A health plan offers its members a ride to the doctor. Good benefits, real need. Then the actuary asked the question that is important today: does this improve a person’s health, and can we show it? And the honest answer, for most plans, is that the data to answer it doesn’t exist in one place. The trip happened. The evidence is not captured.
The gap used to be tolerable. Not anymore. The rules have shifted from offering a benefit to proving it, and a plan that can’t connect the journey to an outcome is one that will struggle to justify the benefit.
I’m the CMTO at Mindbowser, and the work I care most about is meeting clinical outcomes with the systems that need to capture them. Transportation is one of the cleanest examples today: the obvious benefits help, that plans increasingly have to be maintained with data, and the software that runs most plans was never built to produce that data. This is an explanation of what the current regulations require, why this is a software issue, and what the plan side build actually has to do.
The package of transport benefits offered, and the gaps behind them
Start from the position of the benefit, because the benefit is moving. In 2026, medical transportation benefits were available to 22% of Medicare Advantage enrollees, down from 28% in 2025, and to 73% of SNP enrollees, per KFF Analysis June 2026. Non-medical transportation, offered as a Special Additional Benefit for the Chronically Ill, covers 5% of individual plans and 36% of SNP.
Two things stand out in these numbers. The benefits are widespread, especially in the SNP world where its membership is largest and sickest the need for reliable transportation for care is the highest. And on the individual side, it experiences contraction, which occurs when plans cannot justify cost benefits with evidence of their value. The benefits you can’t measure are the benefits you cut when margins get tight.
The gap beneath the benefits is data. A plan knows that it is paid for travel. What usually can’t be shown is which members are using it, whether those members have an appointment, and whether the benefit changes anything about their care or costs. This is not a reporting inconvenience. Under the current rules, this is an existential question for the sake of it.
What CMS now requires you to prove
The CY2025 Medicare Advantage final rule, CMS-4205-F, with provisions effective in 2026, changes the supplemental benefit standards. There are two most important requirements for transportation.
First, the standard of evidence. For Special Supplemental Benefits for People with Chronic Illnesses, a plan must contain a bibliography of high-quality clinical research, published within ten years of the year of coverage, demonstrating that the benefit has a reasonable expectation of improving or maintaining the overall health or function of chronic disease enrollees who receive it. You can read the framing at CMS-4205-F fact sheet. Simply put, offering transportation benefits in the belief that it helps is no longer enough. You must be able to show proof, and increasingly be able to show your own proof.
Second, mid-year notification. Beginning January 1, 2026, plans must send a semiannual notice to each enrollee with unused additional benefits, no later than June 30 and no later than July 31, listing the benefits they have not yet used. For transportation purposes, this means you have to know, member by member, mid-year, who has and has not used the rides. That’s a live utilization tracking requirement, not an annual report you put together after the fact.
Combine the two and the message is clear. You have to prove that the benefits work, and you have to track their use carefully so you can encourage members who don’t. Both are data capabilities, and most plans don’t link the two.
Why is this a software issue, not a policy memo
It may be tempting to treat these new requirements as a compliance task, something the regulatory team handles by binding them. But the binder couldn’t answer the actuary’s questions, and it couldn’t produce a mid-year notice. The requirements are broken down into four data capabilities, and each of them is software.
You need eligibility logic that knows which members qualify for benefits and under what rules, because SSBCI eligibility is narrower than general membership. You need utilization tracking that looks at each trip as it is, not in a quarterly broker file, so that mid-year notification of unused benefits is accurate. You need a picture of outcomes and experiences that connects the journey to what is possible, appointments kept, gaps in care closed, so that benefits can be linked to measurable outcomes. And you need member engagement, reminders, and booking experiences, which turn the benefits offered into useful benefits.
None of those are transportation features. That’s a feature of health plan data, and they have to share information. The reason this is a niche design for serious plans is because the available tools have their parts, the brokers have their vehicles, the benefits admin systems have their feasibility, the analytics team has their results, and there is nothing that ties it all together into a single chain that proves the benefits work. Disciplines capture the same results that are executed quality tracking under value-based care This is what is currently required by transport benefits, applied to travel.
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