CHA News Article

CMS Clarifies Medicaid Reimbursement of Housing-Related Activities

The Centers for Medicaid & Medicare Services (CMS) has released the attached bulletin to assist states in designing their Medicaid benefits, and to clarify the circumstances under which Medicaid reimburses housing-related activities. CMS’ goal in distributing the information is to promote community integration for individuals with disabilities, older adults needing long-term services and supports (LTSS) and those experiencing chronic homelessness. The guidance clarifies that consistent with statute, CMS does not provide federal financial participation for room and board in home and community-based services, but can assist states with coverage of certain housing-related activities and services. CMS notes it is working with the Substance Abuse and Mental Health Services Administration to provide additional guidance and clarify the circumstances under which Medicaid reimburses for certain housing-related activities and services for those experiencing chronic homelessness.

The bulletin identifies how the following housing-related activities and services can be incorporated into a Medicaid benefit design for individuals needing LTSS and in states’ strategies for transforming systems to achieve optimal community integration: 1) Individual Housing Transition Services – services that support an individual’s ability to prepare for and transition to housing; 2) Individual Housing & Tenancy Sustaining Services – services that support the individual in being a successful tenant in his/her housing arrangement and ability to sustain tenancy; and 3) State-level Housing Related Collaborative Activities – services that support collaborative efforts across public agencies and the private sector and that assist states in identifying and securing housing options for individuals with disabilities, older adults needing LTSS and those experiencing chronic homelessness. Additionally, the bulletin describes the Medicaid authorities and demonstrations through which states can be reimbursed for these services.

The California Department of Health Care Services (DHCS) has included a proposal aimed at increasing housing and supportive services in its final draft 1115 Medi-Cal 2020 waiver renewal application submitted  to CMS for approval by Nov. 1. DHCS has requested authority from CMS to reimburse health plans for a new set of tenancy-based care management services to support at-risk Medi-Cal members to stay in their homes, and to assist Medi-Cal members who are experiencing homelessness in securing stable housing. Under the proposal, DHCS would partner with Medi-Cal managed care plans, counties, community organizations and federal partners to develop county-specific pilot programs in counties where there is a commitment from the full spectrum of stakeholders that will provide the population with the support they need to find and maintain housing and gain consistent access to needed community supports.

Non-traditional Medi-Cal services would include tenancy supports such as outreach and engagement, housing search assistance, stabilization, paying rent and bills on time, not disruptive to other tenants, maintaining SSI and other benefits. The managed care plan would also provide intensive medical case management and care coordination, discharge planning, creation of a care plan, and coordination with primary, behavioral health and social services to improve health outcomes and reduce inpatient services among this high-utilizer, complex population. Such approaches would also be included in the regional, integrated whole-person care pilots also included in the DHCS waiver proposal.

Additionally, housing is an area of focus under DHCS’ proposed Health Homes Program. One objective of the proposal is to ensure that health home providers appropriately serve Medi-Cal members experiencing homeless. AB 361, which authorized DHCS to create a health home program for enrollees with chronic conditions, requires that providers who serve homeless members have the capabilities to engage and serve those members, including making referrals to supportive housing and other social services.

The final Medi-Cal 2020 waiver application is attached. For more information, visit the DHCS 1115 Waiver Renewal website.

More information is available in the attached DHCS concept paper. For more information on the Health Homes for Patients with Complex Needs initiative, visit