Demystifying Federal Authorities: State Considerations for Addressing Social Needs in Medicaid

Below is an excerpt from a recent paper authored by Manatt Health with support from the Commonwealth Fund and Blue Shield of California Foundation and in partnership with the National Governors Association. Click here to read the full report.

Over the past several years, a growing body of literature has indicated that up to 50% of an individual’s health can be driven by the underlying social and economic factors affecting their lives, such as access to safe housing, healthy food, and transportation; education and employment status; and exposure to interpersonal violence. These factors are often collectively known as Health-Related Social Needs (HRSN).

Recent CMS Guidance on HRSN

2021 State Health Official letter on the Social Determinants of Health

2023 Informational Bulletin and accompanying framework on HRSN

2023 State Medicaid Director Letter on In-Lieu of Services and Settings (ILOS)

2024 Final Rule on Managed Care, including updated ILOS provisions

2024 State Medicaid Director Letter on 1115 budget neutrality policies, including for HRSN services

States are increasingly pursuing interventions to address HRSN in their Medicaid programs to improve health outcomes for members and maximize the value of their Medicaid expenditures. The Centers for Medicare and Medicaid Services (CMS) has issued multiple guidance documents and regulations outlining the various authorities under which state Medicaid agencies can fund initiatives to address their members’ HRSN and encouraging states to take advantage of these opportunities. The requirements for these authorities vary but generally afford states discretion to address HRSN if the proposed interventions can be supported by an evidence base illustrating their value in improving health. As a result, state Medicaid programs now have a range of options, which can be used in combination, for covering HRSN services in alignment with their programmatic goals. However, with this assortment of options comes a variety of authority-specific opportunities and constraints described in a patchwork of federal guidance, and determining the best approach to integrating HRSN services into a state Medicaid program can be challenging. This calculus is further complicated by the fact that federal HRSN approval policies are still evolving, in part due to evolving state requests.

This issue brief aims to provide states with an actionable and comprehensive roadmap to evaluate the most suitable authority (or combination of authorities) to meet their HRSN-related goals, based on available guidance to date. The brief is organized by key design questions, which, when combined, shape the scope and scale of state HRSN initiatives. For each design question, the brief describes potential considerations to help guide states’ selection of appropriate federal authority (or authorities) to support program goals and operations. There is no “right” or “wrong” path to authorize HRSN interventions—states with different goals, delivery systems, timelines and operational capacities will want to consider which path or paths are best suited to their circumstances.

Click here to read the full report.

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