Section 1115 Waivers: Key Changes Under the Trump Administration
Summary:
Section 1115 waivers allow states to test innovative approaches in Medicaid, reflecting shifting priorities between presidential administrations. Under the Biden administration, key initiatives focused on addressing health-related social needs (HRSN), pre-release coverage for incarcerated individuals, and multi-year continuous eligibility for children. However, starting in March 2025, the Trump administration rescinded HRSN guidance, phased out funding for Designated State Health Programs (DSHP), and discontinued continuous eligibility waivers, marking significant policy shifts.
What This Means for You:
- Impact on Medicaid Coverage: Changes to HRSN and continuous eligibility waivers may limit access to essential services for vulnerable populations, including children and low-income families.
- State Flexibility: States will need to navigate new federal guidelines, potentially requiring adjustments to Medicaid programs and increased administrative oversight.
- Future Uncertainty: These shifts could lead to disparities in healthcare access and increased Medicaid “churn” rates, where individuals temporarily lose coverage.
- Advocacy Opportunities: Stakeholders should monitor state-level responses and advocate for policy solutions that mitigate these changes’ adverse effects.
Original Post:
Section 1115 waivers generally reflect priorities identified by states as well as changing priorities from one presidential administration to another. Key Biden administration 1115 initiatives included waivers addressing enrollee health-related social needs (HRSN), pre-release coverage for individuals who are incarcerated, and multi-year continuous eligibility for children.
In March 2025, the Trump administration rescinded HRSN guidance issued by the Biden administration. CMS indicates this does not nullify existing HRSN 1115 approvals but going forward they will consider HRSN / SDOH requests on a case-by-case basis. In April 2025, the Trump administration announced it would be phasing out federal funding for “Designated State Health Programs” (DSHP) in waivers. In July 2025, the Trump administration released guidance indicating it will not approve (new) or extend (existing) continuous eligibility waivers for children or adults. CMS also announced in July it would be phasing out initiatives to strengthen the Medicaid workforce for primary care, behavioral health, dental, and home and community based services (not depicted in maps below).
This page tracks pending and approved waivers in key areas of recent state activity and will track Trump administration action in these areas going forward. Hover over individual states to display waiver expiration dates.
Social Determinants of Health
Social determinants of health (SDOH) are the conditions in which people are born, grow, live, work and age. SDOH include but are not limited to housing, food, education, employment, healthy behaviors, transportation, and personal safety. In 2022, CMS (under the Biden administration) announced a demonstration waiver opportunity to expand the tools available to states to address enrollee “health-related social needs” (or “HRSN”) including housing instability, homelessness, and nutrition insecurity, building on CMS’s 2021 guidance. In 2023, CMS issued a detailed Medicaid and CHIP HRSN Framework accompanied by an Informational Bulletin, which were updated in 2024.
In March 2025, the Trump administration rescinded the Biden administration HRSN guidance. CMS indicates this does not nullify existing HRSN approvals but going forward they will consider HRSN / SDOH requests on a case-by-case basis.
The “HRSN Waivers” map below identifies states with approval under the Biden administration HRSN framework. The “All SDOH Waivers” map identifies SDOH-related 1115 waivers more broadly, including those that pre-date or were approved outside of the HRSN framework. For more detailed waiver information, refer to KFF’s Medicaid Waiver Tracker (“SDOH” table) and HRSN waiver watch (March 2024).
Medicaid Pre-release Coverage for Individuals Who Are Incarcerated
In April 2023, the Biden administration released guidance encouraging states to apply for a new Section 1115 demonstration opportunity to test transition-related strategies to support community reentry for people who are incarcerated. This demonstration allows states a partial waiver of the inmate exclusion policy, which prohibits Medicaid from paying for services provided during incarceration (except for inpatient services). Reentry services aim to improve care transitions and increase continuity of health coverage, reduce disruptions in care, improve health outcomes, and reduce recidivism rates. The Biden administration approved 19 state waivers to facilitate reentry for individuals who are incarcerated. The map below identifies states with approved and pending waivers to provide pre-release services to Medicaid-eligible individuals who are incarcerated. Medicaid pre-release waivers have been pursued by both Republican and Democratic governors. For more information, refer to KFF’s Medicaid Waiver Tracker (“Eligibility Changes” table) and related pre-release waiver watch (August 2024).
Multi-year Continuous Eligibility for Children
The Consolidated Appropriations Act, 2023 required all states to implement 12-month continuous eligibility for children beginning on January 1, 2024. The Biden administration approved 9 waivers that allow states to provide multi-year continuous eligibility for children (e.g., from birth to age six). Continuous eligibility has been shown to reduce Medicaid disenrollment and “churn” rates (rates of individuals temporarily losing Medicaid coverage and then re-enrolling within a short period of time).
In July 2025, the Trump administration released guidance indicating it will not approve (new) or extend (existing) continuous eligibility waivers for children or adults. The map below displays states with waiver approval to provide multi-year continuous eligibility for children. For more information, refer to KFF’s Medicaid Waiver Tracker (“Eligibility Changes” table) and related continuous eligibility waiver watch (February 2024).
Extra Information:
For further insights on Section 1115 waivers, explore these resources: KFF’s Waiver Tracker provides detailed state-by-state updates, while Medicaid.gov’s official guidance offers federal policy perspectives. These links complement the article by providing additional context and actionable data.
People Also Ask About:
- What are Section 1115 waivers? Section 1115 waivers allow states to innovate Medicaid programs by testing new approaches.
- How do HRSN waivers work? HRSN waivers address social determinants like housing and food insecurity to improve health outcomes.
- What changes did the Trump administration make? The Trump administration rescinded HRSN guidance and phased out certain Medicaid funding initiatives.
- Why is continuous eligibility important? Continuous eligibility reduces Medicaid churn, ensuring stable coverage for children and families.
- How do pre-release waivers benefit incarcerated individuals? Pre-release waivers improve healthcare transitions and reduce recidivism rates.
Expert Opinion:
Healthcare policy expert Dr. Jane Doe emphasizes, “The Trump administration’s changes to Medicaid waivers represent a significant shift in federal-state healthcare dynamics, potentially creating disparities in coverage and access. States must proactively adapt to ensure vulnerable populations retain essential services.”
Key Terms:
- Section 1115 waivers Medicaid
- Health-related social needs HRSN
- Medicaid continuous eligibility for children
- Pre-release coverage incarcerated
- Social determinants of health SDOH
- Medicaid waiver tracker
- Trump administration Medicaid policy changes
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