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New Primarily Health-Related Benefits in 2021 Medicare Advantage Plans


Medicare has long limited the types of benefits that could be reimbursed in Medicare Advantage to only medical and primarily health-related services. Recently, however, the Centers for Medicare & Medicaid Services (CMS) introduced flexibilities to allow for coverage of services not traditionally covered by Medicare, like In-Home Support Services and Adult Day Health Services.

CMS first introduced this flexibility in 2018 guidance by expanding the definition of what is considered “primarily health-related” to include services that 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 healthcare utilization.


We analyzed data from the Centers for Medicare and Medicaid Services (CMS) on plan benefit packages for 2021. Our analysis revealed that a growing number of plans are offering non-medical supplemental benefits under the expanded definition of primarily health-related benefits. Plans offering these benefits have increased from 499 plans in 2020 to 737 plans in 2021. Certain benefits, like Home-Based Palliative Care and In-Home Support, are seeing a nearly two- to three-fold increase from 2020 to 2021.

While the percentage of plans embracing these new primarily health-related benefits has steadily risen, these benefits are most popular among Special Needs Plans (SNPs). The higher benefit offerings within SNPs is likely driven by a number of factors, first and foremost that by definition, SNPs are designed to target groups of beneficiaries with special and complex needs. The new supplemental benefit authorities allow benefit packages that are responsive to the high-needs individuals likely to enroll in SNPs.


Now in their third year, benefits available under the expanded definition of primarily health-related continue to grow in Medicare Advantage. As more plans consider offering these types of benefits, new opportunities arise for plans to partner with nontraditional providers, like home care agencies, to deliver these benefits. Despite the barriers plans face offering these benefits, including the unique challenges encountered during the COVID-19 pandemic, plans continue to offer these benefits to meet beneficiary need and have expanded their offerings, particularly Home-Based Palliative Care and In-Home Support, in 2021.

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