CMS Delays Supplemental Benefit Mid-Year Notification Requirement: What Plans Need to Know Now

By Laura Massetti, Growth Leader

In April 2024, the Centers for Medicare & Medicaid Services (CMS) finalized a new requirement for Medicare Advantage (MA) organizations as part of the Contract Year 2025 Final Rule. This policy obligated all MA plans to provide a personalized mid-year notification to enrollees by July 31 of each contract year. The purpose of the notification was to remind members of supplemental benefits available to them that had not yet been used, and to ensure that they had the information needed to access those benefits. 

The regulation, codified under 42 CFR § 422.2267, requires that each communication include a list of unused supplemental benefits, a description of the scope of each benefit, any applicable cost sharing, details on how the enrollee may access the benefit, relevant network requirements, and a customer service contact. CMS intended this measure to address the long-standing issue of supplemental benefit underutilization. Research and agency commentary have consistently shown that a significant portion of MA members do not use available services such as dental, vision, transportation, meals, or over-the-counter allowances. The agency linked this lack of awareness and engagement not only to poorer outcomes but also to diminished member experience and lower Star Ratings. 

The operational burden on plans was immediately apparent. To comply, organizations would need to integrate data across disparate claims systems, utilization reports, and third-party vendor platforms. Many plans rely on multiple supplemental benefit partners, complicating the task of aggregating accurate, real-time information. Execution of the notice also requires coordinated efforts across compliance, IT, operations, and communications teams. The original 2025 implementation timeline provided limited runway to build these processes at scale without significant risk of compliance lapses or audit findings. 

In September 2025, CMS announced that it would delay enforcement of the mid-year supplemental benefit notification requirement. While the regulation itself remains in effect, CMS has temporarily paused auditing and penalties associated with the mandate. The agency acknowledged the complexity of implementation and the need for further guidance. Importantly, the delay does not eliminate the obligation. The requirement is still codified in federal regulation and will be enforced once CMS finalizes its timeline for resumption. 

For health plans, this enforcement pause should not be seen as a reprieve but as a strategic window. Plans that invest now in building compliant processes will be better positioned when enforcement resumes. This means auditing current data flows, improving vendor oversight structures, and ensuring that supplemental benefit utilization data can be consolidated and reported accurately. It also presents an opportunity to reframe the mid-year notice as more than a regulatory checkbox. With thoughtful design, these communications can become tools to educate members, increase engagement, and strengthen satisfaction—all of which can support higher CAHPS scores and Star Ratings. 

At Command Direct, our position is that the delay represents an opportunity rather than an obstacle. Organizations that act now will be audit-ready and fully compliant when CMS resumes enforcement. Just as importantly, they will be able to transform supplemental benefit notifications into a lever for improved member engagement and competitive differentiation. By treating this time as preparation rather than postponement, Medicare Advantage plans can turn a regulatory mandate into a strategic advantage. 

References 

• Centers for Medicare & Medicaid Services. Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly; Final Rule (CMS-4205-F). Federal Register, April 23, 2024. Codified at 42 CFR § 422.2267. 

• CMS Health Plan Management System (HPMS) Memo. Delay of Enforcement: Mid-Year Supplemental Benefit Notification Requirement. Issued September 2025. 

• Centers for Medicare & Medicaid Services. Fact Sheet: Contract Year 2025 Medicare Advantage and Part D Final Rule (CMS-4205-F). April 4, 2024.