This report is one section of State Strategies to Leverage Medicaid Managed Care Contracting for Investments in Health and Housing Alignment. See the full resource guide.
For more information on financing housing-related services, please visit our Medicaid and Housing toolkit.
Data sharing and reporting are critical components of planning, implementing, and evaluating interventions to address housing needs. Sharing data between MCOs and housing entities can assist states with ensuring that they are aware of and effectively coordinating with existing housing resources across the state and are targeting populations that would most benefit from certain housing supports. MCO reporting requirements can help states determine whether MCOs are meeting the obligations of their contract, assess whether the housing investment is producing desired results, and identify potential program improvements.
Leverage CoC Partnerships and HMIS Connections
MCOs that partner with housing entities and share aggregate-level data with their state Medicaid agency can assist the state with identifying populations that would most benefit from targeted housing interventions, identifying existing housing resources across the state, and evaluating efforts to address housing needs. These partnerships among MCOs and housing partners are critical to using a data-informed approach when aligning affordable housing, rental assistance, and supportive services.
A state Medicaid agency may require that MCOs collaborate with key holders of housing-related data, particularly the Continuum of Care for the Homeless (CoC). CoCs govern the Homeless Management Information Systems (HMIS), used to collect client-level data and data on the provision of housing and services by CoC agencies. Several states include provisions in their Medicaid MCO contracts that encourage MCOs to access HMIS data to support planning efforts for homelessness response in their community. For example:
Arizona
Arizona’s Medicaid agency (Arizona Health Care Cost Containment System, or AHCCCS) requires MCOs support this effort by ensuring key program and operational staff participate in the planning and implementation of data-sharing structure and protocols in HMIS in all three Housing and Urban Development (HUD)-recognized Homeless CoCs in the state. Additionally, MCOs must cover any agency or user fees associated with HMIS usage. This provision in particular may be instrumental in facilitating coordination of health and housing-related services if, for instance, MCOs pay for the HMIS license fee for local behavioral health providers (p. 109 of ACC contract).
California
California’s Medicaid agency encourages MCOs to build partnerships and connect to HMIS data to support planning efforts through the housing and homelessness incentive program (HHIP). Although MCOs are not directly required to access HMIS, they are required to provide an aggregate landscape analysis “utilizing relevant data from the HMIS, point-in-time (PIT) homelessness counts, and other local needs assessments” in HHIP. In this guidance, the state clarifies that an MCO that “does not have the current data capabilities … must provide an estimate based on PIT counts and describe what they need to achieve the connectivity to HMIS or other local data sources to report this information in the future” (p. 4 of All Plan Letter).
Utilize Data Sources to Identify Target Populations
State Medicaid agencies can also leverage contracts to require that MCOs use specific methods to identify target populations that would most benefit from services (such as case management or a targeted housing intervention) and determine if an enrollee meets criteria for certain initiatives. For instance:
Tennessee
Under Tennessee’s Population Health Program, MCOs must evaluate their entire enrolled population and identify enrollees for specific cohorts according to risk, rather than disease-specific categories. To do this, MCOs must “utilize a combination of predictive modeling utilizing claims data, CSMD [Controlled Substance Monitoring Database] data, pharmacy data, and laboratory results, supplemented by referrals, UM [utilization management] data, and/or health risk assessment results to stratify the member population into cohorts.” Social needs data such as housing status must be incorporated into enrollee risk stratification, and MCOs must re-stratify the enrollee population on at least a quarterly basis (p. 121 of MCO Statewide Contract).
Hawaii
Hawai‘i’s Community Integrated Services (CIS) program for beneficiaries who are unhoused or at-risk of homelessness, and with chronic or complex health needs, requires MCOs to use multiple methods to identify targeted populations that would most benefit from the initiative. The CIS program aims to coordinate enrollee health care services and social supports, as well as establish connections to primary care, behavioral health and substance use services, specialists, hospitals, homeless service agencies, and other community resources. The contract specifies several data sources that health plans must consider in their analytic methodology to identify target populations that would most benefit from participating in the CIS program. The contract sets the expectation that health plans identify and gain access to data on enrollees shared across Hawai’i’s Department of Health and Behavioral Health agencies and other state partners. These sources include:
- Claims data and history
- Case conferences
- Real-time data from hospital notifications, pharmacy utilization data, and other sources to identify MCO enrollees who are accessing services but are not engaged in primary care
- Health screening, assessment tools, and enrollee surveys
- Social risk factor (SRF) tools that are approved by the Department of Human Services. SRFs refer to an enrollee’s social and economic barriers to health, such as housing instability or food insecurity.
- The Homeless Management Information System for Hawaii
(p. 19 of Health Plan Manual; CIS Implementation Updated Guidelines)
Leverage Reporting for Program Evaluation
State Medicaid programs can use reporting requirements to ensure that MCOs are submitting information and data that allow the state to assess contract compliance and the impact of housing-related requirements. Oregon and Arizona offer examples of how states approach MCO reporting and use MCO reports to advance housing-related goals.
As discussed in more detail under “Paying MCOs to Address Housing Challenges,” Oregon offers its CCOs financial incentives to provide housing-related services as health-related services (HRS). To administer this policy and promote transparency, MCOs are required to submit semi-annual reports (L.621 and L.622) detailing their spending on HRS. Required information includes a description of each service, type of HRS (e.g., housing support services), dollars spent, and measurable outcomes for services. MCOs are also required to report the Medicaid ID number of all MCO enrollees who received more than $200 of HRS. Oregon has established a review process to ensure all HRS meet Oregon’s definition of an HRS and consistent coding of HRS across MCOs. Once the review process is completed, Oregon analyzes the data to produce:
- Briefs detailing spending and services provided
- Calculate the medical loss ratio and performance-based reward incentives (see “MCO Payment” section)
Analysis of the 2022 data found the following:
- Housing was the second highest HRS spending category in 2022 when MCOs spent a total $10,553,949 on housing.
- The majority of HRS spending on housing was for temporary housing ($3,950,443), houselessness supports and supplies ($2,540,125), and rental assistance ($2,066,331).
Arizona
Arizona requires MCOs operating under its AHCCCS Complete Care (ACC) Contract to provide permanent supportive housing coordination to eligible MCO enrollees, including “assessment of, coordination with, and supports to, assist members in attaining and maintaining housing as part of their independent living goals and service planning” (p. 108). As part of this coordination, MCOs are required to enter into an agreement with the AHCCCS housing administrator. The housing administrator operates the AHCCCS housing program, which uses state funding to pay for housing for eligible enrollees, who are primarily those with a severe mental illness diagnosis who meet additional eligibility criteria. The roles of each of the contractors and how they should work together to provide housing to eligible enrollees is detailed in a separate policy document, which is regularly updated.
AHCCCS requires each MCO to submit a quarterly supportive housing report, which the agency can use to assess whether MCOs are meeting the performance requirements described above, and support program evaluation. This report includes information about all enrollees who were referred for or requested housing assistance, including those who were referred to a housing program other than that offered by the housing administrator and those who did not qualify for permanent supportive housing coordination. The report includes:
- Information about referrals and their results (if known)
- Information needed to understand whether listed enrollees qualified for permanent supportive housing, including whether the individual was on the MCO’s high-cost needs roster and had a severe mental illness diagnosis, as well as each enrollee’s current housing situation
- Whether the enrollee received any housing navigation or supportive services
- Both the Medicaid and HMIS identification number, which enable the agency to find more information about the enrollee’s medical and housing needs, as well as enrollee health outcomes
Utilize Z Codes
Some states use ICD-10 Z codes, diagnosis codes that enable providers to specify the type of SDOH they identified, in planning and evaluation. However, underutilization of Z codes in practice remains a challenge. Robust uptake will require bidirectional engagement among providers and the state to capitalize on this option. To address this challenge, some states have leveraged their contractual relationships to require MCOs to ensure that providers use Z codes, require that MCOs reimburse providers who submit Z codes, and require that MCOs educate providers on Z codes to promote their use. For example, in Arizona, MCOs must “monitor, promote, and educate providers on the use of SDOH ICD-10 codes. These codes shall be included on claims to support data collection on the HRSN experienced by AHCCCS members” (p. 47 of ACC Contract).
Acknowledgements
The authors would like to thank Robin Wagner, Elaine Chhean, and all the state officials who reviewed this brief for their thoughtful feedback. This resource is supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS) under the National Organizations of State and Local Officials as part of a three-year award totaling $2,632,044 with 0% financed with non-governmental sources. The information, content, and conclusions are those of the author(s) and do not necessarily represent the official views of, nor an endorsement, by HRSA, HHS, or the U.S. Government. For more information, please visit HRSA.gov.
