The Centers for Medicare and Medicaid Services (CMS) in April 2024 issued a final rule that included a new requirement for Medicare Advantage organizations (MAOs) to issue a mid-year notification of available supplemental benefits to enrollees starting in 2026. This paper aims to help plan sponsors better understand the financial and strategic implications of this regulatory change in the Medicare Advantage landscape. Key questions addressed in the paper include:

1. What impact could increased benefit utilization have on projections and bid development and how could it be measured?
2. How do beneficiaries utilize plan communications, and how might that impact benefit usage?
3. How can actuaries factor in potential changes in benefit usage patterns?