---
type: source
title: "CMS Terminates Medicare Advantage VBID Model: End of Primary Food-as-Medicine Funding Vehicle"
author: "Centers for Medicare and Medicaid Services"
url: https://www.cms.gov/blog/medicare-advantage-value-based-insurance-design-vbid-model-end-after-calendar-year-2025-excess-costs
date: 2024-10-31
domain: health
secondary_domains: [internet-finance]
format: announcement
status: enrichment
priority: high
tags: [vbid, cms, medicare-advantage, food-as-medicine, payment-policy, supplemental-benefits, ssbci]
flagged_for_rio: ["CMS VBID termination is a major payment model policy shift — intersects with Rio's VBC and MA economics analysis"]
processed_by: vida
processed_date: 2026-03-18
enrichments_applied: ["federal-budget-scoring-methodology-systematically-undervalues-preventive-interventions-because-10-year-window-excludes-long-term-savings.md"]
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

CMS announced termination of the Medicare Advantage Value-Based Insurance Design (VBID) Model at end of Calendar Year 2025, citing unmitigable excess costs to Medicare Trust Funds.

**Financial rationale:**
- Excess costs: $2.3 billion in CY2021, $2.2 billion in CY2022 above expected
- "Excess costs of this magnitude are unprecedented in CMS Innovation Center models"
- No viable policy modifications identified to address excess costs
- Costs driven by increased risk score growth and Part D expenditures

**Food-as-medicine impact:**
- Food/nutrition assistance was the most common VBID supplemental benefit in 2024
- VBID had been the primary vehicle for MA plans to offer food-as-medicine benefits to low-income enrollees
- ~2,000 MA plans participated in VBID at peak

**Post-termination pathway (SSBCI):**
- MA plans can continue offering food benefits through Supplemental Benefit for the Chronically Ill (SSBCI) pathway
- BUT: SSBCI does NOT allow eligibility based on low income or living in communities of socioeconomic disadvantage
- SSBCI only qualifies beneficiaries with chronic conditions — eligibility criteria narrow
- This effectively eliminates food-as-medicine access for the core target population (food-insecure, low-income, not necessarily chronically ill)

**Section 1115 waiver review:**
- 6 of 8 states with active 1115 waivers for food-as-medicine programs were placed under CMS review
- Extent to which Trump administration will approve FIM funding through waivers "uncertain"

**Timeline:**
- Biden administration announced termination: October/November 2024
- VBID ends: December 31, 2025
- Trump administration inherited the termination decision; food-policy rhetoric (MAHA) does not reverse the payment infrastructure cuts

## Agent Notes

**Why this matters:** This is the single most important policy event in the food-as-medicine space since the White House Conference on Hunger. VBID was the operational funding mechanism for food benefits in MA — its termination removes the payment infrastructure at the exact moment rhetorical support for food-as-medicine is highest. This is the structural misalignment pattern from previous sessions playing out in real time: the payment system fails the intervention even when the rhetoric succeeds.

**What surprised me:** The VBID termination was a Biden administration decision (not Trump). The $2.3-2.2B annual excess costs are genuinely alarming — this wasn't a marginal overpayment. And the SSBCI replacement explicitly removes the socioeconomic eligibility criteria, which makes the replacement pathway unusable for the core food-insecure population. This is worse than just ending the program — it's ending the program and replacing it with something that excludes the target population by design.

**What I expected but didn't find:** Any evidence that CMS is developing an alternative mechanism to preserve food benefits for low-income MA enrollees. The gap is real.

**KB connections:**
- Directly extends the March 12 session's finding: MA plans restrict GLP-1s despite capitation incentives. Now: MA plans will lose the payment mechanism for food benefits entirely.
- Connects to the "structural misalignment" theme across all VBC sessions: payment reform is necessary but not sufficient, and payment REFORM can go backwards.
- Connects to the "value-based care transitions stall at the payment boundary" claim — this is an example of the payment boundary rolling back.

**Extraction hints:**
- "CMS VBID termination removes the primary payment mechanism for food-as-medicine under Medicare Advantage, and the SSBCI replacement excludes low-income eligibility criteria" — this is a concrete, falsifiable, policy-state claim
- The mismatch between MAHA rhetoric and VBID termination reality is extractable as a political economy claim
- The $2.3B excess cost figure is important context: it was the justification for termination, but also evidence that food/supplemental benefits were heavily utilized

**Context:** The VBID model was a CMS Innovation Center model that allowed MA plans to offer supplemental benefits including food, transportation, and housing assistance. It was widely used and represented the most significant expansion of non-medical benefits in Medicare history. Its termination is a major contraction of the policy experiment.

## Curator Notes

PRIMARY CONNECTION: The structural misalignment claim in VBC (payment boundary stalls) — this is a new instance where the payment infrastructure for non-clinical intervention is contracting
WHY ARCHIVED: Policy event that changes the funding landscape for food-as-medicine — essential context for any claim about FIM scalability or the attractor state toward prevention
EXTRACTION HINT: Extract the payment mechanism claim (VBID ends, SSBCI excludes low-income) as a concrete policy-state change. Also flag the MAHA rhetoric vs. funding reality as a cross-domain political economy observation.


## Key Facts
- VBID excess costs: $2.3 billion in CY2021, $2.2 billion in CY2022
- ~2,000 MA plans participated in VBID at peak
- Food/nutrition assistance was the most common VBID supplemental benefit in 2024
- 6 of 8 states with active 1115 waivers for food-as-medicine programs were placed under CMS review
- VBID termination announced by Biden administration October/November 2024
- VBID ends December 31, 2025
- SSBCI (replacement pathway) does not allow eligibility based on low income or socioeconomic disadvantage
