Author Archives: Gabby Palmieri
OK Submits Extension Request for Section 1115 SMI Demonstration
The Centers for Medicare & Medicaid Services (CMS) announced on July 11, 2025, that the Oklahoma Health Care Authority (OHCA) has submitted a request seeking a five-year extension of its Section 1115 Institutions for Mental Diseases (IMD) for Serious Mental Illness (SMI) and Substance Use Disorder (SUD) Demonstration. The state is not seeking new demonstration authorities but is seeking to terminate the authority to cover Qualified Residential Treatment Programs (QRTPs) for beneficiaries under age 21 because the state has no QRTP programs. Public comments are open through August 10, 2025.
HHS Excludes Undocumented Immigrants from Additional Federal Benefit Programs
The U.S. Department of Health and Human Services (HHS) announced on July 10, 2024, that it has rescinded a 1998 interpretation of the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA), reinstating the law’s intent to limit federal public benefits to individuals who meet specific citizenship and immigration eligibility requirements. The updated policy broadens the list of HHS programs classified as “federal public benefits”—including certified community behavioral health clinics, Title X, and several behavioral health and workforce initiatives—and clarifies that these benefits are not available to undocumented immigrants. The change aligns with recent executive directives and takes immediate effect, with a 30-day comment period.
AL Governor Appoints Bo Offord as Medicaid Commissioner
Alabama Governor Governor Kay Ivey announced on July 10, 2205, that Bo Offord has been appointed commissioner of the Alabama Medicaid Agency, effective July 16, 2025. Offord has served in legal leadership roles at the agency since 2010. He succeeds Stephanie McGee Azar, who led the agency for over 13 years and will become CEO of the State Employees’ Insurance Board.
Section 1115 Medicaid Demonstration Inventory
HMAIS expanded its inventory of tracking documents to include a new resource focused on a subset of Medicaid Section 1115 demonstration programs. The calendar currently reflects 45 states with approved and pending 1115 demonstrations in eight major categories.
Federal Judge Rejects BCBS-LA Star Rating Challenge
STAT News reported on July 9, 2025, that a federal judge dismissed a lawsuit by Blue Cross Blue Shield of Louisiana challenging its Medicare Advantage (MA) star rating. The judge stated that the BCBS-LA’s arguments were inconsistent with their own previous requests. The lawsuit revolves around two MA contracts that BCBS-LA merged, alleging that CMS allows plans to submit data from both the surviving and consolidated contract for two years post-merger but then failed to use that data for some star measures.
ME Section 1115 Demonstration Substance Use Disorder (SUD) Care Initiative Documents, 2020-25
1. Maine Section 1115 Demonstration Substance Use Disorder (SUD) Care Initiative (Proposed “Whole Person Care”) Renewal Application, June 27, 2025
2. Maine Section 1115 Demonstration Substance Use Disorder (SUD) Care Initiative (Proposed “Whole Person Care”) Draft Renewal Application, March 18, 2025
3. Maine Section 1115 Demonstration Substance Use Disorder (SUD) Care Initiative Amendment, January 9, 2025
4. Maine Section 1115 Demonstration SUD Care Initiative, Approved December 22, 2020
ME Submits 1115 SUD Demonstration Renewal with New Coverage Initiatives
The Centers for Medicare & Medicaid Services (CMS) announced on July 10, 2025, that Maine submitted a Section 1115 demonstration renewal application for its substance use disorder (SUD) Care Initiative, requesting a five-year extension through December 31, 2030. In addition to continuing Medicaid coverage for a full continuum of SUD services, including short-term residential treatment in Institutions for Mental Diseases (IMDs), the renewal proposes new initiatives such as contingency management, transitions of care incentive payments, pre-release Medicaid services for justice-involved individuals, supports addressing health-related social needs, traditional healing therapies for Native Americans, and expanded coverage of clinically appropriate services for individuals with serious mental illness residing short-term in IMDs. The federal public comment period is open through August 9, 2025.
KY Section 1115 Community Engagement Demonstration Waiver Documents, 2025
1. Kentucky Section 1115 Community Engagement Demonstration Application, Issued June 25, 2025
2. Kentucky Section 1115 Community Engagement Draft Demonstration Proposal, Issued May 13, 2025
KY Submits New 1115 Application to Refer Expansion Enrollees to Job Services
The Centers for Medicare & Medicaid Services (CMS) announced on July 10, 2025, that Kentucky submitted an application for a new Section 1115 Community Engagement demonstration proposal which would require able-bodied Medicaid expansion adults without dependents, enrolled for more than 12 months, to be automatically referred to the state’s Department of Workforce Development for job placement support. Exemptions would apply to groups such as full-time students, individuals with disabilities, pregnant women, and caregivers. The state estimates 75,000 individuals would be subject to the program, with minimal impact on overall enrollment. Public comments will be accepted through August 9, 2025.
NY Increases Oversight of For-Profit Nursing Home Ownership
Crain’s New York Business reported on July 10, 2025, that New York’s Public Health and Health Planning Council is increasing oversight of nursing home ownership transfers amid concerns over inexperienced, for-profit operators in Medicaid-reliant facilities. A new committee will recommend stricter ownership criteria, deeper financial reviews, and closer scrutiny of related-party transactions. The move follows the council’s initial rejection—then conditional approval—of several for-profit entities seeking to acquire financially strained, Medicaid-dependent facilities.
