As 2026 approaches, healthcare leaders continue to grapple with the volatility of policy shifts, regulatory oversight, and evolving care models. Nowhere is this uncertainty more visible than in the management of dual-eligible populations: individuals enrolled in both Medicare and Medicaid. These members represent some of the most complex, high-cost, and high-need patients in the US healthcare system. How do you provide integrated, value-driven care for duals in a policy environment that feels anything but stable?
The answer lies in doubling down on value-based approaches, specifically through specialized Dual Eligible Special Needs Plans (D-SNPs), policy-informed care management strategies, and integrated care models designed to reduce fragmentation and deliver measurable outcomes.
Review D-SNP-specific strategies that can help health plans strengthen dual-eligible care management in 2026.
The Policy Backdrop: What’s Changing in 2026
Policymakers are signaling continued scrutiny of costs across federal health programs. With total Medicare enrollment at 68.9 million1 and Medicaid at more than 78 million,2 states and CMS are pushing for tighter alignment between programs to reduce duplication and waste. For dual-eligible populations, this convergence is critical, and several policy trends are shaping the landscape.
- D-SNP Integration Requirements: Federal regulators have continued to expand requirements that D-SNPs coordinate closely with state Medicaid agencies. D-SNPs will need to demonstrate stronger integration around care coordination, supplemental benefits, and member engagement.
- Value-Based Payment Expansion: CMS Innovation Center models are shifting focus to population-based payment and accountability for total cost of care, reinforcing the need for value-driven D-SNP strategies.
- Quality & Equity Benchmarks: New measures tied to health equity, behavioral health integration, and social determinants of health are placing added accountability on health plans. D-SNPs that cannot address these factors risk falling behind in Star ratings and contract renewals.
- Digital Data Mandates: Interoperability and digital quality measurement will move from optional to expected. Plans must be able to integrate data from disparate systems to monitor duals effectively.
For health plans, the mandate is clear: align with policy shifts, build scalable integrated models, and adopt value-based strategies that balance cost and quality.
DSNP-Specific Strategies: Resilience Through Specialization
Duals face multiple chronic conditions, behavioral health needs, and social barriers. D-SNPs remain the most effective vehicle for addressing these complexities, but success depends on how plans adapt their strategies.
- Enhanced Care Coordination
Plans that invest in multidisciplinary teams including care managers, pharmacists, behavioral health providers, and community-based partners can break down silos that often fragment dual care. - Member Engagement That Works
Engagement requires going beyond standard outreach. In 2026, the most effective DSNPs will use culturally sensitive, personalized communication strategies and deploy digital tools that simplify access to care. - Leveraging Supplemental Benefits
Benefits like transportation, meals, and housing assistance are not just “nice to have.” They’re critical tools for managing utilization and improving member satisfaction. As policy changes expand flexibility, DSNPs must use supplemental benefits strategically to demonstrate value. - Aligning Incentives with Providers
DSNPs that move providers toward value-based contracts tied to outcomes for duals, not just utilization, will create more sustainable care ecosystems. These arrangements encourage providers to prioritize quality, care coordination, and long-term outcomes rather than short-term volume.
For a deeper dive into how case managers can play a pivotal role in supporting high-risk populations, read our blog: 5 Ways Case Managers Can Support High-Risk Populations.
Integrated Care Models: From Concept to Execution
The next era of dual-eligible care management is about integration not just of benefits, but of care models, financing, and data systems. Integrated care models offer health plans a framework for delivering consistency in uncertain times.
CMS defines value-based care as care that prioritizes quality, provider performance, and the patient experience.3 For dual-eligible populations, these principles are most effectively realized through integrated care models that reduce fragmentation and enhance coordination across providers.
- Clinical Integration
Embedding behavioral health and long-term services and supports into medical management creates a unified care pathway for duals. This integration reduces hospitalizations, improves adherence, and enhances member outcomes. - Operational Integration
Plans that align operational functions — from UM to claims processing — can eliminate redundancies and reduce administrative burden. In a BPaaS (Business Process as a Service) model, for instance, functions like UM or provider credentialing can be reimagined for efficiency and scale. - Financial Integration
Shared-risk models between Medicare and Medicaid create alignment of incentives, reducing the “cost-shifting” that often undermines care for duals. States piloting integrated financing will set the tone for broader adoption. - Data Integration
As interoperability requirements expand, integrated models must harness data across systems. This means not only collecting data, but also applying analytics to identify gaps, predict risk, and target interventions.
For an example of how health plans can build a more effective D-SNP case management model, see our case study: Empowering Effective D-SNP Case Management.
Health plans that embrace integrated care models are better positioned to weather policy shifts while delivering real value to dual members.
Looking Ahead: Care Management in 2026
The uncertainty facing federal health programs is not going away. But for health plans serving duals, uncertainty does not have to mean instability. By anchoring strategies in value-based approaches, plans can navigate regulatory shifts and build resilience.
Key Takeaways for 2026
- Policy changes will continue to push D-SNPs toward deeper integration and accountability
- Value-based strategies, especially those that align incentives and leverage supplemental benefits, will be critical differentiators
- Integrated care models supported by digital tools and data-driven insights will define the next phase of dual-eligible care management
In uncertain times, the health plans that succeed will be those that embrace integration, anticipate policy shifts, and commit to value as the foundation for care management.
Find a Partner in Choppy Waters
Dual-eligible populations bring complexity but also opportunity. As 2026 ushers in new requirements and heightened expectations, health plans have a chance to redefine how they deliver care management. By investing in DSNP-specific strategies, adopting integrated models, and staying ahead of policy changes, plans can create lasting value for duals and the broader healthcare system.
Clearlink Partners stands ready to support health plans in this journey, bringing proven expertise in utilization management, value-based approaches, and integrated operations. Contact us for more information on our capabilities and proven track record for supporting D-SNPs.
Sources:
1. Medicare Monthly Enrollment, Centers for Medicare & Medicaid Services
2. April 2025 Medicaid & CHIP Enrollment Data Highlights, Medicaid.gov
3. Value-Based Care, Centers for Medicare & Medicaid Services