LeadingAge NY Comments on 2026 SMAC Contract

(April 28, 2025) In comments on the 2026 draft State Medicaid Agency Contract (SMAC) for Dual-Eligible Special Needs Plans (DSNPs), LeadingAge NY called for greater clarity surrounding the State's vision for integrated managed care for beneficiaries who are dually eligible for Medicare and Medicaid. The association's comments focused on the implications of the draft contract for integrated managed care plans, sponsored by non-profit long-term care providers.

The SMAC governs the obligations of DSNPs to coordinate services and benefits for dually eligible beneficiaries. It includes provisions related to comprehensive assessments of beneficiaries, coordination of benefits, care coordination, supplemental benefits, sharing of information, enrollment and service area expansions, and the grievance and appeals processes.

The 2026 SMAC implements the 2025 federal Medicare Advantage and Part D Final Rule. The Rule continues the efforts of the Centers for Medicare and Medicaid Services (CMS) to promote integration of Medicare and Medicaid managed care coverage and to encourage the enrollment of dually eligible beneficiaries in integrated plans. The Rule seeks to accomplish this by allowing Medicare Advantage Organizations (MAOs) to offer only one DSNP in the same service area as its affiliated Medicaid managed care product. In NY, there is an exception to this limit for MAOs that offer both a Medicaid Advantage Plus (MAP) product and a DSNP paired with a partially capitated Managed Long-Term Care (MLTC) product. In addition, beginning in 2027, the Rule limits new enrollment in a DSNP with an affiliated Medicaid managed care product to individuals who are also enrolled in the Medicaid product. By 2030, all enrollees of these DSNPs will have to be enrolled in the affiliated Medicaid managed care product.

LeadingAge NY's comments stressed the importance of transparency regarding the State's intentions for integrated managed care going forward so that plans can develop appropriate strategies for the future. The comments raised a number of questions regarding the future of certain integrated plan arrangements and the implementation of various contract provisions.

The association's comments are available here.

Contact: Karen Lipson, klipson@leadingageny.org