FAQ on New CMS Regulations for Rewards & Incentives in Medicare Advantage

In early 2021, the Centers for Medicare & Medicaid Services (CMS) released the Contract Year 2022 Medicare Advantage (MA) and Part D Final Rule with sweeping changes to reward and incentive programs for MA plans that mostly flew under the radar. However, with 2022 right around the corner, it’s important to understand the impact of these new rules and what actions plans must take to avoid sanctions from CMS.

To summarize the changes at a very high level: Plans that are using HEDIS® measure criteria to define incentive eligibility or including reloadable debit cards and Amazon gift cards as rewards will need to overhaul their programs or face potential penalties for non-compliance.

If this is news to you, you're not alone—Healthmine has prepared a list of frequently asked questions from our conversations and seminars with numerous health plans that you can download by filling out the form on the right.

Some of the key regulations set to drop on January 1, 2022 include:

• The new definition of “Qualifying Individuals” changes who must be deemed eligible for a reward; HEDIS denominators and/or numerator status cannot be used as the sole eligibility criteria to qualify for and/or earn rewards in MA
• MA plans are required to create equitable access to rewards programs by informing all Qualifying Individuals that they are eligible for rewards
• Incentive programs cannot include Amazon gift cards or unrestricted rechargeable debit cards; Walmart and Target gift cards are allowable, but with exclusions for items such as alcohol, tobacco, and firearms
• Non-compliance with the new reward and incentive standards will be treated as Grievances and may lead to sanctions

While speaking to health plans about the new rules, Healthmine took note of the most pressing and common questions being asked and compiled our expert answers into a helpful guide for navigating the nuances of incentive eligibility and gift card requirements.

We encourage all MA plans to download the FAQ and contact the experts at Healthmine if you have any additional questions.