D-SNP operating infrastructure
Regional and community health plans are being forced into D-SNP by federal mandate — without the infrastructure to run it. DualWorks is the operating layer they need to launch, comply, and compete.
Federal mandates
D-SNP enrollment has tripled since 2018. National carriers spent a decade building the infrastructure to run these plans profitably. Regional and community plans are being given a fraction of that time, under federal mandate, with far fewer resources.
Look-alike plans lose CMS contracts. Non-SNP MA plans that hit 60% dual eligible concentration can no longer crosswalk members into other MA plans — only into D-SNPs. Enter or lose the members.
New enrollment restricted to aligned members only. D-SNPs with affiliated Medicaid MCOs can only enroll members who are simultaneously enrolled in that MCO. One D-SNP per service area per parent organization.
Unaligned member disenrollment required. Plans must disenroll every member not enrolled in the affiliated Medicaid MCO. Approximately 67,000 members face displacement in Wisconsin alone.
States are raising the integration floor. Michigan launched MI Coordinated Health in January 2026, requiring nine contracted plans to cover full LTSS under a capitated contract. Wisconsin, Colorado, California, and New York are moving the same direction.
Where plans struggle most
The operational challenge isn't one thing. It's every function running simultaneously, without the institutional muscle nationals built over years.
Revenue at risk
Risk adjustment undercoding
FQHCs' prospective payment model creates a structural coding gap. Behavioral health diagnoses go systematically undocumented. Plans lose risk-adjusted revenue they've already earned — and can't recover it at year-end.
Quality
Stars without infrastructure
Medicaid-focused plans discover Stars gaps in their third year, when they're already at 2.5. Quality measures aren't being tracked across departments — they're found at audit time when it's too late to close them.
Compliance
Model of Care audit exposure
CMS audits what the plan committed to in its Model of Care — HRA completion rates, individualized care plans, LTSS coordination. Most plans have no system to know their audit readiness in real time.
Launch
No playbook for new entrants
A first D-SNP requires CMS application, Model of Care, NCQA approval, Medicaid network adequacy, care management infrastructure, unified appeals — all simultaneously. No vendor has built this specifically for regional plans.
The platform
Every D-SNP commits to CMS exactly how it will identify, assess, and manage its members. DualWorks operationalizes that commitment across the full MOC-to-P&P-to-workflow stack — so every workflow, every member record, and every audit trail reflects what your plan said it would do. No other vendor in this market connects those three layers for community plans.
Who we serve
DualWorks is not for United, Humana, or Centene. It's for the regional Blues plans, health system-owned insurers, and community-rooted plans that hold the member relationships — and are now being asked to build the operational muscle to match.
Regional Blues plans
Single-state or regional Blues affiliates entering D-SNP for the first time or scaling existing programs under consolidation pressure.
E.g. BCBS Michigan, Capital Blue Cross, BCBS Alabama, Premera
Community health plans
ACAP-member plans and FQHCs-owned insurers operating D-SNP under state mandate, often with Medicaid as the core competency — not Medicare.
E.g. LA Care, SCAN, Healthfirst, VillageCare, Jefferson Health Plans
Health system plans
Hospital-owned or provider-sponsored organizations building D-SNP to anchor their integrated care model and retain dually eligible patients.
E.g. UPMC Health Plan, Presbyterian Health Plan, HAP CareSource
County and public plans
County-run Medi-Cal managed care plans now required to unify under a Medicare Advantage contract — entering D-SNP with no institutional infrastructure for it.
E.g. Partnership HealthPlan, San Francisco Health Plan, Alameda Alliance
The team
DualWorks was founded on a simple observation: the tools health plans are handed to run complex government programs were not designed for those programs.
Amy Wang
Founder
Most recently Chief of Staff at Malama Health (YC S22), where as employee #1 she scaled operations from $120K to $3M+ ARR across 15 Medicaid MCOs in California, Texas, and Colorado — building the care managment model, AI-enabled infrastructure, and care delivery team that earned 90+ audit scores across all health plan partners.
Prior to Malama, Amy led enterprise Mental Health Parity governance across legal, clinical, product, and network teams at Health Care Service Corporation. She holds an MPA from the University of Wisconsin-Madison.
Request access
DualWorks is actively working with its first plans. If you're building, scaling, or aligning a D-SNP — or you're a reinsurer, advisor, or investor working in this space — reach out.
We respond within one business day.
We'll be in touch within one business day. In the meantime, if you're building a D-SNP and need something faster, email [email protected] directly.