Medicaid Reentry and Community Health (M-REACH)

Medicaid Reentry and Community Health (M-REACH)

M-REACH is a new program under Colorado’s 1115 “Expanding the Substance Use Disorder (SUD) Continuum of Care” Waiver (1115 Waiver). On January 13, 2025, the Centers For Medicare and Medicaid Services (CMS) approved a waiver amendment authorizing reentry services. Implementation dates for the two phases of this program have been adjusted to account for delays in receiving necessary federal authority. Reimbursement for reentry services will begin on the following schedule: 

• Phase 1 (State-run correctional facilities): January 1, 2026
• Phase 2 (Local correctional facilities): January 1, 2027

The reentry services that HCPF will offer meet the minimum requirements established by CAA 5121, described below.

M-REACH Overview

Project Goals 
As described in the amendment application, the goals of M-REACH include: 

• Increase coverage, continuity of coverage, and appropriate service uptake through assessment of eligibility and availability of coverage for benefits in carceral settings just prior to release;
• Improve access to services prior to release and improve transitions and continuity of care into the community upon release and during re-entry;
• Improve coordination and communication between correctional systems, Medicaid systems, administrative services organizations, and community-based providers;
• Increase additional investments in health care and related services, aimed at improving the quality of care for beneficiaries in carceral settings and in the community to maximize successful reentry post-release;
• Improve connections between carceral settings and community services upon release to address physical health, behavioral health (BH), and health-related social needs (HRSN);
• Reduce all-cause deaths in the near-term post-release; and
• Reduce the number of emergency department (ED) visits and inpatient hospitalizations among recently incarcerated Medicaid beneficiaries through increased receipt of preventive and routine physical and BH care.

Reentry Services Package
Coverage for reentry services will begin 90 days prior to release for all Medicaid and CHP+ eligible youth and adults and include:

• Case Management: Targeted Case Management (TCM) will be provided in the period up to 90 days immediately prior to the expected date of release and is intended to facilitate reentry planning into the community in order to: (1) support the coordination of services delivered during the pre-release period and upon reentry; (2) ensure smooth linkages to social services and supports; and (3) ensure arrangement of appointments and timely access to appropriate care and pre-release services delivered in the community;
• MAT: Medication assisted treatment (MAT) for all types of substance use disorders (SUDs) as clinically appropriate, including coverage for medications in combination with counseling/behavioral therapies in the period up to 90 days immediately prior to the expected date of release; and
• Pharmacy: A 30-day supply of all prescription medications provided to the individual immediately upon release from the correctional facility, consistent with approved Medicaid and CHIP state plan coverage authority and policy.

As established by the Centers for Medicaid & Medicare Services (CMS), correctional facilities must offer all three of those services (minimum service requirement) to participate in M-REACH. Facilities do have flexibility to determine whether they will bill Medicaid for some or all of those services.

Steps to Participate
In order for reentry services to be billable, the correctional facility in which the member is incarcerated must have passed a Facility Readiness Assessment. The assessment covers the following topics: 

• Medicaid Application Processes
• Provider Enrollment & Billing
• 90-day Pre-Release Service Delivery
• Oversight & Project Management

HCPF will work in conjunction with participating facilities to support the development of policies and procedures to attain readiness, in alignment with the M-REACH policies and guidance provided below. Please consider the following milestones and associated timelines:

Legislative Background

• In 2022, the Colorado General Assembly passed SB22-196, requiring HCPF to evaluate and decide if the state should seek additional federal authority to provide certain reentry services through Health First Colorado (Colorado Medicaid). HCPF engaged Health Management Associates (HMA), a national healthcare consulting firm, to fulfill the requirements of SB 22-196. The final report, Federal Authority to Support Health Related Re-Entry Services, outlines the population that would be covered, the services and benefits, the costs of these services, and the potential impact to Coloradans. The report states there are public health and financial benefits to HCPF covering a limited benefit for Medicaid eligible justice-involved population up to 90 days prior to release, and potential to improve outcomes for these individuals transitioning out of jails, prisons, and juvenile facilities. Based on the fiscal analysis, implementing reentry services for Medicaid-eligible members in prisons, jails and juvenile youth facilities is unlikely to increase state dollar expenditure.
• In 2024, the Colorado General Assembly passed HB24-1045, authorizing HCPF to request federal authority for and to implement a limited set of reentry services. On January 13, 2025, the Centers For Medicare and Medicaid Services (CMS) approved a waiver amendment authorizing reentry services. Additionally, the bill required HCPF to submit an annual report to the Colorado state legislature that provides information on the reentry demonstration benefit, see report listed below.
  • 2025 Reentry Demonstration Amendment Within the Comprehensive Care for Colorado Waiver (also posted on Legislator Resource Center webpage)

CAA 5121

CAA 5121 refers to Section 5121 of the Consolidated Appropriations Act of 2023. CAA 5121 creates federal minimum requirements for Medicaid and CHP+ services to be provided to eligible youth who are post-adjudication and 30 days prior to release from a correctional setting.
HCPF has requested federal authority through the 1115 Waiver, described above, to offer a more expansive set of reentry services. Through the phased implementation of Medicaid Reentry and Community Health (M-REACH), HCPF will meet the minimum standards created by CAA 5121. HCPF and our federal partners at the Centers for Medicare & Medicaid Services (CMS) recognize that it will take time after the CAA 5121 effective date of January 1, 2025, to fully implement reentry services in correctional facilities across the state.
For correctional facilities that wish to implement CAA 5121 services prior to M-REACH implementation, CMS guidance states that compliance can be achieved if a correctional facility furnishes the required services to eligible juvenile beneficiaries, regardless of whether those services are billed to Medicaid (SHO24-006).
CMS Guidance for CAA 5121

• SHO# 24-004 RE: Provision of Medicaid and CHIP Services to Incarcerated Youth
• SHO# 24-006 RE: Provision of Medicaid and CHIP Services to Incarcerated Youth - FAQs