Tuesday, March 19, 2024

The Hidden Opportunity Behind the New CMS Benefit Rules

The Centers for Medicare & Medicaid Services (CMS) is putting some muscle behind its oversight of the supplemental and ancillary benefits offered by Medicare Advantage plans. The goal? To make sure those benefits get used by members — and not just promoted during the Annual Enrollment Period (AEP). Here’s why these new regulations are a gift in disguise — and how to turn them into a revenue engine, starting now.

By: Linkwell Health Editorial Team

What’s a Medicare Advantage plan without an array of choice perks? These days, dental, vision, and hearing benefits are merely the baseline. Fitness benefits are a must and top-of-the-line extras like over-the-counter drug coverage, food delivery, transportation services, and in-home support are increasingly prevalent. 

In fact, since 2020, the number of plans offering supplemental benefits has increased by 250%. The reason is clear: These enticing extras mitigate some of the most common barriers to care, and when used to their fullest, they can dramatically increase a member’s general health and wellness.

But take note of the phrase “when used to their fullest,” because that very concept lies at the heart of two recent CMS rulings. Effective January 1, 2024, plans must provide much more detailed data on supplemental benefit use to the Encounter Data System (EDS). The EDS system has been in place for about 10 years to help CMS manage plans’ risk adjustment, but reporting around non-provider-based benefits and services has been spotty. The second pending ruling, if finalized, would require Medicare Advantage plans to conduct a round of personalized member outreach at midyear, specifically to alert members to the benefits they have not yet used that year. 

The subtext? Supplemental benefits are there to be used by your members to the fullest — they can’t just be trumpeted during AEP and fall into the background come January 1.

Once finalized, failure to comply with these new rules could bring the usual stiff penalties, including fines and sanctions. But there’s even more at stake financially: Low utilization of supplemental benefits may lead to policy changes where there is less reimbursement revenue from the government to care for patients. 

If this sounds like a lot, it’s because it is. However, there’s a huge gift tucked inside these rules and regulations: The data you’re collecting and reporting can be used to power member engagement campaigns that build trust, deepen loyalty, and boost benefit activation. The more people take advantage of what their plan has to offer, the more value they find and the happier they are with their choice. All of which translates to a better bottom line. There’s no time to lose. Here’s how to maximize this opportunity, starting today.

1. Engage early and often

Don’t wait for midyear to get the conversation started. In fact, don’t wait for these rules to become a requirement. Instead, start talking to members now, getting them acclimated to a steady cadence of high-value, useful-to-them communications that highlight the benefits you offer. 

What makes communication useful to a member? At Linkwell, we take a behavioral science–backed service journalism approach to content, breaking down often daunting or confusing health and plan info into bite-size, compelling tips that leave the reader with a clear takeaway — and a nudge toward taking meaningful action to improve their health. 

To a member trying to make sense of the complex world of benefits, copays, premiums, and claims, this approach to engagement doesn’t feel dutiful. It’s delightful (a bold statement but one we stand by). Members feel guided, advised, valued. And they know that their health plan supports them. After all, research shows that 62% of consumers say the best brands are those that make their lives easier. This is your chance to show members how ready you are to do just that. Come open enrollment, they’ll remember.

2. Create surround sound

What’s better than valuable content? Valuable content that arrives via numerous channels, providing a full immersion experience:

  • A text that reminds a member that, for example, December is national flu vaccination awareness month and asks if they have received their shot yet. If not, here’s a quick and easy link to more info. (After all, 61% of Americans ages 65 and older own a smartphone, according to the Pew Research Center.)
  • An email newsletter that feels both timely and helpful, a candy box of varied and valuable information with clear calls to action.
  • A print mailer that reads like a magazine, with QR codes to drive members to your website, boosting their digital literacy and urging them toward the next best action they should take to safeguard their health.

The point of this multipronged approach isn’t to inundate, but to become indispensable, to make members feel that their plan is ever-present in their lives and right there, close at hand, to help when help is needed.

3. Optimize for the action you want

Knowing which services your members have and haven’t used requires a whole lot of one thing: data. Since you’re likely already pulling those numbers to comply with the MA Encounter Data System reporting rules, why not put that info to even greater use to engage members when and where they need it?

With this information in hand, you can start making your communications to members far more targeted, heading underutilization off at the pass. Analyzing data from Q1 can help you surface the highest value services for each member, then emphasize the benefits that will pack the biggest punch for each person.

If the data tells you that a member living in a food desert hasn’t been using a healthy meal benefit, for example, you know precisely what your messaging should highlight. If an individual living in a rural area hasn’t yet realized that you offer a transportation benefit, your next communiqué should make that clear, showing the member exactly how to make use of it.

4. Drive benefit activation and support the Health Equity Index at the same time

Many supplemental benefits are designed to address common gaps in healthcare and are geared toward populations adversely affected by social determinants of health (SDOH). As a result, driving greater benefit utilization may bring about a very welcome side effect: helping plans meet new Health Equity Index (HEI) requirements, which will start to have a significant impact on Star ratings in 2027.

Beginning that year, plans with higher scores among low-income subsidy, dual eligible, and disabled enrollees will receive extra weight in their ratings. That’s a big deal: A one-star bump in a given year can spark an 8% to 12% increase in enrollment, according to researchers from Navigant Consulting and Columbia University.

To meet this moment, plans need to demonstrate that they can enroll members with unmet needs, proffer interventions and benefits that are of genuine and significant use to members, and provide a best-in-class member experience. How?

  • By designing accessible, bilingual, and user-friendly content experiences and digital pathways to care
  • By ensuring that those supplemental and ancillary benefits are worth using and easy to access
  • And by harnessing the data at every plan’s disposal to create bespoke benefit activation journeys that help drive members toward their optimal state of health


Linkwell’s Benefit Activation Platform is poised to help Medicare Advantage plans do exactly that. It’s designed to help you meet the administrative demands of personalized notifications to members about their unused benefits, offering a turnkey solution to proactively build awareness, excitement, and utilization of high-value benefits so that members engage early and often. To learn more about how it works — and how it can help — contact us at info@linkwellhealth.com.