AHCCCS seeks waiver amendment to improve health outcomes for homeless

The Centers for Medicare and Medicaid Services (CMS) announced on Monday that Arizona has submitted an 1115 waiver amendment request aimed at improving health services for its homeless population. The Arizona Health Care Cost Containment System (AHCCCS) submitted the request on May 27.

The amendment request – which AHCCCS refers to as the Housing & Health Opportunities (H2O) demonstration – looks to “improve health care delivery and health outcomes for AHCCCS members who are homeless or at risk of becoming homeless using strategies designed to fill identified gaps, expand existing evidence based practices, and reduce barriers to housing.


Get the latest state-specific policy intelligence for the health care sector delivered to your inbox.


According to data from the US Dept. of Housing and Urban Development, between 2017 and 2019, the number of homeless individuals across Arizona jumped by 12% to over 10,000 individuals. During this time, limited shelter capacity resulted in a 43% increase in the number of unsheltered individuals.

AHCCCS estimates the average annual cost of care for homeless Medicaid members is $23,090 – a cost approximately $16,082 greater than the average cost of care for Medicaid enrollees generally. The amendment request states:  

AHCCCS recently assessed the crisis, inpatient, and behavioral health care utilization of 30,363 members who were identified as homeless. A third of these members had three or more ED visits and 38 percent had three or more inpatient stays over the 18 month period reviewed.”

For homeless enrollees with a serious mental illness (SMI) designation, the average annual cost of care was $66,784.

In a letter to CMS Administrator Chiquita Brooks-LaSure, AHCCCS Director Jami Snyder writes that the new waiver amendment is designed to complement the agency’s existing housing program. Using state dollars, the current program provides rent subsidies to close to 3,000 individuals experiencing homelessness each year. Snyder says the existing program has led to improved outcomes and reduced costs.

“The State’s investment in permanent supportive housing programs has paid off, resulting in notable reductions in emergency department visits, inpatient admissions, and crisis utilization as well as increased use of less costly preventative care.”

The amendment request would advance this initiative, writes Snyder, by strengthening homeless outreach strategies, securing resources to support housing stability for members, and enhancing wraparound housing services and supports to drive better health outcomes.

Under its goals for strengthening outreach, AHCCCS is seeking authority to cover reentry services for individuals with serious behavioral and physical conditions who are at high risk for homelessness upon release from prison or jail. Services would begin a month prior to release “in order to create community linkages and ensure that they receive needed coordination of care, physical and behavioral health services, medication and medication management, and critical social support upon release into the community.”

Arizona’s current 1115 waiver ends on September 30, 2021. If approved, the amendment would run concurrently with the agency’s requested renewal period from October 1, 2021, through September 30, 2026.

The federal comment period for the amendment request runs from June 7 through July 7, 2021. Just two comments have been published thus far, both in support of the amendment.