With roughly 125,000 people enrolled in I-SNPs representing about 12% of long-stay nursing home residents, this shift could directly affect how SNF-linked plans are structured and governed.
Contract Year 2027 Medicare Advantage and Part D Proposed Rule
The second RFI addresses the significant growth in chronic condition special needs plans (C-SNPs) enrollment, with particular concern about dually eligible individuals enrolling in these plans rather than dual eligible special needs plans (D-SNPs) that offer integrated Medicare-Medicaid benefits. CMS is exploring potential solutions including adopting a State Medicaid Agency Contract requirement for C-SNPs and/or institutional special needs plans (I-SNPs) with high concentrations of dually eligible individuals, like existing D-SNP requirements.
— CMS.gov, November 25, 2025
Centers for Medicare & Medicaid Services. “Contract Year 2027 Medicare Advantage and Part D Proposed Rule.” CMS.gov, 25 Nov. 2025. https://www.cms.gov/newsroom/fact-sheets/contract-year-2027-medicare-advantage-part-d-proposed-rule.
Medicare Advantage and Medicare Prescription Drug Programs Expected to Remain Stable in 2026
Based on plans’ projections, enrollment in MA is projected to be 34 million in 2026, a decrease from 34.9 million in 2025, with MA enrollment representing approximately 48% of all people enrolled in Medicare, compared to 50% in 2025. However, based on recent historical experience and enrollment trends, CMS anticipates that enrollment in MA in 2026 will be more robust than the plans’ projections and that enrollment will be stable.
— CMS.gov, September 26, 2025
CMS pitches star ratings reform in 2027 Medicare Advantage rule: 7 notes
CMS published its 2027 Medicare Advantage and Part D proposed rule on Nov. 25 that includes an overhaul of how star ratings are calculated, new enrollment flexibilities, and rollbacks of Biden-era health equity requirements. The proposed rule is subject to a 60-day public comment period. A final rule is expected in spring 2026, with most provisions taking effect for contract year 2027.
— Becker’s Payer Issues, November 26, 2025
CMS: Dual-Eligible I-SNP Enrollment May Warrant More State Involvement, but Info Needed
I-SNPs are Medicare Advantage plans tailored for people who require a nursing home level of care. Some I-SNP beneficiaries are eligible for both Medicare and Medicaid coverage; however, I-SNPs “do not integrate Medicare and Medicaid benefits and may not be the best approach for meeting the needs of dually eligible individuals,” CMS stated in a proposed rule issued Tuesday. That same concern applies to dual eligible beneficiaries in chronic condition special needs plans (C-SNPs).
— Skilled Nursing News, November 25, 2025
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