Flex cards and grocery benefits that can also pay rent or utilities

This guide explains in clear terms:

• What flex cards and grocery benefits are
• When these benefits can be used for rent or utilities
• How HUD, Section 8, public housing, SNAP, and Medicaid treat flex card and grocery benefits
• Practical steps to protect your housing and benefits while using every resource available

Throughout, we rely on high quality, non commercial sources such as Medicare.gov, the Centers for Medicare & Medicaid Services (CMS), the U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Agriculture (USDA), the National Council on Aging (NCOA), the Center for Medicare Advocacy, and the Pennsylvania Health Law Project.

If you want broader support finding help with utilities, rent, and medical costs, you can also review Understood Care’s financial assistance resources at https://understoodcare.com/uc-articles/financial-help and https://understoodcare.com/uc-articles/how-seniors-can-beat-rising-expenses.

Introduction

Flex cards and grocery benefits are newer types of support that some Medicare Advantage plans offer. They are usually loaded onto a plastic card that works like a debit card at approved stores or vendors.

These benefits can make it easier to afford:

• Groceries and healthy food
• Over the counter medicines and health items
• Assistive devices and transportation
• In some plans, utilities such as electric or gas
• In a smaller number of plans, part of your rent or mortgage

The rules are detailed and vary by plan, which can be confusing. On top of that, HUD, SNAP, and Medicaid all have their own definitions of what counts as income or a resource.

This guide walks through the big picture and gives you language and questions you can use with your plan, landlord, housing authority, and advocates so you do not have to figure it out alone.

Key terms: flex cards, grocery cards, and supplemental benefits

Medicare Advantage and supplemental benefits

Medicare Advantage (also called Part C) is a type of Medicare health plan offered by private companies that contract with Medicare. Plans must cover all standard Part A and Part B benefits and can offer extra “supplemental benefits,” such as dental, transportation, and certain nutrition or utility supports.

Some of these supplemental benefits are delivered through pre loaded cards instead of traditional insurance billing.

What is a Medicare flex card

A Medicare flex card is a pre loaded debit type card offered by certain Medicare Advantage plans. It is not provided by Original Medicare. It is used to help pay for out of pocket costs and some day to day expenses that the plan has chosen to cover.

According to the National Council on Aging, flex cards:

• Are available only through participating Medicare Advantage plans, not through Original Medicare
• Are pre loaded with a set dollar amount per month, quarter, or year
• Can be used for qualifying expenses such as assistive devices, fitness classes, groceries, toiletries, over the counter products, transportation to care, and utilities, depending on the specific plan

Each plan decides:

• Who is eligible for a flex card
• How much money is loaded
• How often the benefit is renewed
• Which categories of spending are allowed
• Which stores, providers, or billers can accept the card

What is a Medicare grocery allowance or food card

Some Medicare Advantage plans, especially certain Special Needs Plans for people with both Medicare and Medicaid, offer a separate grocery allowance or “healthy food card.”

These cards:

• Are usually restricted to eligible food items and participating grocery or pharmacy chains
• Often exclude alcohol, tobacco, prepared hot foods, or non food items
• May be loaded monthly or quarterly

AARP notes that certain Medicare Advantage plans issue grocery allowances through prepaid cards (often called flex cards) that can be used for healthy foods and sometimes over the counter medicines at approved retailers.

Not all plans that have a grocery benefit also allow rent or utility payments. That is a special feature in only some designs.

Other terms you may see

You may see your benefits described with names such as:

• OTC card or OTC plus card
• Healthy food card
• Utilities benefit or “healthy utilities” credit
• “Special Supplemental Benefits for the Chronically Ill” (SSBCI)

These are all part of the broader category of Medicare Advantage supplemental benefits that CMS approves under federal law.

When flex cards and grocery benefits can pay rent or utilities

The most important thing to understand is that not every flex card or grocery benefit can pay rent or utilities. Whether yours can depends entirely on your individual plan.

Non profit benefits organizations report that, in some plans, flex cards can be used to help pay for groceries, rent, and utility costs.

In many cases, the benefit works like this:

• Your plan loads a set amount on the card
• The card can be used at approved merchants or for specified bill types
• The plan decides whether rent and utilities are valid categories

Common utility categories may include:

• Electric or gas
• Water and sewer
• Home heating or cooling
• Internet or phone service

In a smaller set of plans, the card or related allowance can be used toward:

• Rent payments to a landlord
• Sometimes mortgage payments, depending on plan rules

Even when rent is allowed, there may be caps, such as:

• Only a portion of the rent
• Only for a set number of months
• Only for members with specific chronic conditions or who are dual eligible (Medicare and Medicaid)

Because these details are plan specific, you should always check your plan’s official documents before using a card for rent or utilities.

How to check if your card can pay rent or utilities

To understand exactly what your card covers:

1. Look at the “Evidence of Coverage” or “Summary of Benefits”
   • Search for sections labeled “flex card,” “grocery,” “healthy benefits,” “utilities,” or “rent support.”
2. Log in to your plan’s member portal
   • Many plans show categories where your card can be used, including merchants and bill types.
3. Call the number on the back of your card
   • Ask specifically:
     • “Can this card be used to pay electric, gas, water, internet, or phone bills”
     • “Can this card be used for rent or mortgage payments”
     • “If so, how are those payments made and what proof do you require”
4. Use the official Medicare Plan Finder
   • If you are comparing plans, the Medicare.gov plan comparison tool lists extra benefits like food and utilities. This can help you see whether rent or utility support is available in your area.

If anything is unclear, it is reasonable to ask the plan to send written confirmation or a link to the relevant page in your Evidence of Coverage.

HUD, Section 8, and public housing: when flex cards count as income

A major worry for many people is whether a Medicare flex card or grocery benefit will be treated as income for housing programs such as:

• Housing Choice Vouchers (Section 8)
• Public housing
• Project based HUD rental assistance

In early 2025, HUD released a detailed Frequently Asked Questions document on Medicare Advantage supplemental benefits and flex cards for HUD assisted housing.

According to HUD and summaries from the Center for Medicare Advocacy and the Pennsylvania Health Law Project:

• Flex card benefits that are not used for rent or utilities should not be counted as income for HUD housing programs.
• This includes:
  • Amounts used for groceries, over the counter items, transportation, or other health related supports
  • Unused amounts that expire at the end of the month or plan year
• Flex card benefits that are used to pay rent or utilities must be included in income calculations for HUD rental assistance.
  • If you actually use the card to pay part of your rent or a utility bill, that portion is treated similarly to other rent or utility support in HUD rules.

HUD’s guidance also states that housing providers should generally:

• Assume flex cards and other Medicare Advantage supplemental benefits are not being used to pay rent or utilities, unless they have information that shows otherwise
• Avoid asking tenants to provide detailed verification of these benefits when they are being used only for groceries or other non housing items

This clarification came after reports that some residents saw rent increases simply because they received a flex card, even when they never used the card for rent or utilities.

What this means for you if you are in Section 8 or public housing

If you receive a flex card or grocery benefit and live in HUD assisted housing:

• Using the card for groceries, over the counter medicines, assistive devices, or transportation should not affect your HUD rent calculation under current federal guidance.
• If you use the card for rent or utilities, the amount used for those purposes may be added to your income for rent calculation.
• Simply having the card, or having a balance that expires, should not be treated as income.

Because each local housing authority may implement rules a bit differently, it is still important to:

• Ask your housing authority how they are applying the new HUD guidance
• Keep any letters or notices from your plan that explain what the card can be used for
• Keep copies of any rent or utility bills that were paid with the card, if you choose to use it for that purpose

If your rent has already gone up because of a flex card that you did not use for rent or utilities, you may have grounds to ask for a review. Organizations like the Center for Medicare Advocacy and state based health law projects have highlighted cases where residents were able to correct these errors once HUD issued its guidance.

SNAP, Medicaid, and other public benefits

Flex cards and grocery cards can also raise questions about food benefits, Medicaid eligibility, and other programs.

SNAP (food stamps)

In December 2024, the U.S. Department of Agriculture’s Food and Nutrition Service issued formal guidance on Medicare Advantage supplemental benefits and SNAP. The agency instructed state SNAP programs to:

• Exclude all Medicare Advantage supplemental benefits, including flex card and related supports, from SNAP income calculations.

The reasoning is that these benefits are reimbursements or targeted supports for health related needs, and they are not meant to provide extra cash income.

In practice, this means:

• Flex card or grocery card benefits should not reduce your SNAP eligibility or monthly SNAP amount.
• States are not supposed to treat these benefits as countable income or resources.

If you believe your SNAP caseworker has counted a flex card or grocery benefit as income, it is reasonable to:

• Ask them to review the USDA guidance on Medicare Advantage supplemental benefits
• Request a supervisor review or fair hearing if the issue is not resolved

Medicaid and other medical assistance

Legal aid organizations report that federal guidance now clarifies that Medicare Advantage flex cards should not be treated as income or resources for Medicaid eligibility.

However, Medicaid rules vary by state and can be complex. If you get a notice that your Medicaid was reduced or terminated because of a flex card or grocery benefit:

• Contact your state Medicaid office and ask for an explanation
• Request help from a legal aid or health law program in your state
• Keep all letters from your Medicare Advantage plan that describe the benefit

Other programs

Other programs, such as energy assistance (LIHEAP), local rent relief, or charitable supports, may have their own rules. In many cases:

• Flex card benefits used for health related items are not counted as income.
• If a program specifically asks about rent or utility assistance, it may want to know if your card is being used for those purposes.

It is important to read each application carefully and ask questions when you are unsure. An advocate or caseworker can often help you interpret the language.

Practical steps to use flex cards and grocery benefits safely

To get the most from your card without risking your housing or other benefits, consider these steps.

1) Confirm what type of card you have

Ask your plan or look at your materials to answer:

• Is this a flex card, a grocery only card, an OTC card, or a combined benefit
• Is it part of a Special Needs Plan (for example, a Dual Eligible Special Needs Plan)
• Does it include utility or rent support, or only health and food items

2) Learn exactly what the card can pay for

Review the official documents for:

• Approved spending categories
• Where and how you can make payments (in store, online, by phone, or through a bill pay service)
• Any limits on how much can be used for utilities or rent in a month or year

If you would like help reading plan documents, Understood Care advocates can walk through them with you and explain key terms in plain language. You can learn more about this kind of support at https://understoodcare.com/uc-articles/medicare-open-enrollment.

3) Decide how you want to use the card

Many people choose to:

• Use flex cards and grocery cards first for food, over the counter medicines, and health supplies
• Avoid using the card for rent or utilities unless they clearly understand how it will affect HUD income rules and rent calculations

If you are behind on rent or facing shutoff notices, it may still make sense to use the card for those bills. In that situation, it is especially important to:

• Talk with your housing authority or landlord about how the payment will be handled
• Keep records of how much card money went toward rent or utilities
• Ask an advocate or legal aid program to help you understand any impact on future rent amounts

4) Keep simple records

You do not need complicated bookkeeping. Simple steps like these can help:

• Save receipts and online confirmations for any rent or utility payments made with the card
• Take a photo of bills that show “paid with Medicare Advantage flex card” or similar notes
• Keep any letters from your plan that describe categories such as “food,” “OTC,” “utilities,” or “rent support”

These records can be useful if:

• Your housing agency misclassifies your benefits as income
• A caseworker asks questions about whether you used the card for rent or utilities
• You need to appeal a decision about rent or benefits

5) Get help if you receive a notice about rent or benefits

If you receive a letter saying your:

• Rent is increasing because of a flex card or grocery benefit
• SNAP or Medicaid is being reduced due to these benefits

You can:

• Contact your housing authority or benefits office and ask them to review current HUD or USDA guidance
• Reach out to a local legal aid or health law program
• Ask a patient advocate to help you gather documents, make calls, and track deadlines

Understood Care advocates can also help you connect flex card and grocery benefits with broader resources, such as LIHEAP, SNAP, and local rental assistance, similar to the support described in https://understoodcare.com/uc-articles/how-advocates-help-with-food-insecurity.

Questions to ask your plan, housing provider, and advocate

You can use questions like these in conversations or letters.

Questions for your Medicare Advantage plan

• Does my plan offer a flex card, grocery card, or both
• What are the specific categories this card can pay for (groceries, OTC, utilities, rent, transportation, dental, vision)
• Can this card be used to pay rent, mortgage, or security deposits
• Can this card be used to pay electric, gas, water, sewage, trash, internet, or phone
• How do I make a rent or utility payment if it is allowed (for example, by using a bill pay portal or calling a special number)
• Is there a monthly or yearly cap on rent or utility payments
• Where in my Evidence of Coverage can I read these rules

Questions for your housing authority or landlord

• How are Medicare Advantage flex cards and supplemental benefits treated when you calculate my rent
• Are you using the latest HUD guidance on Medicare Advantage flex cards and rental assistance
• If I use the card only for groceries and health items, will that be counted as income
• If I use the card for rent or utilities, how will that affect my rent now and at the next review
• Can I receive a written explanation of how my rental income was calculated

Questions for an advocate or benefits counselor

• Can you help me review my plan documents to understand what my card covers
• Can you help me talk with my housing authority about HUD’s flex card guidance
• Can you help me apply for or appeal SNAP, LIHEAP, or other programs that may offset food or utility costs
• If my rent or benefits went up because of a flex card, what are my options to challenge or correct that decision

When to ask for one on one help

You do not have to navigate flex cards, grocery benefits, HUD rules, and multiple applications on your own.

You may benefit from one on one help if:

• Your rent has increased after you received a flex card or grocery benefit
• You received a letter saying your SNAP, Medicaid, or other benefits are being reduced because of a supplemental benefit
• You are unsure whether using your card for rent or utilities is worth the tradeoff
• You are choosing between different Medicare Advantage plans and want to understand how their benefits interact with Section 8 or public housing

Support options can include:

• Understood Care advocates, who can coordinate across your health plan, housing programs, and community resources, as described in https://understoodcare.com/uc-articles/financial-help
• State Health Insurance Assistance Programs (SHIPs), which give free, unbiased Medicare counseling
• Legal aid or elder law programs for housing and benefits appeals

This guide is for educational purposes and does not replace legal or individualized financial advice. For specific decisions about your housing or benefits, it is important to speak with a qualified advisor, housing counselor, or attorney.

Frequently asked questions about flex cards, grocery benefits, rent, and utilities

• Does a Medicare flex card count as income for Section 8 or other HUD housing programs
  Under HUD’s 2025 guidance, flex card benefits used for groceries, over the counter items, or other non housing expenses should not be counted as income for HUD assisted housing. Only the portion of flex card benefits actually used to pay rent or utilities is treated as income for Section 8, public housing, or other HUD rental assistance. Local agencies must still follow these federal rules, so if your flex card was counted incorrectly, you can ask for a review.
• Can a Medicare grocery card pay my rent, and what are the HUD rules
  Some Medicare Advantage grocery or flex cards can help with rent, but many are limited to food and health items. You should check your plan’s Evidence of Coverage or call the number on your card to see if rent is allowed. If you do use the card for rent, HUD considers the portion used for rent as income in your rent calculation, while amounts used only for food and health items stay excluded. If you rely on Section 8 or public housing, it is important to discuss this choice with your housing authority before you start using the card for rent.
• How do Medicare Advantage flex card utilities benefits affect public housing rent calculations
  If your flex card or related benefit is used to pay electric, gas, water, or other utilities, HUD guidance says that the amount applied to utilities must be included in your income for rent calculation. However, benefits used only for groceries, over the counter items, or other non utility categories should remain excluded. Housing providers are encouraged to assume these benefits are not being used for rent or utilities unless they know otherwise, which reduces the need for extra paperwork in most cases.
• Is a Medicare flex card considered income for SNAP, Medicaid, or SSI
  For SNAP, federal guidance instructs states to exclude all Medicare Advantage supplemental benefits, including flex cards, from household income calculations. For Medicaid, federal agencies and health law organizations have clarified that flex cards should not be treated as countable income or resources, though it is still wise to check local practices and appeal if you receive a notice based on these benefits. SSI has its own rules, so if you receive SSI and are concerned, a benefits counselor or legal aid program can review your situation.
• What should I do if my landlord or housing office raised my rent because of a flex card or grocery benefit I did not use for rent or utilities
  Start by requesting a written explanation of how your income was calculated and how the flex card was treated. Share the HUD FAQ language that says flex card benefits not used for rent or utilities should be excluded from HUD income. You can then ask your housing authority to correct your rent. If that does not resolve the issue, you can contact a legal aid or housing rights organization and ask for help with an appeal or grievance. Bringing plan documents that show your card is used only for groceries or health items will strengthen your case.
• How can I find a Medicare Advantage plan with a flex card or grocery allowance that still works with my housing and benefits
  When you compare plans using the official Medicare Plan Finder, look carefully at extra benefits like groceries, utilities, and rent support. Make a list of what matters most to you, then talk with your state SHIP or an advocate about how those benefits interact with Section 8, public housing, SNAP, and Medicaid. It may be better to choose a plan with strong food and health supports and avoid rent or utility use, or you may decide that limited rent support is worth a small change in your HUD income. An advocate can help you weigh those tradeoffs based on your local housing rules and overall budget.

References

• Centers for Medicare & Medicaid Services – Understanding Medicare Advantage Plans (Publication 12026)
  https://www.medicare.gov/publications/12026-understanding-medicare-advantage-plans.pdf Medicare
• Medicare.gov – Medicare Advantage and other health plans
  https://www.medicare.gov/health-drug-plans/health-plans Medicare
• Centers for Medicare & Medicaid Services – Supplemental Benefits for Chronically Ill Enrollees (SSBCI) Guidance
  https://www.cms.gov/medicare/health-plans/healthplansgeninfo/downloads/supplemental_benefits_chronically_ill_hpms_042419.pdf CMS
• National Council on Aging – What Is the Flex Card for Medicare
  https://www.ncoa.org/article/what-is-the-flex-card-for-medicare National Council on Aging
• AARP – Does Medicare offer a grocery allowance
  https://www.aarp.org/medicare/faq/does-medicare-offer-grocery-allowance/ AARP
• U.S. Department of Housing and Urban Development – Frequently Asked Questions: HUD assisted Housing and Medicare Advantage Supplemental Benefits (including Flex Cards)
  https://www.huduser.gov/portal/portal/sites/default/files/pdf/FAQ-Medicare-Advantage-Supplemental-Benefits.pdf HUD User
• Center for Medicare Advocacy – New Medicare Advantage Flex Card Guidance Will Assist Enrollees Who Rely on Housing Benefits
  https://medicareadvocacy.org/new-medicare-advantage-flex-card-guidance-will-assist-enrollees-who-rely-on-housing-benefits/ Center for Medicare Advocacy+1
• Center for Medicare Advocacy – Issue Brief: Medicare Advantage Flex Cards and Public Benefits
  https://medicareadvocacy.org/issue-brief-medicare-advantage-flex-cards-and-public-benefits/ Center for Medicare Advocacy
• Pennsylvania Health Law Project – Clarifying Medicare Advantage Flex Cards and Their Impact on Public Benefits
  https://www.phlp.org/en/news/clarifying-medicare-advantage-flex-cards-and-their-impact-on-public-benefits Pennsylvania Health Law Project+1
• U.S. Department of Agriculture, Food and Nutrition Service – SNAP: Medicare Advantage Supplemental Benefits Excluded from Income
  https://www.fns.usda.gov/snap/medicare-advantage-supplemental-benefits-excluded-income Food and Nutrition Service
• U.S. Department of Agriculture, Food and Nutrition Service – SNAP: Medicare Advantage Supplemental Benefits Excluded from Income (Policy Memo PDF)
  https://fns-prod.azureedge.us/sites/default/files/resource-files/SNAP-Medicare-Advantage-Supplemental-Benefits-Memo.pdf USDA Food and Nutrition Service
• LeadingAge – HUD: FAQs on Medicare Advantage Flex Cards
  https://leadingage.org/hud-faqs-on-flex-cards/ LeadingAge
• LeadingAge – Memo: MA Supplemental Benefits Not Income for SNAP
  https://leadingage.org/memo-ma-supplemental-benefits-not-income-for-snap/ LeadingAge
• AJ Johnson Consulting Services – Understanding Medicare Advantage Flex Card Benefits in HUD Housing Income Determinations
  https://www.ajjcs.net/paper/main/2025/02/16/understanding-medicare-advantage-flex-card-benefits-in-hud-housing-income-determinations/ AJJCS

This content is for educational purposes only and does not replace professional medical, financial, or legal advice. Always consult your healthcare provider, housing authority, and qualified benefits or legal advisors for guidance specific to your situation.