News: CMS rescinds SDOH guidance for state Medicaid programs

CDI Strategies - Volume 19, Issue 14

The Centers for Medicare & Medicaid Services (CMS) has rescinded information on health equity for state Medicaid and the Children’s Health Insurance Program (CHIP), according to a new CMS memo released on March 4.

The information was intended to support the coverage of certain services that address health-related social needs (HRSN), which the Department of Health and Human Services defines as “social and economic needs that individuals experience that affect their ability to maintain their health and well-being.”

HRSNs are a subset of broader social determinants of health (SDOH) factors, which are factors that influence health and well-being at a community level.

The first bulletin rescinded, Coverage of Services and Supports to Address Health-Related Social Needs in Medicaid and the Children’s Health Insurance Program, discussed opportunities available under Medicaid and CHIP to cover certain services and supports that appeared to address HRSN.

This bulletin was published in November 2023 along with the document Coverage of Health-Related Social Needs (HRSN) Services in Medicaid and the Children’s Health Insurance Program (CHIP), which CMS referred to as the “Framework of Coverage of HRSN Services in Medicaid and CHIP” or the “HRSN Framework.”

The second bulletin, an updated version of the first published in December 2024, provided clarifications and superseded both the November 2023 bulletin and the HRSN Framework.

Because they represent the immediate, actionable challenges individuals face due to broader systemic factors, HRSNs are critical for understanding SDOH and addressing health disparities. While SDOH like economic stability, education, and healthcare access create the conditions that influence health outcomes, HRSNs translate the conditions into specific barriers such as housing instability, financial strain, lack of access to healthy food, or lack of transportation.

CMS said it will consider state waiver applications on a case-by-case basis and then determine whether the applications meet federal requirements, potentially making it harder for services that address HRSNs to be covered by the affected programs.

Editor’s note: A version of this article was originally published in JustCoding.

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