September 7, 2026 · 7 min read
The new 2027 rule: your Medicare dual plan and your Medicaid plan must match
Why you generally can't have one company for Medicaid and another for your Medicare dual plan anymore — in plain English.

By David Nunley
Licensed Medicare broker · United Medicare Club, Stow, Ohio · United Medicare Club

For years, many Ohioans with Medicare and Medicaid had their Medicaid with one company and a Medicare dual plan with a completely different company. Each had its own card, its own phone number, and its own rules. Starting with 2027 plans, that arrangement is being phased out.
What the rule actually says
The rule, found in the federal regulations at 42 CFR § 422.514(h), was adopted in the 2025 Medicare Advantage final rule and refined in the 2027 final rule CMS issued on April 2, 2026. Beginning in 2027, if a company (or its parent company) offers a D-SNP and also holds a state Medicaid managed-care contract in the same area, that company:
- May offer only one D-SNP for full-benefit dual eligibles in that area, and
- Must limit new D-SNP enrollment to people who are in — or are enrolling in — its own Medicaid plan.
- Beginning in 2030, those D-SNPs may only keep members who are also in the affiliated Medicaid plan.
Industry shorthand calls this "aligned enrollment." It's the new rule people are describing when they say you can't be on one plan for Medicaid and another for Medicare.
Why CMS is doing this
The goal is fewer cards, fewer phone trees, and one care team that sees the whole picture — hospital stays, home care, behavioral health, and prescriptions together. Ohio's Next Generation MyCare program is built on exactly this model.
The tradeoffs to think about
- Pro: one plan coordinates Medicare, Medicaid, and long-term services, with a single care coordinator.
- Pro: integrated plans can offer $0 or very low prescription copays and extra benefits for aligned members.
- Con: fewer carrier choices. In Ohio, integrated plans come from a small group of companies.
- Con: your doctors must be in that one plan's network. Check before you move.
If you're in a dual plan today, you don't need to figure this out alone. Bring your letters to coffee with me or call me, and we'll look at which aligned plan keeps your doctors.
Have a question about your own situation? Send me a note from the United Medicare Club home page or call (234) 380-6282. — David
Sources
- CMS — FAQs and Enrollment Scenarios for § 422.514(h), updated April 2026
- CMS Fact Sheet — Contract Year 2027 Medicare Advantage and Part D Final Rule (April 2, 2026)
- Federal Register — CY 2027 MA and Part D Final Rule (CMS-4208-F3 / CMS-4212-F)
- UnitedHealthcare — 2027 D-SNP enrollment changes
- HHS Guidance Portal — D-SNPs: Integration & Unified Appeals & Grievance Requirements
Information current as of September 7, 2026. Rules and plan offerings change; confirm details with your plan, Medicare.gov, or the Ohio Medicaid Consumer Hotline.



