On March 4th, the Centers for Medicare and Medicaid Services (CMS) issued an informational bulletin (CIB) that rescinds guidance issued during the Biden Administration on opportunities available to states under Medicaid and the Children’s Health Insurance Program (CHIP) to address Health-Related Social Needs (HRSN). The rescinded guidance from November 2023 (here and here) and December 2024 (here) had laid out a framework for how states can address HRSN within the Medicaid program.
With this rescission, the most up-to-date guidance on the matter appears to be the State Health Official (SHO) letter (here) issued by the previous Trump Administration in its final days in office. While the 2021 SHO letter also outlines ways that states can address social factors under existing Medicaid and CHIP authorities, it is broader and less prescriptive than the rescinded HRSN guidance, which provides explicit guardrails, duration limits, and spending caps for specific HRSN services.
In the CIB rescinding the previous guidance, CMS states that it “will consider states’ applications to cover these services and supports on a case-by-case basis to determine whether they satisfy federal requirements for approval…without reference to the November 2023 and December 2024 CIBs or the HRSN framework.”
The CIB does not appear to directly impact the already-approved New York Health Equity Reform (NYHER) 1115 waiver. However, CMS may revisit NYHER and require New York to justify it under the framework established in the 2021 SHO letter, or possibly under future guidance yet to be released.
The CIB is available here.