I went with the OEM Tesla hanging bike rack (Yakima FullTilt 4), and while we've only used it to host the ski rack on top, one terrific thing that I did not expect is that the refresh MX does not require that it be tilted down in order for the hatch to open. (It is possible for it to collide if the rack is unweighted and tilted backwards, but with any weight, or a slight nudge, it stays out of the way.)
There's only a few mm of space in between, but it makes accessing the hatch super convenient.
I realize tray racks provide the same benefit, depending on the bikes, but the default hanging rack seems to be pretty ski friendly if your family is into such things. For bikes alone, if not too many, tray racks do seem superior.