Medicare Advantage D-SNP Look-Alike Plans
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D-SNP “look-alike" plans are Medicare Advantage (MA) plans that are marketed to, and have membership consisting of at least 60 percent dual eligible beneficiaries. However, unlike true D-SNPs, D-SNP look-alike plans do not provide care coordination and wrap-around services. Starting in 2025 the threshold for determining a D-SNP look-alike plan was lowered from 80 percent to 70 percent and will be reduced to 60 percent in 2026. These plans often have marketing names that sound like D-SNPs, using the terms “coordinated" or “dual." Look-alike plans may be unattractive to non-dual eligible beneficiaries because they often have higher cost-sharing requirements – which only dual eligible beneficiaries are not required to pay.
Because look-alike plans target dual eligible individuals but are not subject to integration requirements that benefit duals, the federal Centers for Medicare & Medicaid Services (CMS) issued regulations in 2020 that required MA organizations to discontinue D-SNP look-alike plan contracts effective January 1, 2023. In addition, CMS issued regulations in 2024 that result in additional MA plans being categorized as look-alike plans, and require MA organizations to discontinue additional D-SNP look-alike plan contracts effective January 1, 2025. The 2020 and 2024 federal regulations also provide an option for those MA organizations to transition their look-alike members to other MA plans offered by the same organization, either true D-SNPs or regular MA plans with $0 premium. MA plans will work with CMS to implement membership transitions needed to comply. The most recent information and guidance from CMS to MA organizations on this transition can be found on the CMS.gov website. More specific information about the 2023 transition is here. The transition is designed to provide continuity of care and cost-sharing protections for dual eligible beneficiaries, as well as provide better care options for people currently enrolled in a look-alike plan.
MA organizations with look-alike plans are required to send notices in the fall to their members with information about the plan transition. Previous guidance from CMS to MA organization on this transition can be found on the DHCS website.
