January 25, 2019

Medicare Advantage Plan Adoption of New Flex Benefits in 2019

Medicare Advantage, the private plan option in the Medicare program, is growing rapidly. Currently, 22 million people choose Medicare Advantage — more than one third of people with Medicare — and that number is expected to top 30 million in the next five years.

Policy changes in 2018 permit Medicare Advantage plans to offer new “flex benefits” in 2019. These flex benefits have the potential to move Medicare Advantage substantially toward a population health orientation. Flex benefits fall into two categories:

  1. Reduced cost sharing for services “medically related” to the treatment of certain health conditions.
  2. Supplemental benefits, such as respite services or non-emergency transportation, that assist in managing care.

These two types of benefits can be combined. They can also be made contingent upon participation in a care management program or services received from a plan-designated high value provider.

FaegreBD Consulting has digested newly-released Centers for Medicare and Medicaid Services (CMS) data to create a national database of Medicare Advantage benefits. We are pleased to provide an early glimpse of the new benefits that Medicare Advantage plans are offering in 2019.

In total, there are 824 condition-benefit category combinations (“flex benefits”) being offered in Medicare Advantage plans in 2019. These 824 flex benefits are clustered in just 153 plans, meaning most MA plans have no flex benefit offerings yet. Of the 824 flex benefits, 458 are reduced cost sharing and 366 are additional supplemental flex benefits

Figure 1: Flex Benefits by Condition or Disease

Roughly two thirds of condition-specific flex benefits are focused on three chronic diseases: Congestive Heart Failure, Diabetes, and Chronic Obstructive Pulmonary Disease (COPD). In total, Medicare Advantage plans are offering flex benefits for 25 chronic diseases.

Figure 2: Flex Benefits by Category of Service

Medicare Advantage plans are offering a wide variety of different flex benefits, the most common of which are meals (which are only permitted in narrow contexts in 2019) and reduced cost sharing for physician services. The high number of “other” benefits demonstrates the high diversity of benefits being offered in 2019.

Figure 3: Flex Benefit Prerequisites

Flex benefits can be contingent upon prerequisites, most notably participation in a care management or wellness program and seeing a plan-designated “high value provider.” In 2019, most plan’s flex benefit packages have such prerequisites. Of these prerequisites, participation in a wellness or care management program are far more common. A few plan packages use both prerequisites.


MAO Parent Org.  Plan Type  Plan Enrollment  Condition or Disease Prerequisite Flex Benefit Category Plan Min. Copay Play Max. Copay Flex Benefit Min. Copay Flex Benefit Max. Copay
 MAO #1  Local PPO  32  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  Local PPO  60  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  Local PPO  35  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  Local PPO  177  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  Local PPO  49  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  Local PPO  56  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO 796  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO 621  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO 4,639  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO  3,584  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO  2,576  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #1  HMO  3,010  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $0.00 
 MAO #2  HMO  3,446  Diabetes  No  Eye Exams  $45.00  $45.00  $20.00   $45.00
 MAO #2  HMOPOS  2,679  Diabetes  No  Eye Exams  $40.00   $40.00   $0.00   $40.00
 MAO #3  HMO  184  Diabetes  No  Eye Exams  $25.00  $25.00  $0.00   $25.00
 MAO #3  HMO  283  Diabetes  No  Eye Exams  $25.00  $25.00  $0.00   $25.00

The table above displays one example of a set of flex benefits: eye exams for people with diabetes. Only three Medicare Advantage companies are offering this benefit in 2019 and none of these plans have high enrollment. None of these benefits require participation in care management/wellness program or use of a high value provider. In this case, benefit cost sharing is commonly reduced to $0 for people with diabetes.

We offered this benefit as a straightforward and easy to narrate example. The quantity and diversity of many other flex benefits is far greater. 

While the new benefits summarized above represent an important starting point, 2019 is the first year of a multi-year process. Enabled by new flexibilities announced in January 2019, permitting benefits based on socio-economic status, flex benefits will grow in number and variety in 2020 and beyond.

If the transformation of Medicare Advantage benefits interests you as much as us, or if you would like to learn more about our database, contact the authors.

The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.

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