In a new letter to the Centers for Medicare and Medicaid Services (CMS), CHLPI and partner organizations lift up the voices of 35 stakeholders across 19 states.
Over the course of March 2023, CHLPI, the Food is Medicine Coalition (FIMC), and the National Produce Prescription Collaborative (NPPC) developed and distributed a survey for on-the-ground implementers, participants, and evaluators of Medicaid 1115 waiver demonstrations piloting nutrition interventions. What’s working? What’s not? Why? What do you wish policymakers understood?
To nobody’s surprise, responses poured in. We heard from Food is Medicine (FIM) program participants, providers, researchers, advocates, and government officials. Respondents wrote of their experiences in states at various stages of section 1115 demonstrations that address nutrition insecurity—states with current waivers covering FIM services (AR, CA, MA, NC, OR), pending waivers that would cover FIM services (NM, NY), states with legislative proposals directing the state’s Medicaid agency to submit 1115 proposals that would cover FIM services (CT, FL, IL, PA, TX), and other states (CO, DC, GA, MD, MI, MN, OH).
Even amid the significant diversity in respondent characteristics, several themes emerged. As highlighted in our letter, learnings and recommendations focus on implementation challenges and opportunities in the following areas:
(1) Legal/regulatory barriers;
(2) Practical barriers; and
(3) Infrastructure funding and support.
Overall, respondents desired more “guidance” and “regulation” from CMS and state Medicaid agencies that would create “consistency,” “cohesion,” “simplicity,” “efficiency,” and “streamlined systems” but emphasized that policy must reflect and be responsive to the clinical and practical realities of implementation. In other words, there is a place for both standardization and flexibility. Balance between them is key to increasing equitable patient access to services, return on investment, and overall chances of pilot success. This has been and will continue to be a core message of our advocacy. For the full findings of the survey and our detailed recommendations, read the full letter here.
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