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SRLJC hears limits, timeline delays and billing uncertainty on Washington’s 1115 reentry waiver

2795334 · March 27, 2025
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Summary

Project manager Eric Green told the SRLJC that Washington’s Medicaid 1115 reentry waiver offers a limited set of benefits for people in custody but implementation is delayed by unclear billing rules, provider enrollment questions and gaps in juvenile electronic health records.

Eric Green, the project manager for the 1115 reentry waiver project, told the Spokane Regional Law & Justice Council on the council’s recent meeting that Washington’s Health Care Authority reentry initiative provides a limited package of Medicaid benefits for people while incarcerated and in the weeks before and after release.

"The reentry initiative is basically a Medicaid waiver that allows for a set of limited benefits for inmates," Eric Green said, summarizing the program’s intent. Under the waiver, Green said, incarcerated people who are found eligible or enrolled in Medicaid move to a suspended status while jailed and may receive up to 90 days of pre-release services and an initial 30‑day supply of medications at release. Optional services can include prerelease medications, labs and radiology.

Green told the council the state initially placed Spokane County in cohort 1 with a July 1 go‑live but later clarified the cohort timing was intended for facilities that already have Medicaid billing capability. Green said the state recommended that counties without that capability consider a cohort 2 start around January 2026. He added the state has issued pieces of guidance incrementally: billing codes were released in late February and the policy and operations guide has been released only in sections so far.

Why it matters: Spokane County and other local jails are still working out who will enroll as a Medicaid provider, how claims will be submitted, and how prerelease medications will be dispensed — all prerequisites to billing and recovering any Medicaid revenue tied to the waiver. Green cautioned that the limited set of reimbursable benefits and the administrative costs of standing up billing may mean the program will not be revenue‑positive for a county jail without significant operational changes.

Among technical barriers Green cited were provider enrollment rules, lack of a billing clearinghouse until the state stands up a contract, and the fact that most correctional facilities use bulk medication procurement rather than point‑of‑sale prescriptions. "Medications that release have been directed to be in hand," Green said, but he noted that changing release dates and on‑the‑spot releases make handing someone a 30‑day supply of medication logistically difficult.

Green also described a separate complication for juvenile detention: the county juvenile facility does not currently have an electronic health record system that meets the state requirements; the state plans to provide one but it is not expected to be live until next year, creating a gap for any near‑term go‑live.

Council members raised cost and eligibility concerns. A sentencing judge said that many people who pass through county custody either go to state prison or are time served, and asked how many people would have known release dates that make them eligible under the known‑release pathway. Green replied the initial data are incomplete and that eligible counts could be very small in some months — "as low as single digits" — while start‑up billing costs could run into the hundreds of thousands of dollars.

Council co‑chair Mike (identified in the meeting only by first name) said the county renegotiated the jail medical contract with NavCare and that the vendor has since included contract language committing to stand up a billing mechanism and to work with county staff on implementation. Mike said NavCare has experience in California but was reluctant early in negotiations because Washington’s guidance was slow to arrive.

The council did not take a vote on policy; members asked staff to continue implementation planning and to report back as the state issues further guidance and the county’s vendor proposals firm up.

Ending: Green recommended continued planning while awaiting the state’s full policy and operations guide and the anticipated clearinghouse contract. Council members said they will monitor cohort rollouts elsewhere and the state’s additional guidance before committing to a local go‑live date.