer. We tell people that regularly, and it costs us nothing to say so.
7. The “everything for $0” ads, and what they have to do with this
From now until December, South Florida television carries a particular kind of ad: dental, vision, hearing, a card loaded for groceries, utilities paid, everything apparently for nothing. Those ads and this rule are closer relatives than they appear.
The richest of those advertised packages are very often D-SNP benefits, available because the plan is built for people who have both Medicare and Medicaid, or they are Special Supplemental Benefits for the Chronically Ill, which federal rules restrict to enrollees with a qualifying condition. In both cases the headline figure is real for somebody, and not available to most of the people watching.
If an ad promises groceries and utilities, ask who actually qualifies
The honest answer is usually “people with both Medicare and Medicaid” or “people with a qualifying chronic condition”. Neither is a reason not to look. Both are reasons to get the eligibility question settled before the plan choice, rather than afterwards.
8. What to do now
Nothing here needs doing today. In order of usefulness:
- Put your Medicare card and your Medicaid card next to each other and write down both company names. That single step answers most of the question.
- If the names differ, note it and carry on — you have until 2030, and the plan must notify you of changes along the way.
- Read your Annual Notice of Change before December 7, for the ordinary reasons rather than this one.
- If you are joining a D-SNP for the first time, ask the plan directly whether its company runs a Medicaid plan in your county, and what that means for your enrollment.
- If any of it is unclear, ask somebody to read the cards with you. It takes about ten minutes and it is free.
9. Frequently asked questions
What is a D-SNP?
A Dual Eligible Special Needs Plan is a type of Medicare Advantage plan built for people who have both Medicare and Medicaid. The idea is that one plan coordinates both sets of benefits instead of leaving you to manage them separately. You have to qualify for both programs to join one.
What is changing in 2027?
A federal rule at 42 CFR 422.514(h) takes effect. Where a company offers a D-SNP and that same company, its parent, or a sister company also runs a Florida Medicaid managed care plan in your area, that D-SNP may only newly enrolll people who are already in, or signing up for, that company’s own Medicaid plan. It also limits that company to one D-SNP for full-benefit duals in that area.
Does this mean I have to change my plan?
Not now. If you are already in a D-SNP, the rule does not move you. CMS has said affected plans may keep serving existing members whose Medicare and Medicaid are with different companies until 2030. The restriction in 2027 is on new enrollment, not on people already there.
What happens in 2030?
From 2030 the affected plans must operate with what CMS calls exclusively aligned enrollment. At that point a plan must disenrolll members who are not also in its affiliated Medicaid plan. That is three full years away, and it is the reason to understand the rule now rather than be surprised by a letter later.
Does this apply to every D-SNP?
No, and this is the part most coverage skips. The rule only reaches a D-SNP where the same company, its parent, or a sister company also holds a Florida Medicaid managed care contract covering full-benefit duals in the same area. If your plan’s company does not run a Medicaid plan where you live, CMS says it may keep enrolling without these restrictions. There are also written exceptions in the rule.
I only have a Medicare Savings Program, not full Medicaid. Am I affected?
The rule is written around full-benefit dually eligible individuals. People with partial benefits, such as a Medicare Savings Program that pays your Part B premium, sit differently, and plans built for partial-benefit duals are treated separately. If you are not certain which you have, that is worth establishing before you make any decision.
How do I find out which Medicaid plan I am in?
Your Medicaid card shows the managed care plan name, and Florida’s Medicaid program can confirm it. Bring that card and your Medicare card together to any plan review — it is the pairing that matters under this rule, and most people have never had a reason to compare the two names side by side.
Can JCKC help me with the Medicaid side?
We are a Medicare and ACA brokerage, not a Medicaid agency. We can explain how the two fit together, read your cards with you, and help you compare the Medicare plans available where you live. For changes to Florida Medicaid itself you would go through the state program, and we can point you in the right direction.
10. Sources
- 42 CFR § 422.514(h), adopted in the Contract Year 2025 Medicare Advantage and Part D final rule and amended by the Contract Year 2027 final rule. Sets the one-D-SNP limit and the restriction on new enrollment beginning 2027, and the move to exclusively aligned enrollment in 2030.
- Centers for Medicare & Medicaid Services — CY2027 Updates: § 422.514(h) Frequently Asked Questions, updated April 2026. Confirms that affected plans may continue to serve existing unaligned enrollees until 2030, that a member who becomes unaligned after 2027 may remain until 2030, and that a parent organization without a Medicaid MCO in the service area faces no enrollment restriction. Also contains the scenario table summarised above.
- Fla. Stat. § 409.972 — Florida Statewide Medicaid Managed Care. Enrollment is mandatory for most populations receiving full Medicaid benefits, including full dual eligibles.
- KFF — Number of Dual-Eligible Individuals, Florida: approximately 959,000 dual eligibles, of whom roughly 500,000 are full-benefit.
- Medicare.gov — Medicare Annual Enrollment runs October 15 to December 7 each year, for coverage beginning January 1.
Please note: This article is general education, not advice about your situation. We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. We are not connected with or endorsed by the United States government or the federal Medicare program, and we are not a Medicaid agency. Federal rules, plan availability and Florida Medicaid policy change, and the application of § 422.514(h) depends on contracts specific to each carrier and county. Please contact Medicare.gov or 1-800-MEDICARE, 24 hours a day, 7 days a week, or your State Health Insurance Assistance Program, or Florida Medicaid, to confirm anything that affects a decision you are about to make.