In 2023, the Centers for Medicare & Medicaid Services (CMS) issued guidance encouraging states to design and test reentry services for individuals transitioning from incarceration. The CMS 1115 reentry waivers let states explore new Medicaid approaches to improve healthcare coverage and access for vulnerable populations, including justice-involved individuals nearing release.

Implementing reentry waivers is not without hurdles. Many carceral facilities lack the technical expertise and infrastructure to manage Medicaid billing or deliver comprehensive pre-release services. States also face tight timelines to enact policy changes and scale programs. As other states are preparing to adopt similar models, Public Consulting Group (PCG) is here to help. PCG provides third party administration services, technical assistance, and implementation support in California, the first state in the nation to implement a reentry waiver to develop and test pre-release services for individuals transitioning from incarceration. From project and program management to stakeholder engagement to conducting research and analysis to help states develop programs and services that prioritize the health and well-being of people who are incarcerated, PCG has been a key partner in guiding California through successful implementation.

PCG’s Julia Kessler, Christine Newhall, Katie Thomas, and Shannon Weaver, authors of “Maximizing Impact: Implementing CMS 1115 Reentry Waivers with Public Consulting Group,” broke down key lessons learned from their work in helping California design and implement 1115 reentry waivers.

Transferable Lessons

California’s implementation of the CMS 1115 reentry waiver has provided a strong foundation for expansion in other states. A design service rollout with phased, iterative implementation approach has proven essential, particularly for justice system partners who have no prior experience billing Medicaid. Utilizing pilot groups to test and refine program implementation, and creating opportunities for technical assistance and peer-learning can help implementers as they gain familiarity with Medicaid processes. Iteration is key, and the design of re-entry programs should build in reflection and review periods on an on-going basis to ensure pain points can be proactively addressed.

It will be important to support justice system partners as they build and navigate new relationships that will be needed in their policy and program landscape. Practitioners will need to build trust and buy-in that will be key for establishing new services in partnership with Managed Care Organizations (MCOs), service providers, local government entities, and other key stakeholders. 

Adoption Considerations

In each state there will be complex and evolving needs of each county that will vary greatly in size and readiness level. Developing a clear and streamlined communication framework that accommodates differing needs, key stakeholders, and local program landscapes across the state will be critical.

The available resources for these initiatives will vary greatly across states and agencies. Policy design should take into consideration the available resources in each state or local entity, and determine milestones, timelines, and scope of services with feasibility and capacity in mind. 

Early Success Stories and PCG’s Impact

The early adopters in the state—Inyo, Santa Clara, and Yuba counties—have already begun providing pre-release services under the California Advancing and Innovating Medi-Cal (CalAIM) Justice Involved (JI) Reentry Initiative. This initiative has expanded access to behavioral health services, substance use disorder treatments, and post-release medical support. In Inyo County, there has been successful implementation with an integrated staffing model, embedding case workers within the social services department and county jail. This approach has fostered a collaborative service delivery model that allows for seamless care for justice involved individuals.

To date, California’s Justice-Involved Capacity Building Program has been awarded $493M, which is the largest initiative of its kind. Given California’s size, diversity, and complexity, the implementation of the reentry waiver has strengthened PCG’s ability to manage large-scale Medicaid initiatives, while still being flexible to local needs.

California’s experience has provided a playbook for national adaptation, offering tested strategies and practical insights that can accelerate implementation in other states. While PCG has extensive experience acting as the fiscal intermediary for a myriad of grant programs in states across the country, the lessons learned in California will serve as a roadmap for successful program development and expansion in other states.

Read more of PCG’s insights on implementing CMS 1115 Reentry Waivers here.