States’ Opportunity: Reentry Section 1115 Demonstration

Medicaid Disproportionate Share Hospital (DSH)

January 2019

Strategies to Support Community Reentry and Improve Care Transitions for Justice-Involved Populations

In April 2023, the Centers for Medicare & Medicaid Services (CMS) issued SMD# 23-003, entitled, Opportunities to Test Transition-Related Strategies to Support Community Reentry and Improve Care Transitions for Individuals Who Are Incarcerated providing guidance for state Medicaid agencies to design and implement demonstration projects that focus on improving care transitions for incarcerated individuals who are nearing release.

This directive serves multiple key purposes:

Increase Access to Health Care Coverage and Services

CMS aims to increase access to Medicaid coverage and healthcare services for low-income individuals, particularly those who are incarcerated. By facilitating access to healthcare services before release, the demonstration projects are expected to ensure that these individuals can receive necessary medical care, which they would typically not be eligible for under standard Medicaid rules.

  • Section 1115 Expenditure Authority
    • Pre-release services to individuals in State Prisons, County Jails, and/or in Youth Correctional Facilities for up to 90 days prior to Release
    • Medicaid objectives promote coverage and quality of health care to improve transitions for individuals being released from carceral settings (and who are otherwise eligible for Medicaid or CHIP).
      • Expanding Eligibility: Extending Medicaid services to incarcerated individuals prior to their release.
      • Enhanced Services: Providing targeted healthcare services such as mental health support, substance abuse treatment, and chronic disease management during the transition period.
      • Care Coordination: Facilitating better coordination between correctional health services and community-based healthcare providers.
      • Potential Flexibility: Start date of 90-day period to include the recently released.
  • Targeted “Pre-release” Services Benefits Package

Aim of pre-release services is to improve identification of health and health-related social needs and facilitate connections to providers with the capacity to meet those needs in the community during the period immediately before an individual’s expected release.

    • Case management of physical and/or behavioral health
    • Medication-assisted treatment
    • Durable medical equipment
    • 30-day supply prescription drugs

How We Can Help 

Myers and Stauffer works to empower state Medicaid agencies with the tools and expertise necessary to implement critical health interventions such Reentry Section 1115 Demonstration waiver.

Our Expert Guidance 

Let our expert consultants help ensure your state is not only compliant with CMS requirements but also effectively meets the needs of your justice-involved populations

  • Budget Neutrality
  • Implementation Plan
  • Provider Readiness Assessment
  • Monitoring Protocol
  • Evaluation Design Framework
  • Reinvestment Plan
  • Comprehensive Program Development, Infrastructure Design, and & Operations Deployment

Improve Continuity of Care

The guidance promotes innovative approaches to healthcare that start pre-release and continue after an individual is released from incarceration. This approach is intended to improve continuity of care, which is crucial for ensuring that the health needs of reentering individuals are met in a timely and effective manner. Continuity of care is especially important for managing chronic conditions, mental health issues, and substance use disorders, which are prevalent in incarcerated populations.

Enhance Quality of Care

The initiative encourages states to test innovative service delivery systems that can lead to higher quality of care. This involves implementing evidence-based, coordinated, and integrated care models that are informed by best practices and promising approaches from around the country.

Facilitate Successful Community Reentry 

By improving access to healthcare services pre-release and ensuring effective care transitions, the demonstration projects aim to facilitate successful reentry of individuals into the community. Access to healthcare is a critical component of successful reintegration, as it can significantly impact an individual’s ability to find employment, secure housing, and reintegrate into society.

Financial Feasibility

The guidance offers states the opportunity to receive federal financial participation (FFP) for healthcare expenditures made for pre-release services to incarcerated individuals. Typically, these costs would not be eligible for FFP. This financial support is crucial for states to implement and sustain these innovative health service delivery models.

Improve Health Outcomes

Ultimately, the improved care transitions and continuous healthcare coverage are expected to lead to better health outcomes for individuals’ post-release. Better health outcomes not only benefit the individuals but also lead to broader public health benefits, including reduced healthcare costs, decreased rates of recidivism, and improved public safety.

CMS guidance represents a significant step towards addressing the healthcare needs of one of the most vulnerable populations—incarcerated individuals—by leveraging Medicaid’s capabilities to support innovative, effective care models that begin within correctional facilities and continue in the community.

How We Can Help

Our firm specializes in assisting state Medicaid agencies navigate, implement, and manage the complexities of Reentry Section 1115 demonstration waivers effectively.

Our services are designed to ensure that states can maximize the benefits of these waivers, ultimately focused on improving health outcomes and integration for individuals transitioning from incarceration to community living.

  • Change Management for Reentry Section 1115 Demonstration Implementations
    • Overview: We apply proven change management practices and tailored strategies to the unique challenges of health policy changes, ensuring state agency staff are prepared and aligned for new processes and systems.
    • Details: From stakeholder engagement to comprehensive training programs, our approach minimizes disruptions and promotes adoption across all levels of your organization.
  • Implementation Planning and Support
    • Overview: Our expert team provides end-to-end support in developing implementation plans, as well as logistical and operational assistance to set up the necessary systems and processes for compliant with federal guidelines and successful program launch.
    • Details: We focus on operational details, from infrastructure development to program rollout, ensuring every step supports the overall goals of enhancing care continuity and access.
  • Infrastructure Development for Health Services
    • Overview: Robust infrastructure is key to successful reentry health programs. We specialize in building integrated systems that support effective case management, MAT services, and timely medication distribution.
    • Details: Our solutions facilitate coordination between correctional facilities and community health providers, ensuring necessary health services are accessible immediately upon release.
  • Coordination and Integration Services
    • Overview: Coordination between multiple agencies and healthcare providers is crucial. We ensure that services are not only planned but also integrated smoothly to support the reentry population.
    • Details: Our firm helps establish protocols and partnerships necessary for effective delivery of case management services, MAT, and other critical healthcare interventions.
  • Other Services include:
    • Strategic Planning: Helping states design comprehensive reentry healthcare programs that align with federal guidelines and local needs.
    • Compliance and Monitoring: Ensuring that programs adhere to all regulatory requirements and achieve intended outcomes through rigorous monitoring and evaluation processes.
    • Training and Capacity Building: Equipping state agency staff with the knowledge and skills needed to manage reentry health programs effectively.
    • Stakeholder Engagement: Facilitating collaboration among corrections, Medicaid agencies, healthcare providers, and community organizations to create a seamless support network for reentrants.

For More Information:

Jerry Dubberly, PharmD
PH 404.524.9519
Kelly Gonzalez
PH 404.524.0775
Bobby Courtney, JD, MPH
PH 317.815.5475
Tara Clark, CPA
PH 888.749.5799