Allowing states to cover HRSNs has been a key tool for addressing the social determinants of health. These services included housing/home environment interventions; home improvements that are medically necessary, such as air filtration or mold removal; accessibility modifications for the home, such as wheelchair ramps; short-term housing; short-term rental assistance; and nutrition interventions. Applications will now be handled on a case-by-case basis under the Social Security Act, which will likely make them harder to obtain.
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Department of Health and Human Services
Non-binding advice and explanations issued by agencies about laws, regulations, and procedures, providing clarity and guidance to the public and regulated entities. It helps inform the public about how regulations are interpreted and implemented, without having the force of law.
Who It Impacts: Employees and divisions within the issuing federal agency. These directives guide how staff enforce regulations, allocate resources, and interpret laws. They may also affect industries regulated by the agency.
Who Is Not Impacted: The general public and businesses are not directly bound by guidance, though these policies may indirectly influence their applications for funding or enforcement practices that affect them.
Date Enacted
March 4, 2025
Last Updated
March 27, 2025
Policy Type
Food & Nutrition
Housing
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Summary
CMS rescinded bulletins on health-related social needs, affecting Medicaid and Children’s Health Insurance Program (CHIP) services and supports, such as housing and nutrition interventions. Eighteen states have approved section 1115 waivers to address these needs under the Health Related Social Needs (HRSN) framework - this framework was also rescinded but the approvals are still valid.
Impact Analysis
Legal Challenges
Take Institutional Action
States with HRSN waiver applications in progress are not required to follow or reference the rescinded guidance but may consider continuing to use the framework as best practice to consider as they design services. Currently states and other institutions can continue to look at how they can best address HRSNs through their approved and proposed waivers, and advocate for their inclusion.
Associated or Derivative Policies
Policy Prior to 2025
- CMS issued November 2023 bulletin, December 2024 bulletin, and the HRSN framework.
