The digital divide is growing and causing massive healthcare disruption. At the RISE Social Determinant of Health Summit this year, Icario hosted an insight-packed session that focused on smashing the misperceptions related to digital access and the many barriers standing between people and better health.

This post is an abbreviated version of a much larger conversation from Icario’s recent appearance at the RISE Social Determinants of Health Summit. For more insights, view the on-demand recording of the full presentation “Crossing the Digital Divide in Government Programs”.

This session covered a lot of ground, highlighting the challenges, while shining a light on the innovations, initiatives, and bright spots that are moving us forward in order to close gaps caused by this super determinant.

Presenters Sara Ratner, Icario Medicaid Advisory Council Member, and Nightingale Partners Chairman, John Gorman, outlined the challenges and issues that are raised when people don’t have reliable internet access, including the difficulty students have completing homework or engaging in remote learning, the ability to manage chronic conditions, and the impossible task of searching for available vaccination appointments, to name a few. Aside from mere access to reliable broadband, Sara and John pointed out that for older adults that do have access to the internet, digital literacy becomes as big of an issue as someone who doesn’t have access at all.

Finally, oftentimes even when members have access to an internet benefit through their health plan, they don’t even know it, with Sara noting that upwards of 70% who are eligible for an internet benefit aren’t even aware of it.

“70% of the people who have access to low-cost or free broadband access don’t even know about it. There’s a real need to make people aware of and connect them to these services.”


Sara Ratner

Icario Medicaid Advisory Council Member

Compliance Considerations

While the full spectrum of challenges have come to light during the pandemic, there are solutions and compliance considerations that health plans can make to offer an internet benefit to their members. John Gorman highlighted 3:

#1—Special Supplemental Benefits for the Chronically Ill (SSBCI)

(included in bid, funded by the rebate)

  • Members are eligible for SSBCI based on chronic illness criteria (general supplemental benefits must be offered to all members equally)
  • Eligible benefits include both health-related & SDoH expenditures
  • Costs are considered eligible medical/provider expenses for minimum medical loss ratio (MLR)
  • May be advertised & included in plan marketing materials

#2—Administrative Benefits

(off-bid offerings, not a “benefit” for Medicare purposes)

  • Greater flexibility, no need to conform with bid/benefit requirements
  • May be offered to a targeted segment of the membership (must ensure not administered in discriminatory or preferential manner)
  • Treated as an administrative expense, not included in MLR
  • Plans must proceed cautiously to avoid perception of non-compliant “benefit” (e.g., no advertising)

#3—Rewards & Incentives

(wellness & preventive care)

  • Must be available to and flexible for access by all members
  • Generally targeted at health & wellness program participation
  • Limitations on types of incentives (no monetary or reduced cost-sharing incentives)
  • May not be used to recruit enrollees, but may be included in marketing materials so long as publicized equally to current members

Broadband Benefit Financing Options

Beyond highlighting the compliance considerations, financing is key. Health plans have a variety of financing options available to them for introducing broadband benefits to members. Importantly, John Gorman notes, external financing presents the lowest risk currently.

Health Plan Financed

  • On-Benefit: paid by the government and included in the bid
  • Mid-Year Benefit Enhancement: paid either by the government and/or external financing
  • Off-Benefit: administrative benefit, paid either by the government and/or external financing
  • SSBCI: paid either by the government and/or external financing

Externally Financed

  • Federal Government: proposed federal government infrastructure legislation (if passed) and the Emergency Broadband Benefit (EBB)
  • State Government: state program funded
  • Private: funded by Internet Service Providers (ISPs), health plans, foundations, or private investors

Mid-Year Benefit Enhancement in Medicare Advantage

In December 2020, CMS issued guidance that allows health plans to offer mid-year benefit enhancements to Medicare Advantage members. Investments in mid-year benefit enhancements can be made outside of the bid cycle with notification to CMS. This is important because it would allow health plans to add a broadband benefit for their members who needed it to manage their health and stay connected.

With the continued expansion of telehealth, offering a broadband benefit is economical for a health plan. Not only will driving people to telehealth improve health and decrease overall costs, but it will also keep members engaged in a system that’s historically marginalized them.

This was a jam-packed session covering far more, including additional solutions, a case study from Nemours, and a discussion of the Emergency Broadband Benefit (EBB). For the full conversation, watch the 35 minute session on-demand.