Medicare Advantage & Meals
Updated, Feb 2022: Among the 2022 Medicare Advantage Plans, the number offering a meals benefit is now almost 70% (67% for individual, 69% for special needs). Since the time of this posting the VT Department of Vermont Health Access (DVHA), in consultation with the Department of Financial Regulation (DFR), have recommended analyzing the feasibility of a Medically Tailored Meals benefit within our Benchmark Plan. An brief analysis of that recommendation in context of FAHC work is found here.
In 2022, the UVM Health Advantage plan will add a new Medicare Advantage option for Vermont (and upstate New York). It includes a Medically Tailored Meals (MTM) benefit after hospitalization and for patients with a new diagnosis of congestive heart failure (CHF).
Through Medicare Advantage plans (or MA Plans) Medicare beneficiaries have the option of receiving their “original Medicare” Part A & Part B coverage from private companies, approved by the same agency that regulated Medicare (CMS). These Medicare Advantage plans follow CMS rules, like original Medicare, but they can cover additional services. Usually these services include vision, dental, and hearing, and often the plans include supplemental benefits like home delivered medically tailored meals. In 2021, more than half of MA plans included a Meals benefit and every state had a least one plan with Meals covered.
The CMS rules for home delivered meals in Medicare Advantage are found in the MA Advantage Plan Manual Chapter 4, Sections 30.1 & 30.3. Key attributes are that they need to be prescribed due to an illness, consistent with medical treatment of that illness, and offered for a short duration. In 2021 the Center for Health Law & Policy Innovation reviewed the options for food coverage beyond meals in Medicare Advantage, specifically Produce Prescriptions. This issue brief is also a nice review of how CMS views food as part of health care services.
The increasingly common coverage of meals in Medicare Advantage, which in turn covered 42% of the eligible Medicare population in 2021, has a few additional implications:
Businesses are emerging to serve the MA Plans, including Mom’s Meals which is the current contractor used by MVP for the UVM Health Advantage plan. Because Mom’s Meals serves any address in the United States, that means there is always an option for MTMs. You can hear Mom’S Meals speak on this food insecurity & health care panel in 2020 (starting at the 41:15 minute mark).
Enough contracts exist in federally funded health care programs that there is an emerging common price point for these meals, which is in the vicinity of $6 per meal.
Although it is Medicaid and not Medicare, the North Carolina Healthy Opportunities Pilot provides some background on the calculations that go into the food pricing — they set MTMs at $5.05 per meal, plus funding for pilot entities to set up the administrative systems. The self-pay option for Mom’s Meals is listed at $7.99, presumably setting their upper bound. Meals payments are often calculated from Older Americans Act funded nutrition programs, which is publicly available information. See, for example, the 2020 Vermont report on meals programs for older Vermonters and a 2015 Mathematica report on the structure of OAA meals costs. Note that the average cost of home-delivered meals was $9.48 in the Northeast but the OAA reimbursement assumes significant additional donations, particularly of labor (which is 35% of overall cost). Was this a sloppy way to guess $6-ish a meal? Yes. If anyone has an actual analysis of Medicare meal reimbursements, both what they are and what they should be, please let us know.
When there is CMS guidance on home delivered meals definitions, national guidance for aligning meals with clinical evidence, widespread use of a form of MTMs in some Medicare plans, commonality on pricing, and assurance that all beneficiaries can have access to MTMs in some way regardless of where they live, that adds up to an opportunity to request coverage in original Medicare as well. The Food Is Medicine Coalition is making just such a request. See below.
H.R. 5370 The Medically Tailored Home-Delivered Meal Demonstration Pilot Act of 2021 would set up a program where CMS pilots coverage of MTMs for Medicare beneficiaries, with the intent of eventually covering this service in original Medicare. It was introduced by Rep McGovern (MA), Pingree (ME), Walorski (IN) and Evans (PA). Read more about this proposal from the Food Is Medicine Coalition here.
This pilot program does not include funding to establish new MTM programs, it would build from existing relationships at least 1 year old. In Vermont, like many states, the primary local programs that deliver home meals, with nutritionist guidance, to the Medicare demographic are Area Agencies on Aging and Meals on Wheels programs. A 2019 conference by the National Resource Center on Nutrition and Aging discussed MTMs within the larger landscape of nutrition programs for seniors, the report on the proceedings is available here. The national Meals on Wheels association tracks health care integration opportunities, including with MTM options, and you can read more at their website. [Update January 2022 - see also this Policy in Plainer English podcast “Food As We Age”]
Another set of programs with similarities to Medicare coverage and Medically Tailored Meals is Farm-to-School. It’s a very different demographic and the Farm-to-School health connection is through prevention, not treatment. However, there’s an underlying similarity. Farm-to-School programs have built from a very low meal reimbursement rate established at a national level to tailor Vermont programs to meet bigger goals, such as local food sourcing, community connections, and nurturing healthy eating habits. With an emerging federal framework for home delivered meals as part of health care, it might make sense to look at the school-based experience, how that was funded, and whether we think that is an appropriate road within a health care context. Read more about Vermont Farm-to-School at VTFeed.org and see also the national Farm-to-School Network.