Social Needs Guidance for Medicaid Taken Down by CMS

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Key Takeaways

CMS retracted bulletins on health-related social needs, affecting Medicaid and CHIP services like housing and nutrition interventions.
The retraction aligns with the Trump administration's stance against diversity, equity, and inclusion programs, and potential Medicaid budget cuts.
Criticism from health care experts and Democrats highlights potential harm to patients, especially in Republican states.
Health equity applications will now be evaluated case-by-case under the Social Security Act, potentially delaying assistance.

Information on health equity was removed by the federal government for both the Children’s Health Insurance Program and Medicaid.

CMS has recently retracted bulletins originally released in the winter of 2023 and 2024 regarding health equity for both Medicaid and the Children’s Health insurance Program (CHIP) that would affect the ability of patients to apply for social services related to health.¹ The efforts described in the bulletins accomplished through the use of section 1115 waivers, which can be used in Medicaid and CHIP to test new or current ways of delivering and paying for health care.²

This health equity information primarily addressed health-related social needs (HRSNs), giving those who required assistance in health care an avenue to obtain that assistance. According to the 2024 bulletin,³ these services included housing/home environment interventions; home improvements that are medically necessary, such as air filtration or mold removal; accessibility modifications for the home, such as wheelchair ramps; short-term housing; short-term rental assistance; and nutrition interventions. All of these services could become harder to obtain with the rescinding of the information.

CMS stated in a new memo⁴ released on March 4 that it would be rescinding the 2024 Center Informational Bulletin (CIB) on the topic of HRSNs and will only be evaluating states’ applications to cover the services in the future. Applications to meet federal requirements will now be handled on a case-by-case basis by using the Social Security Act as a reference rather than the CIB or the HRSN Framework.

Guidance for social services offered by Medicaid and CHIP have been rescinded by CMS | Image credit: Tada Images - stock.adobe.com

Guidance for obtaining social services offered by Medicaid and CHIP have been rescinded by CMS | Image credit: Tada Images - stock.adobe.com

This continues the Trump administration’s continued targeting of equity services and Medicaid. An executive order ending diversity, equity, and inclusion (DEI) programs was signed on the first day of the new administration,⁵ indicating that all DEI programs in the federal government should be terminated within 60 days of the signing of the order. This rescinding of health equity information from the CMS is in line with this order.

The Trump administration has also indicated that Medicaid could be receiving major cuts in the upcoming budget. President Donald Trump has endorsed a House budget that would effectively cut $880 billion from any program that falls under the House Energy and Commerce Committee, which includes Medicaid.⁶ Although it is unclear how much of that $880 billion will come directly from the Medicaid program, the Congressional Budget Office has estimated that either Medicaid or Medicare would have to face significant cuts to achieve the House budget as written.⁷

Criticisms of the rescinding of the health equity guidance have started from Democrats and experts in health care. In a post on LinkedIn, former chief medical officer of the US Medicaid program Andrey Ostrovsky, MD, FAAP, stated that “failing to finance HRSNs or [social determinants of health] with Medicaid will disproportionately harm patients and taxpayers in Republican states.”¹ Sen Ron Wyden (D, Oregon) also criticized the move, stating that keeping Americans healthy relies on addressing underlying causes of health issues.

The future of the applications regarding health equity is unclear as it shifts under the umbrella of the Social Security Act. With the number of applications, it is possible that the applications being considered on a rolling basis could make the approval process longer, preventing patients from getting needed assistance in a timely manner.

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