CMS’s April 27 sub-regulatory guidance details an array of home and community-based (HCBS) services that Medicare Advantage plans can offer as supplemental benefits beginning in Calendar Year 2019.   


CMS’s new interpretation appears to recognize the importance of these services for certain MA plan enrollees while making clear that not every enrollee in an MA plan will be eligible to receive them without a designated need.  CMS identified the following list of specific services as allowable supplemental benefits meeting CMS’s new expanded definition of “primarily health related”:

  • Adult Day Services provided outside the home including transportation to and from this service is also allowable. Also, permits recreational or social activities or meals that are ancillary to the primarily health related services.
  • Home-Based Palliative Care to diminish symptoms for terminally ill beneficiaries with a life expectancy that is greater than 6 months, and so are not eligible for hospice care.
  • In-home support services for individuals with disabilities or medical conditions that need assistance with performing ADLs and IADLs
  • Support for caregivers of enrollees including respite care provided through a personal care attendant or in a short-term institutional care setting.  CMS specifies this benefit should be for short periods (e.g., a few hours per week or two-week period or four-week period).  Counseling and training courses for caregivers of enrollees would also qualify.
  • Medically-approved non-opioid pain management
  • Memory Fitness Benefit can be offered as a stand-alone benefit or as part of a broader health education benefit.
  • Home & Bathroom Safety Devices & Modifications: non-Medicare covered safety devices to prevent injuries with the exception of capital or structural improvements to the enrollee’s home.
  • Transportation to assist with the enrollee’s health needs and may include a health aide to assist during the trip. Does not include transportation for groceries or banking.
  • Over-the-counter benefits that are not otherwise covered under MA plan benefits and permits coverage for assistive devices such as pill cutters, pill crushers, pill bottle openers and personal electronic activity trackers.

However, CMS reiterated that for the above services to qualify as a supplemental benefit under its recently-expanded definition of “primarily health related,” the service must be provided to:

  • Diagnose, prevent or treat an illness or injury
  • Compensate for physical impairments
  • Ameliorate the functional/psychological impact of injuries or health conditions OR
  • Reduce avoidable emergency or health care utilization

CMS notes that this list is not exhaustive and so additional services may also meet the new expanded definition.  In addition, CMS is not permitting services that are “solely or primarily used for cosmetic, comfort, general use, or social determinant purposes.”

On the upside, unlike eligibility for certain Medicare services, eligibility for these supplemental benefits does not require an enrollee to have a prior hospital stay, homebound status or a skilled level of care need. However, it does require these services relate to the enrollee’s health care needs and be recommended by a licensed medical professional as part of care plan. So, it is unlikely a package of assisted living services that are available to all residents would qualify under the new interpretation but some of the individual services may qualify if they are documented as part of an individualized care plan.

To be clear, overall, these services will only be available for enrollees in Medicare Advantage plans that elect to offer them as part of their supplemental benefits in CY2019. These same services will not be paid for through Medicare fee-for service.

It should also be noted that CMS does not set what rates an MA plan must pay providers for these services so those terms will need to be individually negotiated between these HCBS providers and the plans.  Nonetheless, this is an important step that moves us closer to recognizing that older adults’ needs can be more comprehensive than what Medicare has paid for up until now and that those services and supports can play a critical role in better outcomes and lower costs.

For additional background on this topic: “Clarifying New Opportunities for HCBS Providers Under Medicare Advantage Plans”

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As our Director of Health Information Technology, Devyn provides management and support for all health information systems use and performance for the Senior Options national network. Additionally is responsible for the technical, clinical and financial operational procedures of the electronic health record and all ancillary information systems.

Devyn has over 10 years of health information technology and project management experience inclusive of managing and supporting electronic health record systems including implementation planning and maintenance of both physician practice and senior living systems. Devyn has a Master of Science in Healthcare Administration MSHA from Southern New Hampshire University and Bachelor of Science in Health Services Administration from Auburn University. Devyn is a Certified HIPAA Professional (CHP).
Devyn developed a passion for Senior Care while volunteering at a local hospice, skilled nursing facility and Area Agency on Aging during her undergraduate years. She enjoys traveling and outdoor activities and Calligraphy.

Joan is the President of Senior Options, a Home Health and Hospice advisory group, and Westminster-Canterbury at Home, a home health and hospice agency in Virginia Beach. She previously served as Vice President of Operations & Clinical Services for Senior Options. Joan has over 30 years of experience in Home and Community-Based Services (HBCS), Hospitals, and Life Plan Communities.

Joan’s compassion, energy, and focus have been evident throughout her career. She has expertise in implementing new Home Health and Hospice operations as well as supporting existing agencies in operational and financial improvement. In addition, she is an expert in operational audits, consulting, and leadership for Home Health and Hospice. Also, Joan is mission-focused on leadership and creating healthy organizations that bring out the best in people.

Joan has a Bachelor’s Degree in Nursing from The University of Cincinnati and a Master’s Degree in Organizational Development and Positive Change Management from the Weatherhead School of Management, Case Western Reserve University. Joan is Certified in Appreciative Inquiry.

Karen started her medical career in 1984 as a registered nurse working in the intensive care unit and medical surgical. In 1999 she began working in home health, hospice and long term care earning various certificates as a Certified Nurse Executive, CNE; a Certified Wound Care Nurse, CWCN; a Certified Oasis Coder, COS-C; and in 2006 became a Licensed Nursing Home Administrator, LNHA. Before joining Senior Options in 2022, Karen also served as a Nursing Home Administrator for CCRC a skilled nursing facility, a Director of Operations for Home Health and Hospice, a Senior Executive Director for Long-term Care, a Preceptor for the Virginia Board of LTC Administrators and as a Nursing Instructor.

Karen has a bachelor’s degree in Nursing from Excelsior College in Albany NY and a Legal Nurse Consultant Certificate from Kaplan University.

As our Senior Director of Finance and Operations, Melinda is responsible for the finance, accounting, and billing team at Senior Options. And, she works with our current and prospective partners on budgeting, strategic initiatives, reimbursement, cost reports, and pro forma development.

Melinda brings over 25 years of financial management experience in the senior care environment. She has led the overall operations for six healthcare living centers, and two assisted living communities. She also has experience collaborating with multiple healthcare and state associations. Melinda currently serves as the Vice-Chair for the Virginia Society of Certified Public Accountants Board of Directors and is a member of the America Institute of Certified Public Accountants.

Melinda enjoys reading, traveling, walking, attending plays, and concerts.

Michelle’s experience in health care leadership spans for over 13 years. Before joining Senior Options, she served as the Administrator for Columbus Colony (the only deaf Nursing Facility in the country) where she was responsible for quality assurance and regulatory affairs, memory care, activities, policies and procedures, and resident care. Before that, Michelle served as the Vice President of Business Development for Senior Independence, now Ohio Living Home Health and Hospice, where she was responsible for growing home health and hospice by over 200% in seven owned and four partner home and community services agencies. Michelle also has 20 years of leadership experience in many Fortune 500 companies, including Gap Inc., IBM, and GTE, where she served in senior leadership positions in Sales, Marketing, and Client Services.

Michelle has a bachelor’s degree in Business Administration from Grand Valley State University, a Certificate of Economics from the University of Krakow in Poland, and a Master of Business Administration from Franklin University. Michelle is a CHAP, Certified Consultant.