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Score your buildDual Eligible Special Needs Plans must have a contract with the state Medicaid agency under 42 CFR 422.107 in every state where they operate. That contract runs on the state's timeline, and it can shape your network build.
Under 42 CFR 422.107, a Medicare Advantage organization that offers a Dual Eligible Special Needs Plan (D-SNP) must have a contract with the state Medicaid agency in each state where the D-SNP operates. It governs how the plan coordinates Medicare and Medicaid benefits for dual-eligible members. Every D-SNP needs one, on the state's own timeline.
The reason is structural: D-SNP members receive benefits from both Medicare and state Medicaid, so the plan and the state have to work together. States can ask for more than the federal minimum, which is why D-SNP network and compliance teams must engage each state individually rather than applying one national approach.
The contract is between the MA organization and the state Medicaid agency, and plan leadership usually handles the signature. The network ops team is rarely involved in that step. But network ops should own the substance of any network provisions, and make sure those commitments are achievable.
A common failure is a disconnect between what plan leadership commits to and what the network ops team has built. If the state contract calls for specific provider types or access standards beyond CMS's, the network has to deliver them. Network ops teams left out of the discussion can discover late that they are being held to standards they did not know existed. So bring them in early.
Read each state contract for terms that affect network operations, such as:
How long the contract takes depends on the state agency, the complexity of your proposed D-SNP model, and whether the state uses a standard template. We don't have a reliable figure for how long this takes across states, so ask the state Medicaid agency directly, and ask other questions early: does it use a template, and when does it want a request?
Renewals and changes need planning too, especially if you are expanding the D-SNP service area or changing your level of integration.
It is a serious mistake to treat the state contract as paperwork to complete after the network has been built. You may discover that the state expects provider types or access standards your network wasn't designed for, or data sharing your systems don't support.
Begin the state conversation in parallel with, or before, the network build, because it reveals what the state expects. A plan that learns late in a build that the state requires something specific faces a very different task than one that learned it at the start. Network development leads should review draft network language before anyone agrees to it.
Requirements vary across states, and network ops teams operating in multiple states can't assume one state's terms are representative of another's. Some states may ask for little beyond the federal minimum, while others have integrated programs with more demanding terms. Get help from experienced D-SNP compliance counsel if you are entering one of those states for the first time.
Keep the state contract on your compliance calendar next to CMS's application dates, and confirm with CMS what it needs from you and when. CMS notes its application dates are subject to change, so check them each cycle.
Build a multi-state calendar that maps each state contract's end date, when to start renewal with the state, and the CMS dates that depend on it. The compliance function should own it, with network ops input. Build in a buffer, because a state agency's timeline is outside your control.
Without a contract with the state Medicaid agency, a plan can't meet the 42 CFR 422.107 requirement for its D-SNP in that state, and existing enrollees could face a coverage transition. If you see that risk, talk to your CMS Account Manager and your compliance counsel right away. The safest approach is to keep an active relationship with the state, start renewals early, and escalate any impasse to plan leadership well before the CMS deadline.
Blueprint automates the network build workflows described in this article: from adequacy modeling to provider outreach tracking. See it with your state and line of business.