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From Policy to Practice: HMA Offers New Toolkit for Tackling the Challenges of Implementing the 1115 Justice-Involved Reentry Demonstration in Carceral Settings

The Section 1115 Justice-Involved (JI) Reentry Demonstration marks a transformative step in closing the healthcare gap for incarcerated individuals. By allowing Medicaid coverage to resume up to 90 days prior to release, the demonstration aims to improve care continuity and reduce recidivism. Yet, translating this vision into action within jails, prisons, and juvenile detention facilities presents a host of operational challenges. For implementation to succeed, jurisdictions must navigate fragmented systems, strained resources, and competing priorities. That’s where structured tools—like implementation checklists—become essential.


The Challenges: Implementation in Complex, High-Stakes Environments

Implementing the 1115 JI Reentry Demonstration is more than a policy shift—it’s a systemic overhaul that requires cross-agency collaboration, infrastructure alignment, and cultural change. Among the most significant challenges:

1. Fragmented Systems and Data Silos

Carceral systems, Medicaid agencies, and community-based providers often operate in silos, using different data platforms and standards. This fragmentation hinders real-time information exchange and care coordination during the transition from incarceration to the community.

2. Operational Readiness Gaps

Many facilities lack established procedures for conducting Medicaid eligibility screenings, care plan development, and referrals to community-based services within the release window. Without predefined workflows, implementation can stall.

3. Workforce Capacity and Training Needs

Reentry planning demands coordination among correctional officers, social workers, nurses, behavioral health clinicians, and Medicaid staff. Many jurisdictions face staffing shortages and limited training on trauma-informed care, care management, or reentry protocols.

4. Policy Misalignment and Legal Constraints

Local policies may restrict access to Medicaid-related functions during incarceration, or limit facility staff’s ability to share data. Misinterpretation of federal and state rules can create implementation delays.

5. Trust and Engagement Barriers

Justice-involved individuals often face stigma or mistrust from systems they’ve interacted with. Culturally responsive engagement strategies are crucial but frequently underdeveloped.


The Solution: Using a Checklist-Based Implementation Framework

To navigate these hurdles, stakeholders need more than vision—they need structure. Implementation checklists tailored to jails, prisons, and juvenile facilities serve as a practical roadmap that transforms policy goals into operational plans. Here’s how they help:

  • Clarify Roles and Responsibilities

Checklists break down complex goals into clear, role-specific tasks—who enrolls individuals in Medicaid, who develops care plans, and who ensures warm handoffs to community providers.

  • Promote Cross-Sector Coordination

Structured checklists prompt regular touchpoints across agencies—corrections, health services, Medicaid, and behavioral health—ensuring alignment and accountability.

  • Standardize Procedures and Tools

By specifying recommended workflows, assessment tools, and communication protocols, checklists minimize variation and streamline implementation across facilities.

  • Track Progress and Gaps

Built-in progress indicators make it easier to monitor what’s completed, what’s pending, and where additional support or training is needed.

  • Support Compliance and Evaluation

A checklist-based approach provides the documentation trail needed for program audits, reporting, and continuous quality improvement.


Conclusion: A Strategic Tool for Lasting Impact

Implementing the Section 1115 JI Reentry Demonstration is a bold, necessary move toward health equity and system transformation. But success depends on more than ambition. With structured checklists in hand, agencies can move from aspiration to execution—building a thoughtful, well-orchestrated reentry infrastructure that improves health outcomes, reduces recidivism, and meets federal expectations.

Download the HMA JI Toolkit here.

Other 1115 demonstration resources that may be of interest:

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Julie White

Principal
Boston, MA
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John Volpe, LCSW

Principal
New York, NY
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