SEP Changes in 2025

We're here to help you navigate the Special Enrollment Period (SEP) changes in 2025 from the Centers for Medicare & Medicaid Services (CMS). Here's a summary of the changes that could impact you and your clients.

Dual Special Needs Plan (D-SNP) / Low-Income Subsidy (LIS) SEPs

Starting this year, CMS eliminated the quarterly SEP (code MDE) that allowed dual eligible customers and anyone with LIS to make Medicare Advantage (MA) plan changes on a quarterly basis (quarters 1-3).

The quarterly SEP was replaced by:

• A monthly SEP (code DEP) allowing all dual eligible customers and/or customers that qualify for LIS to leave their Medicare Advantage Prescription Drug (MAPD) plan for Original Medicare and join a standalone Prescription Drug Plan (PDP) or switch to a different PDP.
• A monthly integrated SEP (INT-SEP) allowing only full-benefit dual eligible customers to switch to/between integrated D-SNPs with aligned Medicaid plans. See more details below.

Despite this change, full and partial dual eligible customers can continue to use other SEPs, if available, and leverage other non-dual SEPs (i.e., new move, loss/gain of eligibility, etc.) as they do today.

More details on the monthly INT-SEP

The INT-SEP can be used once per month with an effective date the first of the following month for full-benefit dual eligible individuals. Eligible plans for the INT-SEP include:

• FIDE SNP: Fully Integrated Dual Eligible Special Needs Plan
• HIDE SNP: Highly Integrated Dual Eligible Special Needs Plan
• AIP: D-SNP that is an Applicable Integrated Plan 

Source: https://www.cms.gov/files/document/duals-lissepsjobaid01012025.pdf