D-SNP Network Requirements: A Complete Guide for New Plans

What Makes D-SNP Network Requirements Different

Dual Eligible Special Needs Plans (D-SNPs) serve Medicare beneficiaries who are also enrolled in Medicaid — a population with complex health needs, high rates of chronic conditions, and significant reliance on both medical and social services. The network adequacy requirements for D-SNPs are not simply the standard Medicare Advantage requirements reapplied to a different population. They include D-SNP-specific requirements layered on top of the MA base requirements, reflecting both CMS's recognition that this population needs enhanced access and the programmatic requirements that come with coordinating care between Medicare and Medicaid.

New D-SNP plan teams — particularly those launching D-SNPs as a new plan type within an existing MA organization — frequently underestimate the scope of D-SNP-specific requirements. This guide covers the key areas where D-SNP requirements differ from standard MA requirements.

The MIPPA Foundation and State Medicaid Integration

D-SNPs are authorized under the Medicare Improvements for Patients and Providers Act (MIPPA) and must have a Fully Integrated Dual Eligible (FIDE) SNP designation, a Highly Integrated Dual Eligible (HIDE) SNP designation, or a standard D-SNP status — each with different integration requirements with the state Medicaid program. The plan's integration status directly affects its network requirements because more integrated plans must build networks that can coordinate both Medicare and Medicaid services for members.

D-SNPs must enter into a Memorandum of Understanding (MOU) with the state Medicaid agency, and the terms of that MOU may specify network requirements beyond those CMS imposes directly. Plans should review the state's MOU template carefully during the market entry planning phase, as MOU requirements vary significantly by state and can include provisions related to LTSS provider networks, behavioral health integration, and care coordination infrastructure that go beyond standard MA network standards.

Provider Type Requirements Beyond Standard MA

D-SNPs must demonstrate network adequacy for all standard MA specialty types plus additional provider categories relevant to the dual eligible population. Required provider types that may not be standard in non-SNP MA plans include:

• Long-term services and supports providers: Personal care attendants, home health agencies, adult day health programs, and residential care facilities, depending on the scope of LTSS services the D-SNP covers under its Medicaid contract
• Behavioral health integration: Many states require D-SNPs to demonstrate enhanced behavioral health network adequacy given the high prevalence of mental health and substance use disorders in the dual eligible population
• Care coordination staff: D-SNPs must have care coordination staff — typically nurses and social workers — who are geographically distributed to serve members. CMS has increasingly scrutinized whether care coordinators are actually accessible to member populations, not just employed at plan headquarters
• Transportation network: D-SNPs that include non-emergency medical transportation (NEMT) as a benefit must maintain a contracted transportation network with sufficient capacity to serve member volume

Credentialing Complexity for LTSS Providers

Credentialing LTSS providers — personal care agencies, adult day programs, home health agencies — requires different credentialing standards than physician credentialing. These providers are licensed at the entity level (the agency), not the individual level, and their credentialing involves verification of state licensure, Medicare and Medicaid certification, liability insurance, background check processes for direct care workers, and quality and compliance history. Plans new to credentialing LTSS provider types should not assume their physician credentialing workflow applies — it does not, and applying the wrong standards creates compliance gaps.

Provider Directory Requirements for D-SNPs

D-SNP provider directories must accurately reflect the full scope of the plan's network, including LTSS providers, behavioral health providers, and care coordination resources — not just the medical network. CMS's directory accuracy requirements apply to all listed provider types, meaning the 90-day verification cycle must cover LTSS providers as well as physicians. Many plans that perform well on physician directory accuracy fail on LTSS provider directory accuracy because they have not extended their verification workflows to cover non-physician providers.

D-SNP directories must also accurately reflect which providers have specific experience or training in serving the dual eligible population, including Culturally and Linguistically Appropriate Services (CLAS) standards compliance, as this information is material to member access decisions for this population.

Continuity of Care Requirements

D-SNPs are subject to specific continuity of care requirements when a member transitions from fee-for-service Medicare or from another D-SNP. The plan must maintain coverage for ongoing courses of treatment with out-of-network providers for a defined transition period, and the network must include sufficient providers to absorb members transitioning from other plans. Plans entering new markets must assess not just their own network adequacy but whether their network has sufficient capacity to serve members who will transition at the next open enrollment period.

Integrated Model Reporting

CMS requires D-SNPs to report on their integration with state Medicaid programs, and this reporting includes network integration measures. Plans with FIDE SNP status must demonstrate that their Medicare and Medicaid networks are integrated — meaning members do not experience fragmented access when their care involves both Medicare and Medicaid services. Network adequacy reporting for FIDE SNPs requires coordination between the plan's MA network team and its Medicaid managed care counterpart, and plans that operate both an MA and a Medicaid MCO under separate organizational structures often struggle with this coordination.

Getting D-SNP Network Build Right from the Start

D-SNP network builds that do not account for the additional provider type requirements, LTSS credentialing complexity, and state MOU network provisions from the beginning consistently find themselves with gaps that are difficult to close close to the filing deadline. The key is to begin with a D-SNP-specific provider requirements map — not the standard MA specialty type list — and to engage with the state Medicaid agency's managed care unit early in the process to understand MOU network provisions before finalizing the build plan.