Heeding the Administrator’s Call: Opportunities to Improve Supplemental Benefit Data

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AUTHOR – Bill Winfrey

“Are Medicare beneficiaries using [supplemental] benefits? What are they using? How are those dollars being spent?”

– CMS Administrator Chiquita Brooks-LaSure, at the Milken Future of Health Summit, December 8, 2022

Bill Winfrey, Director for ATI Advisory’s Medicare Innovation team and Christina Wu, Vice President of Policy and Research at the Long-Term Quality Alliance co-authored this Insight.

Medicare Advantage (MA) plans are able to offer additional benefits over the benefits all Medicare beneficiaries receive – called supplemental benefits. These supplemental benefits most typically take the form of vision, dental, hearing, and medical transportation services, but the types of benefits offered are evolving rapidly to include things like in-home support services or personal care, food, and help paying utility bills. Improving data available on these supplemental benefits in MA is clearly on the minds of officials at the Centers for Medicare and Medicaid Services (CMS). In March 2023, just a few months after the CMS Administrator posed these questions, CMS issued the Paperwork Reduction Act (PRA) notice about proposed new data collection requirements for supplemental benefits.[1] CMS is proposing to collect data from MA organizations on the specific benefits they offer, the number of members who use the benefit, how often they use the benefit, and how much money the plan spends on members who use the benefit. Building on our years-long work tracking these benefits, ATI and our partners at the Long-Term Quality Alliance (LTQA) believe these efforts to enhance data collection will  improve our ability to assess their value.

Newer supplemental benefits like in-home support services and food and produce offer a promising opportunity to promote health equity and address the comprehensive needs of MA enrollees as well as historic disparities in care and outcomes. But without insight into how these benefits are being made available to and used by members, we can’t ensure that benefits are reaching beneficiaries who need them, much less whether they’re impacting health outcomes. Scrutiny of the MA program is intensifying,[2] and policymakers will be looking into whether these additional MA benefits justify the taxpayer expense.

As Administrator Brooks-LaSure highlighted, one way to begin to understand the impact is through the collection of supplemental benefit utilization data. To that end, the PRA notice builds on CMS’ efforts over the past year to bring additional oversight to the MA program. CMS sought public input in a Request for Information (RFI) last summer on what MA plans and CMS can do to improve understanding of supplemental benefit utilization and appears to be increasing its focus on beneficiary protections through its latest MA final rule.

In a related effort, the Center for Medicare & Medicaid Innovation (CMMI) is exploring new data collection efforts for MA plans participating in the Value-Based Insurance Design (VBID) model.  As plans use flexibilities under the model to offer benefits addressing their members’ nonmedical needs, CMMI proposed to begin mandatory data reporting by participating plans starting this year on benefit utilization, availability, and generosity, as well as the vendors and community-based organizations with whom plans are partnering to provide these services.[3] The proposal also includes optional reporting on beneficiary-level benefit utilization. Though currently limited to VBID model participants, we believe this effort can provide a potential model for reporting on supplemental benefit utilization across MA and improve the field’s understanding of who is accessing these benefits, laying the foundation for potential correlations between benefit utilization and health outcomes.

There are opportunities for CMS to further enhance their data collection.  In LTQA’s response to the PRA notice, they noted that CMS may consider: (1) collecting demographic data alongside benefit utilization data, (2) clarifying reporting on benefits made available via debit cards, and (3) separating the cost of providing a service from the overhead cost of administering that service. Collecting beneficiary-level data in the future will help CMS understand the impact of these benefits on health outcomes, healthcare utilization, and costs.

A first step to understanding the utility and value of these benefits for Medicare beneficiaries is to understand who is using them. We appreciate the actions that CMS is taking to advance this and look forward to  further thoughtful action (that balances real concerns of data privacy and plan burden) to build the infrastructure necessary to assess these benefits and their impact on Medicare beneficiary health-related social needs (HRSNs) and long-term services and supports (LTSS) needs. We recognize that supplemental benefits are just one component of a much larger MA program that CMS must oversee. However, to continue advancing the agency’s significant work in promoting health equity and addressing health-related social needs (HRSNs), we’re glad to see that collecting supplemental benefit utilization data is  a priority for the Administration.

[1] Additional details can be found on the CMS page regarding this data collection effort: https://www.cms.gov/regulations-and-guidance/legislation/paperworkreductionactof1995/pra-listing-items/cms-10261

[2] See recent coverage in the MA program of fraud and misleading marketing practices.

[3] Detailed information on the latest VBID data submission requirements is available at the link entitled “CY 2023 VBID Model Monitoring Guidelines (ZIP) – February 23, 2023” under “CY 2023 Materials” on the VBID web page.

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