In the increasingly competitive Medicare Advantage (MA) marketplace, one key approach that Medicare Advantage organizations (MAOs) use to distinguish their product offerings from those of competitors is enhancing benefit richness. However, the MA program has faced significant changes recently, including downstream impacts from the Inflation Reduction Act (IRA),¹ new measurement standards that led to star rating reductions for some contracts,² rising healthcare trends, and modifications to risk score models, to name a few. As a result of these program changes, on average, plans reduced their medical benefits from 2024 to 2025, marking a notable shift in the program’s history.³

This white paper will primarily focus on how the prevalence and richness of mandatory supplemental benefits (MSBs) evolved in 2025 for general enrollment plans. Supplemental benefits in MA plans can either be mandatory for all enrollees or optional (OSB), requiring an additional premium for those who choose to receive them. Supplemental benefits offered as part of nonuniform benefit (NUB) packages—such as Value-Based Insurance Design (VBID), Uniformity Flexibility (UF), and Special Supplemental Benefits for the Chronically Ill (SSBCI)—are not included in this analysis, as we primarily focus on the general enrollment portion of the MA market, where offerings of these types of benefits are infrequent. These targeted nonuniform benefits, as well as OSBs, are excluded from this analysis.

2025 brought small declines in plan offering prevalence after continued growth in years prior

Dental, vision, and hearing benefits are among the most common supplemental benefits historically offered by MAOs, alongside over-the-counter (OTC) benefit cards, which we discuss later in this paper.⁴ In recent years, these benefits have also been included with other unrelated benefits in “combined” or “flex” benefit packages offered by MAOs.⁵

Combined benefits in MA plans, known as “combo benefits,” bundle various supplemental benefits into one package with a maximum benefit amount, either by visit count or dollar limit. While dental-only, vision-only, or hearing-only packages that combine similar benefits into one package (e.g., preventive dental and comprehensive dental) are common, this paper includes only “true” combo packages—those that integrate multiple unrelated benefit types, such as a combination of dental, vision, and hearing benefits under a single dollar limit—in prevalence counts for combo benefit statistics.⁶

Standalone benefits are those that are provided on their own, not as part of a combination of different types of benefits within one benefit package.

It is important to consider both standalone and combo sources when reviewing coverage of benefits for plans, as reviewing plan designs with either of these benefit types in isolation can lead to incorrect conclusions on the prevalence of benefit design offering.

Figure 1 shows the percentage of general enrollment plans from 2022 to 2025 with coverage for dental, vision, and hearing benefits broken out by standalone coverage and coverage in a combined benefit package.

Prevalence has remained high and relatively constant for general enrollment plans over the last four years for these core benefit offerings, with 2025 bringing small decreases in offerings for comprehensive dental, vision hardware, and hearing hardware benefits.

• The exception is preventive dental coverage, which continued to expand for general enrollment plan offerings in 2025, resulting in roughly a 7% increase from 2022 to 2025. Additionally, there has been a recent decline in the proportion of plans offering this benefit within a combo package.
• The prevalence of vision and hearing hardware benefits decreased slightly from 2024 to 2025; comprehensive dental, one of the fastest-growing supplemental benefits in recent years, experienced a 2% reduction in 2025.
  • Vision exams and hearing exams remain nearly universally covered throughout all years and are not shown here given the lack of differentiation between years and benefit offering changes; most of the value offered to members in vision and hearing benefits is done through the hardware portion of the benefit.
  • With regard to comprehensive dental, some plans are opting to remove this benefit offering under competitive pressures to offer the most MSB value within tightening budgets (either totally removing or moving the benefit to an OSB offering), and MAOs are using this lever to right size dental benefits and still appeal to members by continuing to offer preventive dental while better managing utilization and cost.
• MAOs still offer core benefits like dental, vision, and hearing through a standalone approach at a high percentage. However, after 2022, offering these benefits through a combined benefit package became more popular.
  • With the new ability for plans to offer OTC hearing aids in 2025 plan benefit package (PBP) plan design entries, there was a marked uptick in the offering of hearing aids in combined benefits as plans took advantage of offering both prescription hearing aids and OTC hearing aids through a combined benefit approach.

An especially important supplemental benefit for attracting membership, OTC benefit cards, also saw a significant reduction, which we analyze further in Figure 5.

A number of less common benefits also saw declines in 2025

Overall, the general enrollment market’s coverage of other supplemental benefits moved in a similar direction in 2025. Figure 2 demonstrates the availability of a number of other less common supplemental benefits.

Notable conclusions to highlight here include:

• Non-emergency transportation: With only 31% of plans offering coverage in 2025, this is a significant decline of more than 6% relative to 2024.
• Meals (post-acute): In 2025, about 65% of plans were covering meals, a decline of 7% since 2024, when coverage was about 72% of plans.
• Remote-access technologies: This benefit experienced a significant decrease, with nearly 25% of plans dropping this coverage in 2025, such that only 45% of plans are covering it for the current plan year. This decrease is driven by one national organization dropping this benefit in 2025.

Reduction in the richness of some supplemental benefit offerings in 2025

While the prevalence of general enrollment plans is a critical component to understanding plan design offerings, it is also important to understand the richness or dollar value of these benefits; this is equally crucial in attracting members. Figure 3 provides insight into the average annual limits of popular supplemental benefits.

The takeaways on the richness of these benefits offered by general enrollment plans, as shown in Figure 3, include:

• Both the average annual limit for comprehensive dental and shared dental (this is a combined limit for comprehensive and preventive dental services) increased by around 20% annually from 2022 to 2024. However, both benefits experienced declines from 2024 to 2025. Specifically, the shared dental limits decreased slightly, by 1.4%, in 2025, while the comprehensive dental limit alone saw a near 10% reduction among general enrollment plans offering the benefit.
• Similarly, the average annual vision hardware limit experienced notable growth, increasing by approximately 15% per year from 2022 to 2024. This upward trend, however, slowed in 2025, with a more modest increase of 3.3%.
• In contrast, hearing hardware limits among plans generally maintained a steady annual growth rate of about 7% from 2023 to 2025.

In a notable reversal of trends, plans saw an increase in the prevalence of Part B buydowns in 2025, relative to prior years’ offering of this benefit.

The percentage of plans offering a Part B premium buydown increased significantly from 2024 to 2025, accompanied by an increase in the average monthly Part B buydown amount. This trend aligns with changes by the Centers for Medicare & Medicaid Services (CMS) to the August rebate submission rules and the greater likelihood in 2025 of plans missing the direct subsidy by a larger magnitude than in prior years. As a result, some organizations may be using small Part B buydowns to comply with CMS rebate reallocation guidance. Additionally, one large national MAO has notably increased their average Part B buydown for 2025, further contributing to this shift.

Amid evolving MSB offerings, these trends suggest a broader market shift toward cost containment and resource reallocation. These adjustments in Part B buydowns, driven by the rebate submission process, highlight the importance of understanding the financial implications of missing the direct subsidy estimate. To remain competitive and financially sustainable, MAOs must ensure their benefit designs align with both market dynamics and long-term fiscal strategies.

OTC benefit card offerings changed significantly and were a key benefit lever used to adjust plan design offerings in 2025

One of the most significant shifts in the 2025 supplemental benefits landscape for general enrollment plans is the marked decline in the prevalence and richness of OTC benefit card offerings. Figure 5 provides a detailed illustration of this trend.

As depicted in Figure 5, in 2025, there are several important takeaways for stakeholders to understand with regard to OTC benefit card offerings.

• OTC benefit card offerings decreased by a significant amount, nearly 13% from the year prior; in 2025 only about 73% of general enrollment plans will offer access to an OTC benefit card, compared with more than 80% in all three prior years.
• In addition to a sharp decline in OTC prevalence in 2025, the manner in which the benefit has been offered through general enrollment plans has changed significantly.
  • Beginning in 2024 and continuing into 2025, there was a notable increase in the prevalence of OTC coverage within combo packages, with nearly 25% of plans including OTC in a combo in 2025. Consequently, standalone coverage declined from 80.2% in 2023 to just 48% in 2025.
  • This market-wide shift away from standalone OTC coverage toward combo packages indicates that it is now increasingly common to find OTC coverage bundled with other benefits. As a result, members may need to allocate dollars they would have otherwise used for OTC-eligible products toward other benefits included in the combo package.
• OTC richness follows a similar trajectory, as the average monthly limit decreased by more than 4% between 2024 and 2025, after an annual increase from 2022 to 2024 of 8%.⁷

While not shown in Figure 5, in 2024, approximately 14% of plans offered OTC benefit cards with rollover optionality; however, this was reduced to 9.6% in 2025. An OTC card rollover in an MA plan allows a member some flexibility, in that the unused balance on their OTC card can carry over to the next period, which can range from a month to a year. This enables the member to use the remaining amount for future OTC-eligible item purchases instead of losing it at the conclusion of that time period.

OTC benefits appeal to MA members by offering an allowance to purchase everyday health items (e.g., vitamins, pain relievers, etc.) at no out-of-pocket cost. Despite its popularity, the significant reduction in availability, value, and flexibility of OTC card offerings indicates that the benefit was a key lever that many MAOs in the general enrollment market utilized to scale back costs amid the changing landscape.

Data sources and methodology

In performing this analysis, we relied on the 2025 Milliman MACVAT®. The Milliman MACVAT contains MA plan details and benefit offerings through the 2025 plan year. The Milliman MACVAT uses publicly available data released by CMS, which is then compiled, sorted, and summarized into a user-friendly format.

Benefit data for all years were summarized from the PBPs published by CMS annually.⁸ The analysis presented is limited to non-special needs plans (general enrollment) in the MA market and excludes Medicare Medical Savings Account (MSA) plans and cost plans. Additionally, all statistics are calculated by giving equal weight to each general enrollment plan, without considering enrollment figures. The plan-weighted approach displays the counts of benefits in the market and does not skew counts to the largest plans. This allows for an apples-to-apples comparison of what Medicare eligibles can shop for in the market each year, independent of what plan other Medicare eligibles select.

2026 will usher in more unknowns as revenue pressures increase

The first year that MAOs used benefit design as a material lever to address market headwinds with respect to their general enrollment plan offerings was 2025. Further benefit design changes may take place in 2026, given the looming impacts to the entire MA market—including drug price negotiations, star rating methodology changes, continued revenue pressures, changes in member buying habits and shopping preferences, and market reactions to competitor strategies in 2025, just to name a few.

It is essential for MAOs and other healthcare stakeholders to understand local market implications of the anticipated market changes noted above on general enrollment competitor benefit designs. Healthcare stakeholders who understand these changes in relation to their own strategic objectives will be best equipped to minimize revenue reductions compared to their competitors and mitigate risks from industry headwinds. Milliman’s acumen in this area, as well as our data assets, can assist in providing the financial clarity that healthcare executives need to develop rational and strategic benefit designs while addressing market pressures head on.

Caveats and limitations

Julia Friedman, Matt Timm, and Aric Booth are actuaries for Milliman, members of the American Academy of Actuaries, and meet the qualification standards of the Academy to render the actuarial opinion contained herein. To the best of our knowledge and belief, this information is complete and accurate and has been prepared in accordance with generally recognized and accepted actuarial principles and practices.

The material in this report represents the opinion of the authors and is not representative of the view of Milliman. Milliman is not advocating for, or endorsing, any specific views contained in this report related to the Medicare Advantage program.

This report is intended to summarize benefit richness in MA plans from 2022 through 2025. This information may not be appropriate, and should not be used, for other purposes. We do not intend this information to benefit, and assume no duty of liability to, any third party that receives this work product. Any third-party recipient of this report that desires professional guidance should not rely on Milliman’s work product but should engage qualified professionals for advice appropriate to its specific needs.

In preparing our analysis, we relied upon public information from CMS, which we accepted without audit. However, we did review it for general reasonableness. If this information is inaccurate or incomplete, conclusions drawn from it may change.

¹ Friedman, J., Cates, J., & Bentley, C. (December 19, 2024). State of the 2025 Medicare Advantage industry: Dual-eligible plan valuation and selected benefit offerings [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/state-of-medicare-advantage-d-snp-2025.;
Gergen, R., Leciejewski, Z., Koenig, D., & Pierce, K. (January 18, 2023). Medicare Part D risk and claim cost changes with the Inflation Reduction Act [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/medicare-part-d-risk-claim-cost-changes-inflation-reduction-act.

² Rogers, H., & Smith, M. (November 6, 2024). Star ratings in retrograde: Decoding the 2025 decline [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/Star-Ratings-in-Retrograde-Decoding-the-2025-Decline.

³ Friedman, J., Cates, J., & Phillips, E. (December 16, 2024). State of the 2025 Medicare Advantage industry: General enrollment plan valuation and selected benefit offerings [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/state-of-medicare-advantage-general-enrollment-2025; Friedman, Cates, & Bentley, op cit.

⁴ Laktas, J., Yeh, M., & Friedman, J. (March 21, 2023). Prevalence of supplemental benefits in the general enrollment Medicare Advantage marketplace: 2019 to 2023 [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/prevalence-supplemental-benefits-general-enrollment-ma-marketplace-2023.

⁵ Yeh, M., & Yen, I. (April 3, 2024). 2024 combined benefits in Medicare Advantage: Tracking benefit strategy and options [Milliman white paper]. Retrieved February 17, 2025, from https://www.milliman.com/en/insight/2024-combined-benefits-medicare-advantage-tracking-benefit-strategy.

⁶ Ibid.

⁷ The average OTC monthly limit is calculated by standardizing all limits on a monthly basis using the periodicity indicator (i.e., monthly, quarterly, etc.) filled out in PBPs. This ensures that the average is based only on plans with an OTC limit, preventing skewing by plans without a set limit.

⁸ These data can be downloaded from https://www.cms.gov/data-research/statistics-trends-and-reports/medicare-advantagepart-d-contract-and-enrollment-data/benefits-data.