Author: Karin VanZant, Vice President, Social Determinants of Health & Health Equity
The first time you may have heard about 1115 waivers was in January 2018 when the first KY-HEALTH 1115 Waiver was in development in Kentucky—requiring twenty hours of community service or employment.1 Since its approval in 2018, KY-HEALTH 1115 has undergone several years of changes and is currently up for renewal in September 2023. KY-HEALTH 1115 is one of many 1115 waivers approved by CMS, which provide states with a pathway to test innovative approaches that align with the current administration. Three of the six immediate priorities of the White House focus on health equity and impact all sectors of the healthcare system. Given the country’s priorities to restore the system post-pandemic, promote racial equity, and protect and expand access to quality, affordable healthcare, the approvals of the Medicaid 1115 waivers with social determinants of health and health equity provisions truly make sense.
Take a closer look at what’s included in the most recent Medicaid 1115 waiver approvals and some of the work that must be done between the states and their plan partners in the coming months in order to be committed to heath equity.
Source as of March 2, 2023: https://www.kff.org/medicaid/issue-brief/medicaid-waiver-tracker-approved-and-pending-section-1115-waivers-by-state
Massachusetts
On September 28, 2022, CMS and the Massachusetts EOHHS announced the approval of their latest MassHealth Section 1115 waiver amendment—a significant milestone in the state’s Medicaid program that will impact every aspect of care delivery in the Commonwealth. Several components are related to SDOH and health equity.
- A focus on the individual aspects of SDOH: Health-related social needs are specific non-medical needs that may help or hinder an individual from accessing or achieving health services that impact health outcomes. MassHealth will focus on increasing access to housing, food security, and transportation services and achieving higher-quality health outcomes.
- Housing support may include security deposits and rent; relocation expenses; furniture and home modifications; air conditioning and filtration systems; housing case management; and housing outreach, education, and linkages to other state and federal programs.
- Food security support may include nutrition support and counseling; meals for up to six months; food security case management; and food security outreach, education, and linkages to other state and federal programs.
- Transportation support may include transportation to and from both housing and food support programs and services.
- Eligibility conditions and process changes: Several updates have been approved that allow continuous eligibility for at least twelve months for members experiencing homelessness and those recently released from correctional institutions. The adult eligibility process has been streamlined and the one-time deductible for certain individuals has been eliminated as well.
California
Much of the country has been watching the California Advancing and Innovating Medi-Cal (CalAIM) waiver since its approval in December 2021. The California Department of Health Care Services requested a five-year extension of its Medicaid 1115 demonstration and 1915(b) managed care waivers.2 The CalAIM initiative launched in Jan 2022 to provide more equitable programs and access to the more vulnerable residents in California.3 Since then, managed care plans have rolled out Enhanced Care Management benefits and fourteen ILOS categories for plans to use, many of which address health-related social needs.4
Then in January 2023, CMS approved the state’s 1115 request to cover a package of reentry services for eligible incarcerated individuals ninety days before release.5 The approved request is now the first 1115 waiver to include a partial waiver of the statutory Medicaid inmate exclusion policy prohibiting Medicaid from paying for services provided during incarceration.
Why would California ask to waive this part of the exclusion? The 2018 SUPPORT for Patients and Communities Act directed CMS to examine how waivers could assist in the continuity of care for individuals entering and exiting the justice system.6 California estimates 200,000 individuals will participate in its Reentry Demonstration Initiative each year—a complex program with several interesting pre-release services.
- All Medicaid-eligible adults incarcerated in state prisons and county jails and juveniles in youth correctional facilities will be screened for eligibility ninety days before release.
- Beginning April 2024, case management services, pre-release education and outreach, and Medicaid eligibility and enrollment information will be provided to all incarcerated individuals.
- Limited benefits will be offered pre-release to improve transitions of care to individuals upon release to prevent hospitalizations, overdose, recidivism, and suicide.
Waivers in Other States
At least fourteen other states are pending similar types of requests. These states understand the administrative burden involved in ending and reestablishing eligibility when individuals enter and exit the justice system, the general lack of care continuity, and the difficulties of accessing high-quality housing, food security, and transportation services across the country.
If your state is adjusting with a newly approved 1115 waiver or facing a pending waiver with SDOH and health equity requirements, take the right steps to weather change with confidence. Clearlink has partnered with states to build 1115 waivers and with health plans to support SDOH and health equity program development, helping the industry meet the needs of complex members with strategic population health and integrated care approaches, and embracing health equity for a lasting impact.
Our experienced consultants can offer guidance as you:
- Assess your organization’s readiness surrounding 1115 waivers
- Begin program development and establish related partnerships
- Ensure appropriate data and analytics capabilities are in place
Looking to propose something in your state? Need assistance navigating 1115 updates? Connect with Clearlink to get in touch with our team of specialized industry experts.
Sources:
- KY HEALTH State Waivers List, Centers for Medicare & Medicaid Services
- California Reentry Demonstration Initiative Amendment Approval, Centers for Medicare & Medicaid Services
- CalAIM Waiver Announcement Issue Brief December 2021, California Department of Health Care Services
- CalAIM Enhanced Care Management and In Lieu of Services FAQ, California Department of Health Care Services
- Section 1115 Waiver Watch: How California Will Expand Medicaid Pre-Release Services for Incarcerated Populations, KFF
- H.R.6 – SUPPORT for Patients and Communities Act 115th Congress (2017–2018), Congress.gov