Section 1115 of the Social Security Act provides the Secretary of Health and Human Services the ability to approve experimental social determinants of health demonstrations or pilots through state Medicaid plans. These 1115 demonstrations or waivers are intended to help states be more flexible with the way they design and implement programs for Medicaid populations. The pilots must also align with Centers for Medicare and Medicaid (CMS) health equity priorities.
1115 demonstrations must be implemented by state Medicaid agencies in a way that is budget neutral. This means that during the course of the project, Medicaid expenditures will not be more than Federal spending without the demonstration in that state. Waiver periods typically last for 5 years with the possibility of a 3-5 year extension.
In Illinois, an 1115 demonstration is in line for a five-year extension this year, after initially being approved in 2018. The original demonstration focused on behavioral health benefits. When preparing the language for extension, the Illinois Department of Healthcare and Family Services (HFS) opted to include other health-related social needs (such as food and housing) that impact health outcomes. Other states like North Carolina and California have used 1115 demonstrations in similar ways to extend social determinants of health pilots.
HFS indicated they would open the 1115 demonstration extension for public comment from May 12 to June 12. Given the Alliance for Health Equity’s interest in social determinants of health programs, and specifically housing and food and nutrition interventions, they began the process of preparing comments to submit to HFS.
With respect to food and nutrition benefits, the Alliance began to research how other states had structured their 1115 demonstrations to cover food is medicine programs. Simultaneously, they also held conversations with policy experts, hospitals and healthcare systems, and community-based organizations who were familiar with Medicaid and could speak to the ways in which the benefits might be best designed to maximally benefit patients. The Alliance notably spoke with Mara Ruff from Sinai, Jill Hayden from Seller’s Dorsey, Alissa Wassung from the Food is Medicine Coalition, and Erika Hanson from the Harvard Center for Health Law and Policy Innovation. They also received recommendations from groups like the Chicago Food Policy Action Council, the USDA Midwest Health Care Partners network, and the Alliance for Health Equity’s Food is Medicine Subcommittee.
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As a result of their research into food and nutrition benefits and medical respite, the Alliance developed comments for HFS and shared theme with partners in their network. Partners were encouraged to adopt these comments into their own submissions or provide them to HFS directly. The Alliance’s comments were also presented at the Illinois’ public hearing on the waiver, which took place on May 25th.
HFS submitted their application to Federal CMS for approval at the end of June, including much of the feedback provided by partners who submitted the Alliance’s comments and remarks of their own. The final step before implementation in Illinois is to move forward with Federal approval of the extension. Partners who are interested in supporting this process of approval are encouraged to submit comments directly to Federal CMS voicing support for the 1115 demonstration before July 28.