On April 27th, the Centers for Medicare and Medicaid Services issued guidance on the 2019 Call Letter’s reinterpretation of the scope of Medicare Advantage (MA) supplemental benefits, to help insurers prepare their bids for 2019 plans. One criterion for MA supplemental benefits, which are funded through rebate dollars and plan premiums, is that they be “primarily health related.” CMS has historically interpreted this criterion as excluding supplemental benefits that are primarily for daily maintenance to compensate for physical impairments. Starting in January 2019, the Call Letter expands the scope of supplemental benefits to include health care benefits that are medically appropriate and recommended by a licensed provider to:
- Diagnose, prevent, or treat an illness or injury;
- Compensate for physical impairments;
- Act to ameliorate the functional/psychological impact of injuries or health conditions; or
- Reduce avoidable emergency and health care utilization.
The Call Letter provided the example of fall prevention services as a supplemental benefit that will be eligible under the new standard and indicated that further guidance would be issued on other services that would qualify as supplemental benefits. The guidance specifies that the following services will be allowable supplemental benefits under CMS’ new interpretation of primarily health related:
- Adult Day Care Services;
- Home-Based Palliative Care;
- In-Home Support Services, including Personal Care Services;
- Support for Caregivers of Enrollees;
- Medically-Approved Non-Opioid Pain Management;
- Stand-alone Memory Fitness Benefit;
- Home and Bathroom Safety Devices and Modifications;
- Transportation; and
- Over-the-Counter Drugs and Assistive Devices Benefits.
The guidance letter is attached. Policy questions related to the expansion of supplemental benefits may be submitted here and operational questions may be submitted here.