Policy Number: CLARE-2025-01

1. Policy Purpose 

The purpose of this policy is to establish clear and compliant standards for the administration, disclosure, and oversight of the Monthly Caregiver Health Promotion Challenge (“the Program”). This ensures adherence to all applicable federal and state regulations governing Medicare, Medicaid, and healthcare incentive programs, including the Anti-Kickback Statute, Beneficiary Inducement Provisions, and HIPAA Privacy & Security Rules.

2. Program Voluntariness 

Participation in the Clare Senior Travel Rewards Program is entirely voluntary. Enrollment or non-participation will not affect a member’s eligibility for Medicare or Medicaid benefits, cost-sharing, access to providers, or covered services. Members may opt in or out of the Program at any time without penalty.

3. Program Independence 

This Program is not part of any required Medicare or Medicaid benefit. Rewards and travel credit notes are supplemental incentives designed to promote health engagement and preventive care activities. The Program is not health insurance, reimbursement, or a covered benefit.

4. Travel Redemption & Optional Participation 

All travel credits are redeemed exclusively through Clare’s approved travel booking partners. Travel participation is optional and has no effect on any member’s coverage or provider choice.

Travel credits:

• Have no cash value
  
• Are non-transferable
  
• May only be used toward eligible travel booked via Clare’s platform
  
• Expire after the timeframe stated in current Program materials
  

5. Value Limitations 

Rewards must be of reasonable and nominal value, consistent with CMS and state Medicaid guidance. Annual caps and activity-based limits are published in Program materials. Credits may not be redeemed for cash, gift cards, medical equipment, or personal goods.

6. Grievance and Dispute Process 

Members who believe their reward was denied or miscalculated may submit a Grievance using any of the following methods:

• Phone: (617) 388- 2885
  
• Email: support@clare-afc.com
  
• In person: Clare Senior Care office locations
  

All grievances will be logged, investigated, and resolved per Clare’s Member Grievance and Appeals Policy. A written determination will be provided to the member within 30 calendar days.

7. Documentation and Audit Requirements 

Clare Senior Care shall maintain secure audit logs documenting all Program transactions, including credits earned, redeemed, and expired. These records will be:

• Retained for a minimum of 10 years or per CMS/EOEA retention rules
  
• Stored in HIPAA-compliant electronic systems
  
• Made available to regulatory agencies upon request
  

Periodic internal audits will verify compliance, accuracy, and equitable administration.