Over the past several weeks, the Centers for Medicare and Medicaid Services (CMS) issued a number of 1115 waiver approvals. The approvals largely focus on issues that were central to the Biden Administration’s priorities, including health-related social needs (HRSN) services, also referred to as social determinants of health interventions; pre- and post-release services for individuals in correctional facilities; and substance abuse/mental health treatment. On a related basis, CMS has also released several forms of guidance, including Medicaid Director Letters and Informational Bulletins, to provide further guidance on items such as eligibility determinations and renewals, expansion and clarification of HRSN services, and coverage of services for incarcerated youth.

Through these actions, the administration seeks to shore up some of their central policy goals, including expanding access to coverage and addressing the social determinants of health for Medicaid beneficiaries. While President Trump could seek to undo some of these policy actions, rescinding waiver approvals can be challenging and undoing previously issued guidance will require future policymaking activity. As the administration transition occurs, we anticipate administrative activities that focus more intently on ensuring enrolled individuals are eligible for services, implementing additional eligibility criteria such as work requirements, and more aggressive fraud oversight.

Some of the waiver approvals have included:

Guidance has included: