Medicaid Reentry and Community Health (M-REACH)

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

Re-entry transitional case management services to assess and address physical and BH needs and HRSN;
Medication Assisted Treatment (MAT) for all medications approved by the Food and Drug Administration (FDA), including coverage for counseling; and
A 30-day supply of covered medications upon release

Pending additional federal approval, the earliest that HCPF anticipates having authority to reimburse for covered reentry services delivered at Division of Youth Services and Department of Corrections facilities is October 1, 2025, and local jails on July 1, 2026. The reentry services that HCPF will offer meet the minimum requirements established by CAA 5121, described below.

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.

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