Medicaid 1115 Waivers: Tracking SDOH, Pre-Release Coverage & Continuous Eligibility Changes

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Shifting Sands in Medicaid: Trump Administration Reverses Biden-Era Policies

The landscape of Medicaid is undergoing significant changes as the second Trump administration rolls back several key initiatives implemented during the Biden administration. These shifts impact access to care, workforce development, and coverage for vulnerable populations, signaling a return to a different set of priorities for the nation’s healthcare safety net.

Rescinding Biden-Era Guidance on Social Determinants of Health

A core area of change centers on addressing social determinants of health (SDOH) – the non-medical factors that influence health outcomes, such as housing, food security, and transportation. In 2022, the Centers for Medicare & Medicaid Services (CMS) under the Biden administration, announced a demonstration waiver opportunity to expand tools available to states to address enrollee “health-related social needs” (HRSN), including housing instability, homelessness, and nutrition insecurity [1]. This built upon earlier CMS guidance from 2021.

Still, in March 2025, the Trump administration rescinded this HRSN guidance. While existing state waivers approved under the Biden framework remain in effect, CMS will now evaluate future requests to address HRSN and SDOH on a case-by-case basis [1].

Phasing Out Medicaid Workforce Initiatives

Another significant reversal involves workforce development programs. CMS is phasing out federal funding for “Designated State Health Programs” (DSHP) within waivers, announced in April 2025 [1]. In July 2025, CMS announced it would not approve new or extend existing initiatives aimed at strengthening the Medicaid workforce in primary care, behavioral health, dental care, and home and community-based services [1]. This decision comes as states grapple with ongoing challenges in accessing providers, particularly in underserved communities, due to provider shortages and lower Medicaid payment rates [1].

Changes to Continuous Eligibility for Children

The Consolidated Appropriations Act of 2023 mandated 12-month continuous eligibility for children in Medicaid, beginning January 1, 2024. The Biden administration had previously approved nine waivers allowing states to extend this continuous eligibility to cover children from birth through age six, aiming to reduce coverage disruptions [1].

However, in July 2025, the Trump administration signaled a shift, announcing it would not approve new waivers or extend existing ones for continuous eligibility, impacting both children and adults [1].

Pre-Release Medicaid Coverage for Incarcerated Individuals

The Biden administration encouraged states to apply for waivers to provide Medicaid coverage to individuals prior to their release from incarceration, aiming to improve care transitions and reduce recidivism. Nineteen states received approval for waivers to facilitate this pre-release coverage [1]. This initiative garnered support from both Republican and Democratic governors.

Looking Ahead

These policy reversals represent a significant departure from the Biden administration’s priorities for Medicaid. The long-term impact of these changes remains to be seen, but they are likely to reshape the landscape of Medicaid coverage and access for millions of Americans. The evolving nature of Section 1115 waivers, reflecting the shifting priorities of presidential administrations, underscores the dynamic interplay between federal and state policies in shaping healthcare access.

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