Adapt California’s CalAIM program to New York through an 1115 Medicaid Waiver

Disclaimer

Throughout the MPA process, more than 100 proposals were developed thanks in particular to thousands of hours of work by external stakeholders and members of the public. These proposals and the MPA Council commentary are being submitted to the Governor and shared with policymakers and the public to inform policymaking. These proposals represent a starting point for discussion. Further discussion is necessary between relevant state agencies and stakeholders to both refine these proposals and assess which may be appropriate to adopt and implement.

Summary

Implement a program like California’s CalAIM program to utilize Section 1115 waiver funds to build on existing services and fill service gaps. This proposal includes a series of recommendations to expand pre-release Medicaid enrollment and healthcare coverage, provide comprehensive pre-release healthcare services, and integrate community supports to address SDOH. 

Justification

California's CalAIM program leverages Section 1115 waivers to rework Medi-Cal in a way that addresses healthcare gaps for vulnerable communities, particularly for those transitioning out of incarceration. A core component of CalAIM is the provision of pre-release healthcare services for incarcerated individuals. Under existing federal rules, Medicaid coverage is suspended during incarceration, which leaves individuals without Medicaid-funded healthcare while in prison. With Section 1115 waivers, California established a pathway for incarcerated individuals to enroll in Medi-Cal and receive healthcare 90 days prior to their release. This helps maintain healthcare service continuity during the transition out of prison. CalAIM also incorporates Community Supports, which include services like housing navigation, medically tailored meals, and sobering centers. Section 1115 waivers allowed these non-traditional supports to be integrated into Medi-Cal. Care coordinators work with individuals before release, helping them plan for continuing their care in the community. Section 1115 waivers make it possible for Medicaid coverage to start before release, reducing interruptions in healthcare. Another important part of CalAIM is care coordination and data sharing. Setting up a data-sharing infrastructure between correctional facilities, Medicaid, and healthcare providers helps ensure that health information follows individuals as they reenter their communities. Section 1115 waivers allow Medicaid funds to be used for these coordination efforts, which are essential for successful reentry.

Full Proposal

Implement recommendations to allow New York State to implement a program like California’s CalAIM by using Section 1115 waiver funds to build on existing services and fill service gaps:

• Expand Pre-Release Medicaid Enrollment and Healthcare Coverage by establishing a Statewide Pre-Release Enrollment Program
  • Build on Existing Programs: Expand statewide New York’s current 1115 waiver demonstration program that reinstates Medicaid within 30 days prior to release. Currently, Medicaid suspension is reinstated post-release, but this can create delays in access to essential services.
  • Use an 1115 waiver to ensure that Medicaid is fully activated for all incarcerated individuals at least 90 days prior to release. This will require coordination between DOH, Department of Corrections and Community Supervision (DOCCS), and local Departments of Social Services (LDSS).
  • Implement a centralized data-sharing system that allows correctional facilities to automatically notify Medicaid offices of impending releases, ensuring a streamlined re-enrollment process.
• Provide Comprehensive Pre-Release Healthcare Services by establishing Comprehensive Pre-Release Health Coverage
  • Build on Existing Programs: Use the NYC Department of Health and Mental Hygiene’s Bureau of Transitional Health Care Coordination and DOH’s Medicaid Health Homes as models for providing pre-release healthcare to all incarcerated individuals.
    • This was recommended in 2016 by the Governor’s Council on Community Re-Entry and Reintegration.
  • Use Managed Care Organizations (MCOs) to deliver primary healthcare, behavioral health services, and substance use treatment during the last 90 days of incarceration. This mirrors the managed care involvement under CalAIM.
  • Expand services offered by Health Homes to ensure continuity of care, including comprehensive physical and mental health assessments, medication management, and care coordination for those with chronic health conditions.
  • Work with OMH to integrate behavioral health services within this 90-day pre-release window.
• Integrate Community Supports to Address SDOH by expanding Medicaid to Cover Community Supports
  • Build on Existing Programs: Utilize the reentry programs of the Fortune Society, Osborne Association, Release Aging People in Prison, and Parole Preparation Project, among other community-based models for providing holistic support (housing, employment, health services, etc.).
  • Use an 1115 waiver to include Community Supports as Medicaid-covered benefits, focusing on addressing SDOH like housing, employment support, and food security.
  • Establish housing navigation services for those reentering society, as seen in California's waiver. These services should include housing deposits, tenancy education, and support for finding permanent supportive housing. This can build on partnerships with organizations, such as the Supportive Housing Network of New York (SHNNY).
  • Collaborate with local nonprofits, Health Homes, older adult centers, home-delivered meals providers, and others to provide medically tailored meals, transportation support, and community health worker services, enhancing the transition into community life.

MPA Council Commentary

This proposal is categorized as long-term. In 2022, the Department of Health submitted an 1115 waiver application to CMS seeking approval to provide in-reach services to incarcerated individuals; this application is currently pending CMS, as New York and CMS continue to review the best way to implement such an initiative. In addition, DOH – in partnership with many other state agencies, including DOCCS, the Division of Criminal Justice Services (DCJS), the Commission of Correction, and OCFS, amongst others – are taking many steps to address the health of the justice-involved population. DOH is in the process of implementing targeted in-reach services for justice-involved youth, including physical and behavioral health screenings and targeted case management and referrals, which are designed to improve connections to critical healthcare services and bolster better health outcomes. As part of the State’s recently implemented health-related social need (HRSN) 1115 waiver services, justice-involved adults with serious chronic conditions and juvenile justice-involved youth who are high risk are eligible for enhanced HRSN care management, housing, nutrition, and HRSN transportation services. DOCCS currently offers pre-release discharge planning and provides for healthcare needs. Any changes to the Medicaid program or additional resources required to implement additional initiatives in this area would be subject to the annual budget process and available resources.