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Policy Proposals to Advance Integrated Care

  • eschutz35
  • Nov 20, 2025
  • 1 min read

Updated: Nov 21, 2025

Today approximately 10 percent of individuals who are dually eligible for both Medicare and Medicaid are enrolled in managed care plans that fully integrate their Medicare and Medicaid coverage. The remaining dually eligible individuals must navigate a complex system of overlapping coverage and disconnected services. Despite significant regulatory and legislative activity around advancing integrated care models at both the state and federal level, many barriers remain.


The National MLTSS Health Plan Association has developed a series of policy proposals to address existing barriers to integration and to advance and grow the enrollment of dually eligible enrollees in an integrated model. Our proposals are predicated on our steadfast position to build on the existing Dual-Eligible Special Needs Plan (D-SNP) framework and recognize the unique progress of each state towards advancing integrated care. D-SNPs have been the fundamental, permanent vehicle for delivering integrated care benefits, and CMS continues to emphasize the importance of focusing efforts to iterate upon the existing D-SNP framework to improve care for dually eligible enrollees. Below, we identify the requisite statutory and regulatory changes needed to advance D-SNPs forward in providing more integrated, holistic, and accessible care for enrollees.


Our D-SNPs and managed long-term services and supports (MLTSS) health plans with years of experience serving dually eligible enrollees have developed models to support complex populations in a targeted way. MLTSS Association members have acquired and honed specialized skills to deliver services to the dually eligible population and are well-positioned to continue building upon their existing programs and operations to provide a more person-centered, integrated health care experience for the most vulnerable populations.



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