Integrated care continues to be one of the most important areas of growth in Medicare Advantage.
Dual Eligible Special Needs Plan (D-SNP) enrollment grew from 2.2 million in 2018 to 5.8 million in 2024, according to KFF. By early 2025, roughly 44% of all dual-eligible beneficiaries were enrolled in a D-SNP. The number of D-SNP plan offerings grew another 12% in 2026, according to Milliman, driven in part by the required sunset of Medicare-Medicaid Plans and the transition of enrollees into D-SNP structures.
Enrollment in Chronic Condition Special Needs Plans (C-SNPs) is growing rapidly as well.
For health plans, these markets represent a significant growth opportunity. They also create a more demanding operating environment.
We have written previously about the operational requirements behind PACE programs and Medicaid plans expanding into Medicare Advantage. D-SNP growth reflects many of those same trends: complex populations, multiple regulatory requirements, specialized distribution relationships, and much less tolerance for gaps in how enrollment is managed.
As care becomes more integrated, distribution operations must also become more disciplined.
Why D-SNP Enrollment Is Operationally Different
D-SNP enrollees are eligible for both Medicare and Medicaid.
That means enrollment does not operate solely within the traditional Medicare Advantage framework. Health plans also have to account for state Medicaid eligibility, and increasingly, state-specific requirements governing how Medicare and Medicaid benefits are coordinated.
Eligibility can change as a member’s Medicaid status changes. Enrollment periods differ from general Medicare Advantage and state contracts can introduce additional requirements. Distribution may involve specialized agencies and community-based organizations serving dual-eligible populations.
All of this makes the operational record behind an enrollment especially important.
Plans need to know who enrolled the member, whether that agent was properly qualified for the product, which organization the agent represented, what eligibility and product rules applied, and how the transaction flowed through the distribution structure.
That information cannot live in disconnected systems to be manageable at scale.
A Higher Standard for Agent Oversight
CMS has steadily increased the level of structure and accountability surrounding dual-eligible enrollment.
Look-alike plans that enrolled high concentrations of dual-eligible members without meeting D-SNP requirements have been phased out. Integration requirements for Fully Integrated D-SNPs (FIDE SNPs) and Highly Integrated D-SNPs (HIDE SNPs) have increased. States are playing a larger role in how these populations are served.
The broader direction is clear that greater integration comes with greater accountability.
For health plan distribution teams, that makes accurate agent oversight especially important.
Agents selling D-SNP products need the appropriate training and certification in addition to general Medicare Advantage requirements. Plans need reliable processes to ensure those requirements are satisfied before agents begin selling.
And when questions arise about a particular enrollment, plans should be able to trace the transaction through a system of record rather than having to reconstruct it.
Four Areas Health Plans Commonly Underestimate
When health plans expand into integrated care markets, significant attention naturally goes toward the clinical model, regulatory requirements, provider relationships, benefit design, and state contracts.
But the distribution operation supporting that growth can be equally complex.
1. Certification Has to Be Managed Before the Sale
Agent certification is always important, and for D-SNP products, the consequences of getting it wrong are amplified by the population being served and the additional oversight surrounding the program.
Plans need more than a record showing that an agent completed onboarding at some point. They need ongoing visibility into whether licenses, appointments, annual certifications, and product-specific training remain current.
The goal is to identify a readiness problem before an enrollment happens.
2. Distribution Hierarchies Can Be More Complex
D-SNP distribution may involve specialized agencies, FMOs, community organizations, and other partners with deep relationships within the communities serving dual-eligible populations, making accurate hierarchy management critical.
A plan should be able to identify exactly which agent produced an enrollment, which organization that agent represented, what upline relationships existed at the time, and which organizations should receive production credit or compensation.
When those relationships change, the system managing them needs to be flexible as well.
3. Eligibility Changes Affect Compensation Operations
A member’s dual eligibility is not necessarily static. Changes in Medicaid eligibility can affect enrollment status, which can then affect commissions, adjustments, and chargebacks.
For plans accustomed to traditional Medicare Advantage distribution, the frequency and complexity of those changes can put additional pressure on commission operations.
This is where disconnected enrollment, hierarchy, and compensation systems create unnecessary work. Every change has to be reconciled across multiple records instead of flowing through a connected operational structure.
4. Reporting Has More Stakeholders
Integrated care creates another layer of reporting complexity because both CMS and state Medicaid agencies may require visibility into program activity.
The questions are not always the same making the underlying data model important. Agent, hierarchy, enrollment, and compensation records need to be structured well enough that the organization can produce different views of the operation without rebuilding the underlying story each time.
The Pattern Across Integrated Care
D-SNP, PACE, and Medicaid-to-Medicare Advantage expansion may be different programs, but from a distribution perspective they reveal the same pattern.
Growth into more complex health insurance markets creates more complex operational requirements.
The answer cannot simply be adding more people to manage the complexity manually.
Plans need infrastructure capable of managing agent readiness, complex partner structures, changing eligibility, commissions, and reporting as connected parts of the same distribution operation.
At e123, we believe this is an important distinction.
Agent operations are sometimes treated as administrative infrastructure that sits behind the “real” work of launching and managing a health plan’s products.
In integrated care, that distinction becomes difficult to maintain.
The way agents are onboarded, certified, organized, compensated, and monitored directly affects the integrity of the enrollment operation.
For populations with complex health care and social needs, that matters.
How e123 Helps
e123 Abacus™ gives health plans a connected system for managing the distribution operations behind integrated care growth.
Agent onboarding, licensing, and certification tracking help plans identify readiness gaps before an enrollment occurs. Hierarchy management supports complex agency and partner structures. Commission administration connects compensation to the corresponding enrollment and hierarchy records. Reporting gives plans a consistent operational record for understanding what happened across the distribution channel.
The opportunity in D-SNP and other integrated care markets is significant.
But sustainable growth requires operational infrastructure capable of supporting the complexity that comes with it.
If your health plan is expanding in D-SNP, PACE, or other dual-eligible markets, e123 can help you evaluate whether your current agent and distribution operations are built to support that growth.
Book a call with our team to learn how e123 can power your growth.
