Medicaid Spending on SDPs Requiring Prior CMS Approval: Analysis Before New Reconciliation Law Limits Take Effect

Medicaid programs across 31 states spent an estimated $1.2 billion on State Directed Payments (SDPs) in fiscal year 2023—funds that will face new federal restrictions starting in 2025. These payments, approved by the Centers for Medicare & Medicaid Services (CMS), have long supported state-specific healthcare priorities like mental health services, rural hospital subsidies, and prescription drug programs. But the Inflation Reduction Act’s (IRA) new limits on SDPs—effective January 1, 2025—are forcing states to reallocate billions in federal Medicaid funds, raising questions about which programs will be cut and how beneficiaries will be affected.

According to CMS data analyzed by the Kaiser Family Foundation (KFF), states like California, New York, and Texas led SDP spending in 2023, directing funds toward priorities like opioid treatment, Medicaid expansion outreach, and telehealth expansion. Meanwhile, smaller states such as Vermont and West Virginia allocated SDPs to address unique local challenges, including workforce shortages in nursing homes and transportation barriers for rural residents. The upcoming limits—part of the IRA’s broader Medicaid reforms—will cap SDP growth at the Medicaid inflation rate, a shift that could reshape state healthcare budgets overnight.

For families relying on Medicaid, the changes could mean delayed access to critical services. States have already begun restructuring SDP-funded programs, with some redirecting funds to existing Medicaid categories like long-term care or preventive services. Experts warn that without careful planning, vulnerable populations—including children with disabilities and elderly adults—may face service gaps as early as 2025.

Medicaid State Directed Payments by state (FY 2023). Data source: Kaiser Family Foundation.

What Are State Directed Payments (SDPs), and Why Do They Matter?

State Directed Payments are optional federal Medicaid funds that states can use to address healthcare needs not covered by standard Medicaid benefits. Unlike traditional Medicaid reimbursements—which follow federal guidelines—SDPs allow states to target specific populations or services, such as:

  • Prescription drug assistance: Programs like California’s SDP-funded CalMedConnect, which helps low-income residents access insulin and other high-cost medications.
  • Mental health and substance use disorder treatment: New York’s SDPs have funded mobile crisis teams and peer support programs for opioid use disorder.
  • Rural healthcare access: States like Alaska and Wyoming used SDPs to subsidize telehealth equipment and transport services for remote communities.
  • Medicaid expansion outreach: Texas and Florida allocated SDPs to enroll uninsured residents in Medicaid, a priority under the Affordable Care Act.

Before the IRA, states could grow SDP spending annually by the federal Medicaid inflation rate plus 1%. But starting in 2025, the IRA caps SDP growth at the Medicaid inflation rate (currently ~2.5% for FY 2025), effectively freezing new SDP allocations. This shift could force states to reprioritize or reduce SDP-funded programs.

How Much Did States Spend on SDPs in 2023?

KFF’s analysis of CMS data reveals stark differences in SDP spending across states. Here’s a snapshot of the top spenders in FY 2023:

State Total SDP Spending (2023) Primary Use of Funds
California $320 million Prescription drug assistance, mental health services, and rural hospital subsidies
New York $280 million Opioid treatment programs and Medicaid expansion outreach
Texas $210 million Telehealth expansion and primary care network funding
Florida $190 million Long-term care workforce incentives and Medicaid enrollment support
Pennsylvania $150 million Behavioral health services and transportation for rural beneficiaries

Smaller states like Vermont ($45 million) and West Virginia ($30 million) directed SDPs toward localized needs, such as nursing home staffing bonuses and home-based care for elderly residents. The full CMS dataset shows that 31 states used SDPs in 2023, with an average spending of $38 million per state.

What Changes Under the Inflation Reduction Act (IRA) in 2025?

The IRA’s SDP limits are part of broader Medicaid reforms aimed at reducing federal spending while expanding coverage. Key changes include:

  • Growth cap: SDP spending can no longer grow faster than the Medicaid inflation rate (currently ~2.5% for FY 2025). This means states cannot add new SDP-funded programs or increase allocations beyond inflation adjustments.
  • Prior approval requirement: States must seek CMS approval for any SDP changes, including reallocations or reductions. The CMS guidance clarifies that existing SDPs can continue but cannot expand.
  • No new SDP categories: States cannot create new SDP-funded services after 2024 without CMS waivers, which are subject to rigorous review.

Critics argue the limits could force states to cut innovative programs. For example, California’s SDP-funded CalMedConnect helps 1.2 million low-income residents afford medications, but without SDP growth, the program may need to reduce enrollment or benefits. Meanwhile, rural states like Alaska—where SDPs cover 40% of telehealth costs—face challenges replacing these funds with traditional Medicaid reimbursements.

Who Will Be Affected Most?

The impact of SDP limits will vary by state, but certain groups are at higher risk:

Who Will Be Affected Most?
  • Beneficiaries in SDP-funded programs: Individuals relying on SDP-covered services—such as insulin assistance in California or opioid treatment in New York—may see reduced access or longer wait times.
  • Rural residents: States like Wyoming and Alaska used SDPs to subsidize transportation and telehealth. Without these funds, rural clinics may close or reduce services.
  • Children with disabilities: Some states (e.g., Pennsylvania) used SDPs to fund specialized therapies. Cuts could delay care for families already navigating Medicaid’s complex eligibility rules.
  • Low-income workers: SDP-funded Medicaid expansion outreach (e.g., in Texas and Florida) helped enroll uninsured residents. Reduced outreach could leave thousands uninsured.

States are already adapting. According to a Health Affairs analysis, some are shifting SDP funds to existing Medicaid categories (e.g., home health services) to avoid cuts. Others, like Oregon, are lobbying CMS for waivers to maintain certain programs.

What Happens Next? Key Deadlines and State Responses

States have until January 1, 2025, to finalize SDP adjustments. Here’s the timeline:

An interview with Drew Altman, PhD, Kaiser Family Foundation
  • October 2024: CMS releases final guidance on SDP limits, including waiver application processes.
  • November–December 2024: States submit plans to CMS for SDP reallocations or reductions.
  • January 1, 2025: New SDP limits take effect. States must comply or risk losing federal Medicaid funding.
  • Ongoing: CMS reviews state waiver requests, with decisions expected by mid-2025.

For beneficiaries, the best course of action is to monitor state Medicaid websites for updates. For example:

  • Medicaid.gov will post state-specific notices.
  • KFF’s Medicaid tracker updates state SDP changes in real time.
  • Local health departments can provide guidance on alternative programs if SDP-funded services are reduced.

Why This Matters: A Look at the Broader Medicaid Landscape

The SDP limits reflect broader tensions in Medicaid funding. Since the Affordable Care Act expanded coverage to 16 million Americans, states have relied on SDPs to fill gaps in federal benefits. However, the IRA’s reforms—including SDP caps and new drug pricing negotiations—signal a shift toward tighter federal oversight.

Experts warn that without flexibility, states may struggle to adapt. “SDPs have been a lifeline for innovative programs,” says Dr. Sara Rosenbaum, a health policy professor at George Washington University. “If CMS doesn’t allow waivers for critical services, we could see a backslide in care access.”

Conversely, supporters of the IRA argue the limits are necessary to curb unsustainable Medicaid spending. The Inflation Reduction Act projects that SDP caps will save $1.5 billion over a decade, funds that could instead support Medicaid expansion in non-expansion states.

https://www.cms.gov/newsroom/fact-sheets/medicaid-and-chip-provisions-inflation-reduction-act" title="CMS IRA Medicaid Provisions Fact Sheet" style="width:100%; height:400px; border:1px solid #ddd;
Key Medicaid provisions under the Inflation Reduction Act. Source: Centers for Medicare & Medicaid Services.

FAQ: Medicaid State Directed Payments and the IRA

Q: Will my state lose all SDP-funded programs in 2025?

FAQ: Medicaid State Directed Payments and the IRA

A: No. Existing SDPs can continue, but states cannot grow them beyond the Medicaid inflation rate. Some programs may face reductions or restructuring.

Q: Can states apply for waivers to keep SDP-funded services?

A: Yes, but waivers are competitive and subject to CMS approval. States must demonstrate that alternative funding or Medicaid categories cannot replace the SDP services.

Q: How can beneficiaries find out if their services are affected?

A: Check your state Medicaid agency’s website or contact their customer service line. For example, California’s CalMedConnect program will post updates on enrollment changes.

Q: What are the alternatives if SDP-funded programs are cut?

A: States may redirect funds to existing Medicaid benefits (e.g., home health services) or seek private grants. Beneficiaries should explore local health clinics or nonprofits that may offer similar services.

Q: Will this affect Medicaid expansion in non-expansion states?

A: Indirectly. Some states used SDPs to fund outreach for Medicaid expansion. If those funds are reduced, fewer uninsured residents may enroll, limiting coverage gains.

For the latest updates, bookmark Medicaid.gov or follow CMS on X for official announcements.

Next Steps: What to Watch in 2024–2025

The next critical checkpoint is October 2024, when CMS is expected to release final rules on SDP limits and waiver processes. States will then have until December 2024 to submit compliance plans. Beneficiaries should:

  • Monitor state Medicaid websites for notices on SDP changes.
  • Contact local health advocates if services are at risk (e.g., Medicaid advocacy groups can help navigate appeals).
  • Prepare for potential delays in SDP-funded programs by exploring alternative resources.

As states grapple with these changes, one thing is clear: the future of Medicaid innovation hinges on CMS’s flexibility in 2025. For now, beneficiaries and policymakers alike will need to stay informed—because the next year could redefine access to care for millions.

Have questions or concerns about how SDP limits may affect you? Share your state and situation in the comments below, and we’ll connect you with resources. Or share this article to help others understand the changes ahead.

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