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Comment on HHS Report on Housing Supports for Individuals with Substance Use Disorders

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March 2021 | Substance Use Disorder

In a letter to congressional leaders and the Acting U.S. Department of Health and Human Services (HHS) Secretary Norris Cochran, MACPAC comments on the HHS report, Innovative State Initiatives and Strategies for Providing Housing-Related Services and Supports under a State Medicaid Program to Individuals with Substance Use Disorders (SUD) Who Are Experiencing or at Risk of Experiencing Homelessness.

The report identifies relevant federal authorities and other opportunities states can pursue to provide services that may help Medicaid-eligible individuals with SUD who are experiencing or at risk of homelessness access and maintain housing. It describes broad strategies used in five states (Arizona, California, Maryland, Pennsylvania, and Washington) to provide housing supports to beneficiaries with SUD who are experiencing or at risk of homelessness. The report highlights the difficulty that states face in determining the appropriate Medicaid authority to provide housing-related services to individuals with SUD.

In the letter, the Commission highlights the role that Medicaid can play in addressing social factors, such as housing, that affect the health of its beneficiaries. The Commission also comments on non-Medicaid barriers to housing stability for people with SUD and identifies opportunities for federal policymakers to address them. The Commission encourages the Centers for Medicare & Medicaid Services (CMS) to coordinate with other agencies to issue guidance on opportunities for Medicaid to provide housing-related services and other home- and community-based services to individuals with SUD and mental illness.  In addition, the letter says that Congress should consider requiring HHS to note any differences in access and outcomes among racial and ethnic minorities and how policies address health disparities.

Note: In this letter we provide information on racial and ethnic disparities among adults with mental illness who are enrolled in Medicaid. Specifically, the letter notes that Black beneficiaries age 18 – 64 experience mental illness at twice the rate of white beneficiaries. The analysis supporting that statement has been updated since this letter’s publication. MACPAC’s updated analysis revealed that non-institutionalized Black individuals aged 18 – 64 with mental illness are enrolled in Medicaid at nearly twice the rate of white individuals with mental illness. Yet, Black beneficiaries receive treatment at lower rates than their white counterparts. Similar rates are observed when comparing Medicaid enrollment rates among Hispanic individuals with mental illness, and individuals with mental illness who are two or more races.

Publication Type: Comment Letters