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August 21, 2024

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In Focus

Improving Healthcare for Justice-Involved Populations: Key Insights on Medicaid Section 1115 Reentry Demonstrations

This week, our In Focus section considers state and local initiatives centered on the intersection of carceral care and state Medicaid programs.

The Health Management Associates (HMA) team includes clinicians and leaders who bring extensive expertise in justice healthcare, Medicaid, managed care, administration and operations, quality and accreditation, and information technology. Drawing on this wealth of experience, we provide five key insights for states, industry professionals, and other stakeholders aiming to improve healthcare access and related services for justice-involved populations.

Community Reentry: A Pivotal Point to Impact Health Outcomes

The Centers for Medicare & Medicaid Services (CMS) designed the Medicaid Section 1115 Reentry Demonstration Opportunity to improve access to community resources that address the healthcare and health-related social needs of people who are preparing to reenter their communities after incarceration. Medicaid enrollment assistance and prerelease coverage for certain services can help ensure successful care transitions during reentry. This demonstration allows states to provide Medicaid-reimbursable services up to 90 days before release from carceral facilities. These services include care management, behavioral health consultations, and peer support designed aiming to smooth the transition back into the community.

States and their partners are using these Medicaid regulatory flexibilities to develop—and eventually implement—programs that focus on the critical point of transition and reduce emergency department visits and inpatient hospital admissions for both physical and behavioral health issues once individuals are released and return to the community.

Recent State Activity Interest in Medicaid Reentry Initiatives

In July 2024, CMS approved Medicaid Section 1115 reentry demonstration proposals from Illinois, Kentucky, Oregon, Utah, and Vermont. These states join California, Washington, Montana, and Massachusetts in their work to develop the operational details and implementation plans to cover some services prior to release, increasing access to and continuity of care for returning individuals. According to HMA’s monitoring and analysis, another 13 states and the District of Columbia have reentry proposals pending CMS review.

Roles for Medicaid Partners

With 41 states, including the District of Columbia, using managed care for specific Medicaid populations, local and regional managed care organizations (MCOs) are integral to this landscape. The Medicaid Reentry Section 1115 Demonstration highlights the importance of early engagement with state partners and MCOs in preparing to serve the justice-involved population effectively.

By understanding these demonstrations and strategically developing their policy and operational plans, states and MCOs can enhance their services and improve outcomes for individuals transitioning out of carceral facilities. The continued focus on integrating comprehensive care models reflects a commitment to advancing the quality of healthcare for justice-involved individuals and ensuring their successful reentry into the community.

Key Considerations for States and Partners

CMS approval of state reentry demonstration proposals is the first of several critical steps required to improve access to services and health outcomes. Based on their real-world strategy, policy, and operational experience in Medicaid and correctional systems, the HMA team identified the following key considerations for states and their partners pursuing reentry initiatives:

  • Successful reentry programs require breaking down longstanding silos and challenges in policy, funding, contracting, systems/IT, bias, and other aspects integral to reentry.
  • All stakeholders will benefit from operationalizing best practices that use data metrics and reporting to demonstrate compliance with federal and state oversight and monitoring across carceral, public health, and Medicaid programs.
  • State and local carceral facilities may need to change their contracts with healthcare vendors to meet contractual and quality standards and best practices, including, in some cases, transitioning to provision of care to public health systems and university partners.
  • Build a team that will support successful state reentry programs. For example, government and their partners need expertise in the intersection of healthcare and correctional systems, skills in delivery system transformation, and knowledge of the publicly funded healthcare industry. The team will benefit from comprehensive experience with state prison systems, county and municipal jails, drug courts, and probation and parole, including implementing and coordinating medications for addiction treatment along a continuum of care in response to the substance abuse and opioid use disorder crisis facing communities nationwide.
  • Prepare to collaborate with new entities that have a range of experiences and perspectives.

Connect with Us 

The July 2024 edition of HMA’s Podcast, Vital Viewpoints, features a discussion with HMA Managing Director for Justice-Involved Services Linda Follenweider about her insights on this pivotal moment in carceral healthcare. Linda, an advanced practice registered nurse and board-certified family nurse practitioner, discusses the critical gaps in continuity of care for incarcerated individuals. She emphasizes how many people receive necessary medical care while in jail or prison but struggle to maintain these services upon release. The episode showcases the opportunities presented by adopting routine screening questions about incarceration history to ensure better health outcomes and resource utilization.

The upcoming conference, Unlocking Solutions in Medicaid, Medicare, and Marketplace, hosted by HMA, will offer more opportunities to engage with fellow executives, policymakers, and thought leaders across multiple sectors and industries advancing policy and programmatic innovations in carceral care and reentry. Notably, HMA experts Tonya Moore and Stuart Venske offer invaluable insights from their involvement in the development and execution of the CMS Section 1115 demonstration policies, including the reentry opportunity.

For more information about HMA’s work at the intersection of carceral care and Medicaid, contact Linda Follenweider and Julie White.

HMA Roundup

Georgia

Georgia to Launch $10.7 Million Ad Campaign to Boost Enrollment for Expansion Program. The Atlanta Journal-Constitution reported on August 20, 2024, that Georgia is launching a $10.7 million ad campaign to encourage enrollment for its Pathways to Coverage Medicaid expansion program, which includes work requirements. Although the state projected that more than 240,000 individuals could be eligible to enroll in the program, about 4,300 individuals have enrolled since the program began in July. Read More

Georgia to Launch State-based Marketplace November 1. WSBTV reported on August 15, 2024, that Georgia’s health insurance marketplace will transition from the HealthCare.Gov portal to a state-based exchange dubbed Georgia Access, slated to launch on November 1 for the 2025 open enrollment period. Georgia Access will be part of the Office of the Insurance and Safety Fire Commissioner. Read More

Illinois

Illinois Launches PACE; Contracts with Five Organizations. Modern Healthcare reported on August 16, 2024, that the Illinois Department of Healthcare and Family Services launched its Program of All-Inclusive Care for the Elderly (PACE) on June 1 in five regions: West Chicago, South Chicago, Southern Cook County, Peoria, and East St. Louis. The state is contracting with five organizations, including OSF HealthCare, which was the only health system to receive a contract. PACE provides home and center-based care for adults aged 55 and older who are Medicare and Medicaid dual eligibles. Read More

Indiana

Indiana Medicaid Beneficiaries to Maintain Coverage During Healthy Indiana Plan Legal Proceedings, Judge Rules. WFYI reported on August 20, 2024, that a federal judge ruled Healthy Indiana Plan (HIP) members will be able to keep their HIP Plus coverage while the state appeals a federal ruling vacating approval of several aspects of HIP over policies that would require the state’s Medicaid beneficiaries to pay monthly premiums through POWER account contributions. The judge granted the stay because the Indiana Family and Social Services Administration agreed not to collect contributions during the appeal. The ruling does not apply to other Medicaid programs, including CHIP and MEDWorks, whose members will be responsible for cost-sharing. Read More

Massachusetts

Massachusetts Legislature Passes Maternal Health Bill Expanding Access to Doula, Midwife Care. The Boston Globe reported on August 15, 2024, that the Massachusetts legislature has passed a maternal health bill which provides Medicaid coverage for doula care and a pathway to licensure for certified professional midwives and lactation consultants. Under the legislation, reimbursement rates for certified nurse midwives will match those for physicians who provide birthing care, and allows midwives to write prescriptions. The bill now moves to the Governor’s office. Read More

Michigan

Michigan to Submit Dual Demonstration Renewal Request Applications by October 1. The Michigan Department of Health and Human Services announced on August 19, 2024, that it intends to submit renewal requests for its Section 1915(b) and 1915(c) home and community-based services MI Health Link demonstration to the Centers for Medicare & Medicaid Services by October 1. MI Health Link is the state’s Medicare and Medicaid dual eligible program. Public comments will be accepted through September 11. The anticipated effective date for the MI Health Link demonstration renewal is January 1, 2025. Read More

Minnesota

Minnesota Submits Extension Request for Section 1115 Reform 2020: Pathways to Independence Demonstration. The Centers for Medicare & Medicaid Services (CMS) announced on August 16, 2024, that Minnesota has submitted a request to extend the state’s Reform 2020: Pathways to Independence Section 1115 demonstration through January 31, 2030. The waiver provides home and community based services—such as day and nutrition services, home health, and community first supports and services—for Americans 65 and older who are financially limited but not Medicaid-eligible and meet a nursing home level of care. The extension would add transitional services as a benefit. The demonstration expires January 31, 2025. Read More

New York

New York Faces Additional Lawsuit Over CDPAP Fiscal Intermediary RFP. Crain’s New York Business reported on August 20, 2024, that an additional nine companies have filed a lawsuit against the New York State Department of Health and its Commissioner in an effort to block the state’s single statewide fiscal intermediary services vendor procurement for the Consumer Directed Personal Assistance Program (CDPAP). The lawsuit, filed in the state Supreme Court, claims that the requirements for an incoming administrator are designed to exclude all qualified vendors in New York. The new sole statewide contract is slated to be awarded October 1. Read More

Governor Unveils $646 Million Initiative to Expand Health Care Workforce. Crain’s New York reported on August 16, 2024, that New York Governor Kathy Hochul has unveiled a $646 million initiative to recruit and train new health care workers over the next three years through the state’s Medicaid Redesign Team Section 1115 pilot program. Funding for the Career Pathways Training program will be distributed to three workforce investment organizations: 1199SEIU Training and Employment Funds, Iroquois Healthcare Association, and the Finger Lakes Performing Provider System. The participants are required to report performance metrics and spending information and must make a three-year commitment to providers from whom at least 30 percent of their clients are Medicaid beneficiaries or are uninsured. Read More

North Carolina

North Carolina Awards Foster Care Specialty Plan Contract to Blue Cross Blue Shield. The North Carolina Department of Health and Human Services issued on August 15, 2024, a contract award to Blue Cross and Blue Shield of North Carolina for the new Children and Families Specialty Plan (CFSP), a single, statewide plan for children, youth, and families served by the child welfare system. The plan will provide physical health, behavioral health, intellectual and developmental disability, long-term care, and pharmacy services. CFSP is one of four types of integrated Medicaid managed care plans in the state. Contracts will run December 1, 2024, through June 30, 2028, with one option year. Read More

North Carolina Announces Three Grant Opportunities to Expand Mental Health Services. The North Carolina Department of Health and Human Services announced on August 15, 2024, three grant opportunities totaling $4.5 million which aim to support community-based partners in developing and expanding mental health services, specifically for those with substance use and/or intellectual and developmental disabilities. The three grant opportunities include funding to implement community-based mental health initiatives, peer respite and peer living room models, and family and caregiver support services. Eligible organizations are encouraged to submit a proposal or application for funding through the Mental Health Block Grant. Read More

Texas

Texas Files Lawsuit Over CMS Nursing Home Staffing Rule. Modern Healthcare reported on August 14, 2024, that Texas has filed a lawsuit against the Centers for Medicare & Medicaid Services (CMS) over last year’s final rule ordering skilled nursing facilities to have staffing minimums. The rule requires facilities to have a registered nurse on staff at all times and provide a minimum of 3.48 hours of care per resident each day, 0.55 of which must come from registered nurses. The lawsuit argues that CMS has no authority to issue the rule, and that it will force the state to spend millions of dollars on staffing. CMS estimates the requirement will cost facilities $40.6 billion over 10 years. The American Health Care Association and National Center for Assisted Living filed a similar lawsuit in May. Read More

Vermont

Vermont Approves Double Digit Premium Rate Increases for Marketplace Plans. Health Payer Specialist reported on August 19, 2024, that Vermont approved double digit premium hikes for individual plans on the Marketplace. Blue Cross Blue Shield of Vermont will increase individual premiums by 19.8 percent and MVP Health Care will increase individual premiums by 14.2 percent. Read More

Washington

Washington Launches Statewide Electronic Consent Management System ConsentLink. Healthcare Innovation reported on August 19, 2024, that the Washington Health Care Authority (HCA) launched the first statewide electronic consent management (ECM) software system, called ConsentLink, which will house Medicaid beneficiaries’ consents on sensitive data sharing. HCA chose to initially focus on consent sharing of substance use disorder (SUD) data to address the opioid epidemic and plans to implement other consents later on. The agency worked with Midato Health and provider partners Comprehensive Life Resources, Consistent Care, and Answers Counseling to pilot the software before its statewide launch. The ECM system uses federal and state Medicaid funding and will be free for providers to use in their practice. Read More

Wisconsin

Wisconsin Task Force Recommends Medicaid Expansion, Training Programs, to Address Workforce Shortage. Wisconsin Public Radio reported on August 21, 2024, that, according to a report by Governor Tony Evers’ Task Force on the Healthcare Workforce, the state could address its healthcare workforce shortage by expanding Medicaid, funding rural healthcare worker training programs, and reducing training barriers. The report outlines 10 policy recommendations and 26 related actions to help address the shortage. It also recommends the state fund more wraparound services—such as transportation and childcare—to reduce training barriers for students pursuing degrees in healthcare. Read More

National

DOJ Announces Funding Opportunity for Medicaid and Corrections Training and Technical Assistance Program. The Department of Justice (DOJ), Bureau of Justice Assistance announced on August 19, 2024, a funding opportunity for the fiscal 2024 Medicaid and Corrections Training and Technical Assistance (TTA) Program. The award will fund up to one organization to provide TTA to correctional institutions to help leverage and comply with new and existing Medicaid rules expanding reentry services for justice-involved individuals. The program is meant to further the DOJ’s work to improve justice and health outcomes for reentering individuals. The application deadline is September 16. Read More

CMS, Manufacturers Reach Pricing Agreements for 10 Medicare Part D Drugs. The Centers for Medicare & Medicaid Services (CMS) announced on August 15, 2024, that the Biden administration has negotiated the price of 10 prescription drugs covered under the Medicare Part D plan, with lower prices expected to yield $6 billion in savings, with an additional $1.5 billion in savings for those who pay out of pocket. The negotiated costs of the drugs, which treat diabetes, heart disease, and cancer, will be 38 to 79 percent lower than list prices. CMS will continue to negotiate the prices of other Part D drugs, selecting the next 15 to negotiate by February 1, 2025. New prices for the first 10 will go into effect January 1, 2026. Read More

CMS Announces Cell and Gene Therapy Access Model NOFO. The Centers for Medicare & Medicaid Services (CMS) announced on August 15, 2024, a notice of funding opportunity (NOFO) for the Cell and Gene Therapy (CGT) Access Model, designed to increase access to cell and gene therapy, improve health outcomes, and reduce health care costs. Up to $9.55 million in Cooperative Agreement award funding is anticipated to be available to each selected award recipient over the course of up to 10.5 years. All states and territories participating in the Medicaid Drug Rebate Program may apply, and applicants must apply to both the state request for applications and the NOFO by February 28, 2025. The anticipated award date is July 1, 2025. The Cooperative Agreement and the Model are anticipated to conclude no later than December 31, 2035. Read More

CHCs Struggle to Find Sufficient Staffing, Funding, Report Finds. Fierce Healthcare reported on August 16, 2024, that more than 70 percent of community health centers (CHCs), also known as federally qualified health centers, face a primary care, nurse, or mental health professional shortage, according to a Commonwealth Fund survey of 766 facilities. Additionally, many struggle to find adequate funding to cover the cost of care and face difficulties in coordinating care and referring patients to specialists, especially for those who are uninsured or have Medicaid coverage. However, most CHCs offer timely appointments, with 93 percent of centers offering expanded hours for patients. Read More

MACPAC Releases Brief on Eligibility Policies Impacting Access to HCBS. The Medicaid and CHIP Payment and Access Commission (MACPAC) released in August 2024, a policy brief outlining how state-level Medicaid eligibility policies affect the timeliness of access to home and community-based services (HCBS). The brief examines processes meant to accelerate eligibility determinations for individuals whose income is not determined by modified adjusted gross income standards, such as presumptive and expedited eligibility flexibilities, level of care assessment processes, and person centered planning processes, which can help states connect beneficiaries to HCBS faster. Read More

Aged, Disabled Medicaid Beneficiaries Account for Majority of LTSS Spending. The Medicaid and CHIP Payment and Access Commission (MACPAC) released in August 2024, an issue brief which found that aged or disabled Medicaid beneficiaries make up the vast majority of long-term services and supports (LTSS) spending, according to data from 2017 through 2018. The brief also found that dually eligible individuals age 65 and older, including those with physical disabilities, were less likely than those with Medicaid-only coverage to have visited the emergency room in the past year for any reason or to know whom to contact for making changes to their services. Read More

Medicaid Spending Averages $7,600 Per Member, KFF Finds. KFF released on August 16, 2024, a data analysis of total state and federal Medicaid spending of enrollees in 2021, which found national Medicaid spending per member per year was $7,593, with the highest spending on seniors and individuals with disabilities. Individuals with disabilities also had the widest spending variation across states, ranging from $4,602 in Florida to $52,602 in Connecticut. Variation in spending across states is attributed to variation in eligibility levels, benefits, provider payments, demographics, health care costs, and markets. Read More

HMA Releases Report on State Approaches to Managing the Medicaid Pharmacy Benefit. Health Management Associates released on August 20, 2024, a report on state approaches to administering the Medicaid pharmacy benefit, including survey findings on state containment and utilization management strategies, payment and rebate approaches, value-based arrangements, and planned policy changes and challenges anticipated in fiscal 2025 and beyond. Report authors will also discuss and present their findings at a pre-conference workshop “Paying for Innovative Pharmaceuticals: State and Federal Trends Shaping Public Programs” at HMA’s Unlocking Solutions in Medicaid, Medicare, and Marketplace conference, October 7-9 in Chicago. Read More

Industry News

Molina Extends Chief Executive Contract with Zubretsky Through 2027. Modern Healthcare reported on August 20, 2024, that Molina Healthcare has extended its contract with chief executive Joseph Zubretsky through 2027. Zubretsky started as Molina’s CEO in 2017, taking over for the Molina family who ran the company since its inception in 1980. Read More

Humana Agrees to $90 Million Payout in Medicare Part D Fraud Lawsuit. Reuters reported on August 16, 2024, that Humana has reached a $90 million settlement over a whistleblower lawsuit filed under the federal False Claims Act in 2016, which accused the insurer of overcharging the federal government for Medicare Part D prescription drugs between 2011 and 2017. The whistleblower, who is a former actuary for Humana, alleges that Humana submitted fraudulent bids to the Centers for Medicare & Medicaid Services for drug contracts, overstating the actuarial assumptions and the level of benefits it was providing. Read More

Elevance, Clayton, Dubilier & Rice Close Deal on Primary Care Company. Modern Healthcare reported on August 14, 2024, that Elevance Health has finalized a deal with private equity firm Clayton, Dubilier & Rice (CD&R) to form a primary care delivery platform named Mosaic Health. The newly formed company will utilize primary care services from Millennium Physician Group and digital health services from Apree Health, both CD&R portfolio companies. The companies will also continue to operate independently. Terms of the deal were not disclosed. Read More

Tentative Deals Reached for Six Massachusetts Steward Health Hospitals. Modern Healthcare reported on August 16, 2024, that Lifespan, Boston Medical Center, and Lawrence General Hospital tentatively agreed to take over operations of six Steward Health Care hospitals in Massachusetts. Lawrence General Hospital will operate both campuses of Holy Family; Lifespan would take over operations of Morton Hospital and Saint Anne’s Hospital; and Boston Medical Center will take over operations of Good Samaritan Medical Center. Boston Medical Center also intends to operate Saint Elizabeth’s, although the state is first taking control of the hospital through eminent domain. Read More

Orlando Health Files $439 Million Qualified Bid to Acquire Three Steward Health Florida Hospitals. Health News Florida reported on August 15, 2024, that Orlando Health has filed a qualified, binding $439 million bid to purchase three of Steward Health’s Florida hospitals, along with some surrounding medical clinics. Orlando Health’s offer is subject to higher bids filed by August 26. A sales hearing for the hospitals is scheduled for September 10. Read More

RFP Calendar

HMA News & Events

NEW THIS WEEK ON HMA INFORMATION SERVICES
(Exclusive Access for HMAIS Subscribers):

HMAIS Reports

  • Updated Section 1115 Medicaid Demonstration Inventory
  • Updated West Virginia State Overview

Medicaid Data

Medicaid Enrollment:

  • Arizona Medicaid Managed Care Enrollment is Down 1.4%, Aug-24 Data
  • Illinois Medicaid Managed Care Enrollment is Down 3.9%, Apr-24 Data
  • Illinois Dual Demo Enrollment is Down 12.4%, Apr-24 Data
  • Kansas Medicaid Managed Care Enrollment is Down 0.7%, Jan-24 Data
  • Louisiana Medicaid Managed Care Enrollment is Down 6.6%, Apr-24 Data
  • Maryland Medicaid Managed Care Enrollment Is Down 1.6%, Mar-24 Data
  • New Jersey Medicaid Managed Care Enrollment is Down 9.1%, May-24 Data
  • New York Medicaid Fee for Service vs. Managed Care Penetration, 2014-23
  • Washington Medicaid Managed Care Enrollment is Down 4.4%, Jul-24 Data
  • Wisconsin Medicaid Managed Care Enrollment is Down 5.4%, Mar-24 Data

Public Documents: 

Medicaid RFPs, RFIs, and Contracts:

  • Idaho Dual Medicaid Managed Care RFP Documents, 2024
  • Maine Transformed Medicaid Statistical Information System Comprehensive Solution RFI, Aug-24
  • North Carolina Foster Care Specialty Plan RFP, Award, Proposals, and Related Documents, Feb-24
  • Virginia Cardinal Care Managed Care RFP, Award, Protest, and Related Documents, 2023-24
  • Washington Third-Party Reentry Initiative Services RFI and Responses, 2024
  • Washington State Medicaid Agency Contract (SMAC) D-SNP Contract, 2024

Medicaid Program Reports, Data, and Updates:

  • Arizona AHCCCS Quality Strategy Evaluation, CYE 2021-23
  • Arkansas DHS External Quality Review Technical Report, 2020-23
  • Massachusetts Medicaid Managed Care Plan Quality Performance Report, 2018-23
  • Minnesota Reform 2020 1115 Waiver Documents, 2013-24
  • New Hampshire Medicaid Enrollment Demographic Trends and Geography, Jul-24
  • Wisconsin Governor’s Task Force on the Healthcare Workforce Report, Aug-24
  • DOJ FY 2024 Medicaid and Corrections Training and Technical Assistance Program Funding Opportunity, Aug-24

A subscription to HMA Information Services puts a world of Medicaid information at your fingertips, dramatically simplifying market research for strategic planning in healthcare services. An HMAIS subscription includes:

  • State-by-state overviews and analysis of latest data for enrollment, market share, financial performance, utilization metrics and RFPs
  • Downloadable ready-to-use charts and graphs
  • Excel data packages
  • RFP calendar

If you’re interested in becoming an HMAIS subscriber, contact Andrea Maresca at [email protected].

Edited by:

Alona Nenko
Andrea Maresca
Mary Goddeeris
Gabby Palmieri
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