In some cases.   If you are eligible for both Medicare and Medicaid or Medicare Part D Extra Help, you are granted a Special Enrollment Period and can change Medicare Part D prescription drug plans (PDPs) once per month from January through November with coverage starting on the first day of the month after you enroll in a new plan.

However, starting in 2025, after the close of the Medicare Advantage Open Enrollment Period (MA-OEP ending March 31st), your ability to change Medicare Advantage plans during the year will be limited and will depend on the type of Medicare Advantage plan you wish to join.

Reminder: If you are eligible for both Medicare and Medicaid (Dual-Eligible) then you are automatically qualified for Medicare Part D Extra Help and this Special Enrollment Period.


Special Enrollment Periods for people qualified for both Medicare and Medicaid - or the Medicare Part D Extra Help program:

• People enrolled in a stand-alone Medicare Part D plan (PDP) and eligible for the Medicare Part D Low-Income Subsidy (LIS) or Extra Help program will have a monthly opportunity to change their PDP. 
  
  
• Important 2025 change:  Most Medicare beneficiaries enrolled in a Medicare Advantage plan (MA, MAPD, or SNP), and eligible for Extra Help will no longer be granted a Special Enrollment Period (SEP) to join or change Medicare Advantage plans.
  
  
• However, an Extra Help recipient will be granted a Special Enrollment Period to drop their Medicare Advantage plan, return to Original Medicare, and join a stand-alone Medicare Part D PDP.
  
  
• And, people who are dually-eligible for Medicare/Medicaid and enrolled in an integrated Medicare Advantage D-SNP (FIDE D-SNP, HIDE D-SNP, or AIP) will be able to change month-to-month to another qualifying integrated D-SNP.
  
  
• Please note that Low-Income Subsidy or Extra Help recipients can still use the MA-OEP or other Special Enrollment Periods to change Medicare Advantage plans outside of the annual Open Enrollment Period (from October 15 through December 7).

Question: Where can I see a Medicare Advantage D-SNP’s level of Medicare/Medicaid integration?

The Q1Medicare Medicare Advantage plan finder coverage details include information on whether a Dual-Eligible Medicare Advantage Special Needs Plan (D-SNP) is a: 

• Fully-Integrated Dual-Eligible (FIDE) SNP, 
• Highly-Integrated Dual-Eligible (HIDE) SNP, or 
• Coordination-only D-SNPs
  and whether the D-SNP is designated as an Applicable Integrated Plan (AIP) and/or a Medicare Zero-Dollar cost-sharing plan.

Example screen from the 2025 Medicare Advantage plan finder (clicking on the D-SNP plan name will show the plan's coverage details).



Using this Special Enrollment Period
You can use the SEP to change stand-alone Medicare Part D plans (or drop your Medicare Advantage plan or change to a similar HIDE, FIDE, or AIP Medicare Advantage D-SNP) by telephoning a Medicare representative at 1-800-633-4227 (TTY 1-877-486-2048)  - or you can contact the Medicare plan directly - or you can submit a printed enrollment application to your chosen Medicare plan.

Your new plan coverage will start on the first day of the month after your enrollment.  For example, if you decide to use the Extra Help SEP and submit an enrollment application in September, your new Medicare Part D coverage will begin on October 1st.


Medicare history:  From 2019 to 2024, if you qualified for Medicare Part D Extra Help* - you could change Medicare plans three times a year.

From 2019 through 2024, if you were eligible for the Medicare Part D Extra Help or the Low-Income Subsidy (LIS) program, you were granted a Special Enrollment Period (SEP) that allowed you to change Medicare Part D or Medicare Advantage plans once per quarter any time during the first nine (9) months of the plan year.

*Note: 2023 was the last year for partial-Extra Help.  For plan year 2024 and beyond, the Inflation Reduction Act (IRA) of 2022 increases full-Extra Help benefits to people at or below 150% of FPL and consequently, the current partial Extra Help (135% to 150% of FPL) designation will be eliminated.


More Medicare history:  Prior to 2019, the Dual-Eligible (Medicare/Medicaid) SEP was a continuous month-to-month SEP.

Prior to January 2019, Medicare beneficiaries who were dual-eligible (Medicare/Medicaid) or eligible for the Medicare Part D Extra Help program (or low-income subsidy) were granted a "continuous" month-to-month Special Enrollment Period (SEP)  - where a person could actually change Medicare Part D or Medicare Advantage plans every month (though November).  Then, as noted above, from 2019 through 2024, the Dual-Eligible or Extra Help SEP could “be used only once per calendar quarter during the first nine months of the year.”

Why would I want to change to a different Medicare Part D plan?

Even if you stay with the same Medicare plan from last year, you may find that your Medicare Part D or Medicare Advantage plan coverage is different than last year.  So, you may decide to change Medicare plans in the middle of the year if:

• Your medications are no longer covered by your plan and you have not been able to have your plan approve your Formulary Exception request.  (Your plan has not agreed to cover your non-formulary drugs.)
  

• Your medications are governed by strict Usage Management Restrictions (like Quantity Limits or require Prior Authorization).

• You now have a monthly premium for your Medicare Part D plan because your plan no longer qualifies for your state's LIS $0 premium.
  
  
• Your local pharmacy is no longer included in your plan's pharmacy network - or your plan no longer offers a mail-order option.
  
  
• Your Medicare Advantage plan no longer includes some of your healthcare providers (doctors or local hospitals) within the plan's network.
  
  
• Another Medicare Advantage plan is available in your area that covers all your prescriptions, healthcare providers, and adds some additional benefits such as health club memberships, hearing coverage, and/or vision coverage.
  
  

If you are filling out a printed enrollment application to change Medicare plans during the year, you will use the application section for Special Enrollment Periods and then choose the SEP that applies to you.  You will probably read something like the following text on the enrollment application:

"Typically, you may enroll in a Medicare Prescription Drug Plan only during the annual enrollment period [OEP] from October 15 through December 7 of each year. Additionally, there are exceptions that may allow you to enroll in a Medicare Prescription Drug Plan outside of the annual enrollment period."
...

• I have both Medicare and Medicaid or my state helps pay for my Medicare premiums.
  
  
• I get extra help paying for Medicare prescription drug coverage.
  

...

Guidance from Medicare to help you determine your eligibility for this SEP

Dual (Medicare/Medicaid) Eligible
- Do you currently have Medicaid coverage?
- Did you recently receive a yellow letter from CMS?
- Does your state pay for your Medicare premiums?
- Have you recently lost coverage under Medicaid?

Other Low-Income Subsidy
- Have you recently been approved for [Medicare Part D] extra help?
- Have you recently received a green letter from CMS?
- Do you receive SSI cash benefits without Medicaid?
- Did you receive a letter from Medicare letting you know that you automatically qualify for extra help?
- How much do you pay for your prescriptions?

More guidance from the 2025 Medicare Prescription Drug Benefit Manual: Medicare Enrollment and Disenrollment:


Section 30.6.7 – SEP for dual- or other LIS-eligible individuals - 42 CFR §§ 423.38(c)(4) and 423.153(f)

"The SEP for low-income subsidy eligible individuals is a Part D SEP that allows a “full-benefit dual eligible individual” or “partial-benefit dual eligible or other low-income subsidy (LIS) eligible individual” (see § 10) to enroll once per month into any standalone prescription drug plan but does not permit enrollment into MA-PD plans or changes between MA-PD plans.

The SEP may be used once per month with an effective date of the first of the following month.

NOTE: An individual is not eligible for this SEP if the individual has been identified as an “at-risk beneficiary” or “potential at-risk beneficiary” (see § 10). This SEP limitation starts when the individual receives the initial notice from the Part D plan that they are an at-risk beneficiary or a potential at-risk beneficiary and ends when one of the following situations occur . . .”


In 2025, CMS also added a new Special Enrollment Period for dual-eligible (Medicare/Medicaid) recipients to change their D-SNP Medicare Advantage plans – but only to D-SNPs that provide integrated or aligned services with a state’s Medicaid managed care organization. (CMS noted that these integrated D-SNPs make up only about 5% of all MAPDs that can enroll dually eligible beneficiaries).


Section 30.6.35 – SEP for integrated care - 42 CFR § 423.38(c)(35)

"The integrated care [special enrollment period] allows enrollment once per month into a FIDE SNP [Fully Integrated Dual Eligible Special Needs Plan], HIDE SNP [Highly Integrated Dual Eligible Special Needs Plan], or AIP [Applicable Integrated Plan] for dually eligible individuals who are enrolled in or in the process of enrolling in the D-SNPs affiliated Medicaid MCO [managed care organization].  The integrated care SEP is available only to facilitate aligned enrollment, as defined in § 422.2, in the FIDE SNP, HIDE SNP, or AIP and the affiliated Medicaid MCO.

The SEP may be used once per month with an effective date of the first of the following month.”
[emphasis and formatting added]


Source:
New combined 2025 Medicare Advantage and Part D Enrollment and Disenrollment Guidance Updated: 2024

Chapter 3 - Eligibility, Enrollment and Disenrollment, Updated: August 19, 2011 (Revised: November 16, 2011, August 7, 2012, August 30, 2013, August 30, 2014, July 6, 2015, September 1, 2015, September 14, 2015, December 30, 2015,May 27, 2016, August 25, 2016, June 15, 2017, July 31, 2018, August 12, 2020 & August 15, 2023), Section 30.3.2 – SEP for Dual- and Other LIS-Eligible Individuals 42 CFR 423.38(c)(4) (Rev. 1, Issued: July 31, 2018; Effective/Implementation: 01-01-2019)