Food and produce benefit rules: what counts as ‘produce, frozen foods, canned goods’ and what is excluded

Quick answer

A “food and produce” or “healthy food” benefit is usually a plan benefit that can help pay for certain groceries. The exact rules come from your plan, but most programs focus on basic foods for home preparation and may block purchases like alcohol, tobacco, supplements, hot prepared foods, and nonfood items.

Introduction

If you are using a food and produce benefit, it can be frustrating when an item is declined at checkout even though it feels like groceries. That is because these benefits are usually built with specific item rules, and those rules can be stricter than what most people think of as food.

This guide explains what usually counts as:

• Produce
• Frozen foods
• Canned goods and shelf stable foods

It also explains what is commonly excluded and how to avoid checkout problems.

Content

• Why these benefits have item rules
• Produce: what usually counts and what is often excluded
• Frozen foods: what usually counts and what is often excluded
• Canned goods and shelf stable foods: what usually counts and what is often excluded
• Common exclusions that surprise people
• Practical steps to prevent declines

Why these benefits have item rules

Many food and produce benefits are offered through Medicare Advantage plans as extra benefits beyond Original Medicare. Some are designed specifically for people with certain chronic conditions or needs.

Because they are benefit dollars, the plan and its benefit administrator typically:

• Limit which stores can accept the benefit
• Limit which categories of items can be purchased
• Use item-level rules at checkout (for example, based on how an item is coded)

That is why a card may work for a bag of frozen vegetables but not for a frozen dessert in the same aisle.

Start with your plan’s definition of eligible food

Before you assume something is allowed, take a few minutes to confirm how your plan defines eligible items.

Helpful places to look:

• Your plan’s Summary of Benefits
• Your Evidence of Coverage
• Your plan’s online member portal or the benefit administrator portal
• A printed eligible items list, if your plan provides one

If you are a caregiver, ask for the list in writing. It makes shopping easier, especially when multiple people help with errands.

Produce: what usually counts

Usually included

In most programs, produce means fruits and vegetables intended for home use, such as:

• Fresh fruits and vegetables (whole or packaged)
• Bagged salad greens and lettuce mixes
• Pre-cut fruits and vegetables sold in sealed containers
• Fresh herbs, mushrooms, and similar produce items

Some plans also treat certain minimally processed produce as eligible, such as washed and trimmed vegetables.

Often excluded or treated as prepared foods

Produce is most likely to be declined when the store treats it like a ready-to-eat meal or a deli-prepared item. Examples that are often restricted include:

• Salad bar items priced by weight
• Deli-made fruit cups, prepared salads, or party trays
• Fresh juices or smoothies made in store
• Any produce item sold hot

If you see the item coming from the deli, hot bar, salad bar, or ready-to-eat area, assume it might be blocked unless your plan says otherwise.

Tricky produce items

These items can go either way depending on your plan:

• Salad kits that include dressing, croutons, or toppings
• Vegetable or fruit trays that include dip
• Dried fruit with added sugar
• Packaged snack packs that combine fruit with candy or desserts

When in doubt, choose the simplest version: plain produce without added dips, sauces, or extras.

Frozen foods: what usually counts

Frozen foods are one of the most common categories for declines, because frozen can mean many different things.

Usually included

Many programs allow frozen staples such as:

• Frozen fruits and vegetables, especially plain versions without sauces
• Steam-in-bag vegetables when they are still plain vegetables
• Frozen proteins that are basic ingredients (for example, plain fish fillets or unbreaded chicken), if your plan allows proteins

Often excluded

Frozen foods are commonly declined when they look like desserts, snack foods, or ready-made meals. Examples that are often excluded include:

• Ice cream, frozen yogurt, sorbet, popsicles, and frozen novelty treats
• Frozen desserts, cakes, pies, and cookie dough
• Frozen pizza, frozen sandwiches, and frozen burritos
• Frozen entrees and heat-and-eat meals

A simple rule that often matches plan logic:

• Ingredients are more likely to be eligible.
• Prepared meals and desserts are more likely to be excluded.

Tricky frozen items

These are common surprise decline items:

• Frozen vegetables in cheese sauce or butter sauce
• Breaded or fully cooked meats
• Frozen breakfast items like pancakes, waffles, or breakfast sandwiches

If your benefit is strict, choose plain frozen items and add flavor at home.

Canned goods and shelf stable foods: what usually counts

Many plans that allow frozen foods also allow a range of canned and shelf stable staples, but the details vary.

Usually included

Canned items that often fit basic food rules include:

• Canned vegetables and canned tomatoes
• Canned fruit packed in water or 100% juice
• Canned beans, lentils, and peas
• Canned tuna, salmon, sardines, or chicken
• Plain soups, broths, and stews, especially when they are clearly meal ingredients

Shelf stable staples are often included when a plan allows broader grocery purchases, for example:

• Rice, oats, and other grains
• Pasta and pasta sauce
• Nut butters, nuts, and seeds
• Shelf stable milk or plant-based milk alternatives

Often excluded

Canned and shelf stable items are more likely to be declined when they fall into nonfood categories or extras categories, such as:

• Cooking wine or alcohol
• Vitamins, medicines, and supplement drinks that are classified as supplements
• Household and personal care items (paper products, cleaning supplies, hygiene items)
• Candy and desserts

Some benefits also restrict certain beverage purchases. Even if a beverage is non-alcoholic, your plan may still block soda, energy drinks, and sweetened drinks.

Tricky canned and shelf stable items

These items can be coded in unexpected ways:

• Meal replacement shakes and protein drinks
• Electrolyte drinks
• Protein bars and nutrition bars
• Condiments and seasonings (ketchup, salad dressing, spices)
• Oils and sweeteners

If an item has a Supplement Facts label, many programs treat it as a supplement rather than a food item.

What is commonly excluded across food and produce benefits

Even when plans differ, there are exclusions that show up again and again. These are the categories to watch most closely:

• Alcohol and tobacco products
• Items containing controlled substances (for example, cannabis products)
• Vitamins, medicines, and supplements
• Hot foods at the point of sale
• Nonfood items like pet food, cleaning supplies, paper products, hygiene items, and cosmetics

If you are shopping at a store that sells groceries plus household items, you may need to split your purchase into two transactions.

How to reduce declines at checkout

Small process changes can save you a lot of frustration.

Try these steps:

• Use a simple test purchase first. Buy 2 to 5 items you are confident are eligible, then expand.
• Separate maybe items. Put questionable items (like salad kits or frozen meals) in a separate transaction.
• Avoid hot bars and deli counters unless your plan explicitly allows them.
• Keep your receipt. If a purchase is declined, the receipt helps your plan explain what happened.
• Ask for an eligible list. Many plans can provide a printable list or an online catalog of eligible items.
• Have a backup payment method. Fees, tips, and other charges may not be covered, especially for delivery.

When to call your plan

Call your plan or benefit administrator if:

• The same item is approved in one store and declined in another
• Your card declines even for basic groceries
• You are unsure whether online grocery delivery is allowed
• You need a written eligible items list for caregiving or budgeting

A useful question to ask is: “Does my food benefit allow only certain item categories, and does it block hot or prepared foods?”

Related Understood Care resources

• https://understoodcare.com/uc-articles/healthy-food-benefit-vs-otc-card-whats-the-difference
• https://understoodcare.com/uc-articles/can-you-use-a-medicare-flex-card-for-grocery-delivery-instacart-walmart-amazon
• https://understoodcare.com/uc-articles/deep-plan-by-plan-comparisons-of-grocery-benefits
• https://understoodcare.com/uc-articles/flex-cards-and-grocery-benefits-that-can-also-pay-rent-or-utilities
• https://understoodcare.com/uc-articles/helping-you-understand-your-benefits
• https://understoodcare.com/uc-articles/how-healthcare-advocates-help-with-nutrition-and-food-security‍

FAQ

• What counts as produce for a food and produce benefit?
  Produce usually means fruits and vegetables intended for home use, like fresh fruits and vegetables and packaged salad greens. Deli-prepared items (like salad bar purchases) are more likely to be restricted.
• Do frozen fruits and vegetables count for a healthy food benefit?
  Many plans allow plain frozen fruits and vegetables. Frozen items with sauces, breading, or dessert features are more likely to be excluded.
• Are canned goods eligible for a Medicare Advantage grocery benefit?
  Many plans allow canned staples like vegetables, beans, and canned fish. Eligibility can vary for soups, ready-to-eat items, and sweetened products.
• Are hot foods excluded from food and produce benefits?
  Hot foods at the point of sale are commonly excluded. If an item is sold hot or is meant for immediate consumption, it is more likely to be declined.
• Can I buy snacks or soda with a food and produce benefit card?
  Some programs allow them, but many Medicare Advantage food benefits use a narrower list and may block soda, energy drinks, candy, and desserts. Your plan’s eligible list is the best source.
• Why did my card decline for a salad kit or deli fruit cup?
  Items made or assembled by the store and sold as ready-to-eat foods can be coded as prepared foods, which are often restricted.
• Does a Supplement Facts label matter for eligibility?
  Yes. Many benefit programs treat items labeled as supplements differently from foods, so they may be excluded even if they look like nutrition products.
• How can caregivers prevent checkout problems when using a grocery allowance?
  Use a short eligible list, separate questionable items into a second transaction, keep receipts, and do a small test purchase when shopping at a new store.

References

• https://www.medicare.gov/health-drug-plans/health-plans
• https://www.medicare.gov/publications/12026-understanding-medicare-advantage-plans.pdf
• https://www.hhs.gov/answers/medicare-and-medicaid/what-is-medicare-part-c/index.html
• https://www.cms.gov/regulations-and-guidance/guidance/manuals/downloads/mc86c04.pdf
• https://www.cms.gov/medicare/health-plans/healthplansgeninfo/downloads/supplemental_benefits_chronically_ill_hpms_042419.pdf
• https://odphp.health.gov/foodismedicine/federal-resource-hub/medicare-advantage-health-plans
• https://www.cms.gov/priorities/innovation/media/document/vbid-cy2023-food-insecurity-use-case
• https://www.fns.usda.gov/snap/eligible-food-items
• https://www.fns.usda.gov/snap/retailer-eligibility-prepared-foods-and-heated-foods
• https://www.fns.usda.gov/snap/retailer/staple-foods
• https://www.fns.usda.gov/snap/retailer/accessory-foods
• https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2819557
• https://www.medpac.gov/wp-content/uploads/2025/06/Jun25_Ch2_MedPAC_Report_To_Congress_SEC.pdf‍

This information is for general education and does not replace medical advice from your own clinicians or care team. If you are considering PACE or have questions about PACE program food benefits, talk directly with your local PACE organization or a trusted advocate.