On March 17th, the MLTSS Association, along with the Special Needs Plan Alliance (SNP Alliance), the Association for Community Affiliated Plans (ACAP), and the Alliance of Community Health Plans (ACHP), sent a letter urging CMS to use their statutory authority to expand benefit flexibilities for Medicare Advantage (MA) plans. Specifically, we requested that CMS issue bid guidance starting with 2026 bids that would allow MA plans to offer a broader set of supplemental benefits, primarily and non-primarily health-related, to MA beneficiaries eligible for the Low-Income Subsidy (LIS) program. CMS has previously used their statutory authority to expand benefit flexibilities, and we urged CMS to do so at this time to maintain and improve the health of Medicare beneficiaries.
This request is grounded in the need to address the significant challenges faced by Medicare beneficiaries, particularly those with low socio-economic status and chronic health conditions, who will be impacted by the termination of the Value-Based Insurance Design (VBID) demonstration in 2026. The VBID demonstration provided MA plans with flexibilities to offer services (including special supplemental benefits) to enrollees eligible for low-income subsidies, those dually eligible for Medicaid and Medicare, as well as those with chronic conditions. The removal of the VBID model will limit services and leave our most vulnerable, complex populations with substantial barriers to maintaining their health.
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