Dear Administrator Brooks-LaSure:
We write in strong support of the State of Illinois’ application to the Centers for Medicare
and Medicaid Services (CMS) for a Section 1115 Demonstration Waiver to enhance the delivery
of behavioral health services for Medicaid beneficiaries across Illinois. Given the shared federal
responsibility for the Medicaid program, we urge CMS to swiftly approve the State’s 1115
application. This will accelerate efforts in Illinois to address the opioid epidemic, maternal
mortality, violence prevention, mental health challenges, homelessness, hunger, and many other
interrelated public health challenges facing our constituents.
The State’s 1115 application builds upon existing efforts to enhance the delivery of
targeted services to the most vulnerable populations—which holds the promise of reducing
health care costs and improving health care outcomes. The 1115 application also aligns with
several legislative, regulatory, and funding efforts we have supported in Congress to address the
root causes of health disparities and negative societal outcomes.
For example, we know that people experiencing homelessness have a disproportionately
high rate of emergency department utilization—with the University of Illinois at Chicago
recently identifying that 48 chronically homeless patients accounted for 776 emergency
department visits. The State’s 1115 application seeks to address this challenge by furnishing
housing support services to the most vulnerable patients and highest health care utilizers to
provide stable housing and wraparound supports that also can reduce hospital expenditures.
To address the high and concentrated toll of gun violence across our communities, the
State’s 1115 application seeks to utilize Medicaid funds for trauma-informed, community-based
outreach initiatives that can prevent and mitigate community violence. Through street outreach
and hospital-based violence recovery interventions, Illinois has built a nation-leading
infrastructure to break the cycle of violence by utilizing trusted community leaders to address the
trauma facing young people at risk of violence and furnishing mental health, job training, and
other support services.
Building upon the guidance CMS provided to states on the April 27, 2021, call regarding
strategies to utilize Medicaid to promote hospital-based violence prevention programs, this
requested authority holds significant promise to help young people who have witnessed violence
or are likely to perpetrate violence to cope with their experiences and thrive in a healthy manner,
thereby reducing health care costs from gunshot injuries and associated physical and mental
health harms. For example, compared to the national five-year re-injury rate for firearm injury
of nearly 50 percent, hospital-based programs in Illinois that furnish interventions as patients
transition into the community have successfully reduced retaliation and reinjury rates.
Similarly, one in 12 Illinoisans—including one in nine children—face hunger. Food
insecurity and diet-related chronic disease are a significant burden on our health system, and
imperil the academic success of young people. The 1115 application would support an array of
evidence-based interventions to foster healthy eating habits to prevent chronic disease, including
nutrition education and skill development, medically tailored meals, produce prescriptions, and
assistance accessing benefits and nutritious food options for at-risk populations.
The 1115 application proposes several additional authorities which we also strongly
support, including, among others, to: fund transformative collaborations across hospitals,
federally qualified health centers, and other community providers to coordinate care through
preventive services, including annual dental visits for those with substance use disorder; augment
the training and certification for community health workers; bolster the continuum of care
licensure for providers serving individuals with intellectual/developmental disabilities; permit
Medicaid enrollment for eligible individuals 90 days prior to release from incarceration to
promote a healthy and successful reentry; and allow coverage for clinically appropriate substance
use treatment services in Institutions for Mental Diseases.
An estimated 400,000 Illinoisans would benefit from the package of authorities and
services that are proposed in the State of Illinois’ Section 1115 Demonstration. Through our
collective efforts, Illinois has made remarkable progress in addressing the confluence of social
determinants of health that fuel racial and ethnic health disparities and contribute to health care
costs. To propel these efforts forward and harness innovative, community-driven solutions—
involving stakeholders outside of the typical health care system—CMS can help Medicaid
beneficiaries across Illinois improve health and wellbeing by approving the 1115 Demonstration.
We appreciate your consideration and thorough review, and urge your approval of
Illinois’ requested plan.