How CMS Reinterpretations Paved Way for MA Supplemental Benefits

Over the last couple of years, Medicare Advantage supplemental benefits have seen a great deal of reinterpretation that has led to their expansion and evolution, a Milliman brief commissioned by Better Medicare Alliance found.

The brief analyzed five benefits that became more broadly accessible due to CMS guidance from 2018 and 2019: adult day health services, home-based palliative care, in-home support services, caregiver support, and therapeutic massages.

“Not even a global pandemic could disrupt the positive trend of expanded supplemental benefit offerings in Medicare Advantage, as plans find new ways to care for the whole person and address social determinants of health,” said Allyson Y. Schwartz, president and chief executive officer of the Better Medicare Alliance.

“With the uptake of these benefits expanding yet again – an increase of 64% year over year – it’s clear that CMS’s flexibilities have met a need and Medicare Advantage plans are responding with innovations in benefits and care delivery. These benefits, not available in Traditional Medicare, help seniors remain in their homes, avoid social isolation, and lead longer healthier lives.

One of the key changes was redefining the phrase “primarily health-related” when it came to establishing guidelines around how Medicare Advantage plans could expand their supplemental benefits.

At first, the definition was rather narrow. But in April 2018, CMS expounded on the definition using nine services that clearly did not fit into the traditional “health-related” benefits. These included adult day care services, home healthcare for palliative care, caregiver support, and even bathroom safety devices and modifications as well as transportation.

While the latter two options were allowed under the old interpretation, Medicare Advantage plans were given much more latitude in the second edition.

Additionally, CMS reinterpreted the need for uniformity.

Previously, Medicare Advantage plans had to offer the same benefits to all members. That changed in 2018 and 2019 when CMS reinterpreted this guidance to allow for members in similar conditions to be offered the same benefits.

This opened the door for payers to more specifically target chronic disease management benefits. Health plans simply had to create benefits that had a “reasonable expectation” of supporting chronic disease management for members.

Thus, under the calendar years 2020 and 2021 expansions, payers had a range of even more supplemental benefits to offer.

In-home support services have become especially popular supplemental benefits among health plans. In fact, the therapeutic massage benefit—though still one of the more common supplemental benefits—is the only supplemental benefit to experience any kind of decrease in uptake among health plans.

More plans will also be offering more than one supplemental benefit for calendar year 2021. The number of health plans offering multiple supplemental benefits rose from zero in 2019, to 96 plans in 2020, to now 175 plans in 2021.

“The nearly 27 million Americans expected to enroll in Medicare Advantage in 2021 look forward to this more comprehensive view of their health needs and the opportunity for better health outcomes it brings,” added Schwartz.

Meal delivery benefits have also been on the rise, with 34 percent more health plans offering this benefit in 2021 than in 2018, an Avalere study recently revealed. Over-the-counter benefits have also received a boost, jumping 29 percentage points in prevalence among health plans since 2018.

Avalere pointed out that—apart from CMS reinterpretations—the coronavirus pandemic has also been a big driver for increasing supplemental benefits.

“MA plans are quickly adapting to the new reality by recognizing the needs of Medicare beneficiaries during the pandemic,” said Joanna Young, principal at Avalere. “They are offering specific supplemental benefits and enhancing the availability of telehealth options for commonly used services, such as doctors’ visits.”