---
type: source
title: "State Community Health Worker Policies: 2024-2025 Trends — Medicaid Reimbursement Expanding but Scaling Infrastructure Lags"
author: "National Academy for State Health Policy (NASHP)"
url: https://nashp.org/state-community-health-worker-policies-2024-2025-policy-trends/
date: 2025-01-01
domain: health
secondary_domains: []
format: report
status: enrichment
priority: high
triage_tag: entity
tags: [community-health-workers, Medicaid, state-policy, reimbursement, scaling, SDOH]
processed_by: vida
processed_date: 2026-03-18
enrichments_applied: ["SDOH interventions show strong ROI but adoption stalls because Z-code documentation remains below 3 percent and no operational infrastructure connects screening to action.md", "value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk.md"]
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

NASHP policy landscape report on CHW Medicaid reimbursement and certification trends across US states, 2024-2025.

Key findings:
- 20 states have received CMS-approved State Plan Amendments (SPAs) for CHW reimbursement since Minnesota's 2008 approval
- 4 new SPAs approved in this period: Colorado, Georgia, Oklahoma, Washington
- 15 states have approved Section 1115 demonstration waivers supporting CHW services
- 7 states have established dedicated state offices for CHWs (Kansas, Kentucky, Massachusetts, Mississippi, New Mexico, Oklahoma, Texas)
- 6 states enacted new CHW reimbursement legislation: Arkansas, Connecticut, Illinois, Mississippi, New Hampshire, North Dakota

Billing infrastructure:
- SPAs typically use fee-for-service reimbursement through 9896x CPT billing codes (health education focus)
- Innovation: California, Minnesota, Washington adopting Medicare CHI and PIN "G codes"
- Billing code uptake has been slow in many states — entities providing CHW services often cannot bill

Scaling barriers:
- Transportation is largest overhead expense; Medicaid does not cover provider travel
- Community-based organizations (CBOs) lack infrastructure to contract with healthcare entities
- "Community care hubs" emerging to coordinate administrative functions across CBO networks
- COVID-19 funding streams ending, creating funding gaps
- Sustainability requires braiding/blending funds from public health, health care, and social services

Key trend: 7 of 10 most recent Section 1115 waivers focus on pre-release services for incarcerated individuals, recognizing lived experience as a CHW qualification.

## Agent Notes
**Triage:** [ENTITY] — tracks the CHW policy/reimbursement infrastructure across states, critical for understanding why CHW programs with strong evidence (39 RCTs, $2.47 ROI) still haven't scaled
**Why this matters:** The evidence-to-implementation gap is the core mystery of Frontier Gap 1. CHW programs work in RCTs but only 20 states can reimburse them. The billing infrastructure is the bottleneck — identical to the VBC payment boundary problem.
**What surprised me:** Only 20 states have SPAs after 17 years since Minnesota's 2008 approval. The CHW scaling failure parallels the VBC stall — the intervention works but the payment infrastructure doesn't support it. This is the SDOH version of "value-based care transitions stall at the payment boundary."
**KB connections:** [[SDOH interventions show strong ROI but adoption stalls...]], [[value-based care transitions stall at the payment boundary...]]
**Extraction hints:** Claim candidate: "Community health worker programs stall at the reimbursement boundary — only 20 states have Medicaid SPAs despite 17 years of evidence and $2.47 ROI, mirroring the VBC payment transition gap"

## Curator Notes
PRIMARY CONNECTION: SDOH interventions show strong ROI but adoption stalls because Z-code documentation remains below 3 percent and no operational infrastructure connects screening to action
WHY ARCHIVED: Provides the structural/policy explanation for why evidence-backed CHW programs haven't scaled, directly extending the existing SDOH claim with specific infrastructure data


## Key Facts
- 20 states have CMS-approved State Plan Amendments for CHW reimbursement as of 2024-2025
- Minnesota was the first state to receive CHW reimbursement SPA approval in 2008
- 4 new SPAs approved in 2024-2025 period: Colorado, Georgia, Oklahoma, Washington
- 15 states have Section 1115 demonstration waivers supporting CHW services
- 7 states have dedicated CHW offices: Kansas, Kentucky, Massachusetts, Mississippi, New Mexico, Oklahoma, Texas
- 6 states enacted new CHW reimbursement legislation: Arkansas, Connecticut, Illinois, Mississippi, New Hampshire, North Dakota
- CHW SPAs typically use 9896x CPT billing codes for health education services
- California, Minnesota, and Washington are adopting Medicare CHI and PIN 'G codes' as billing innovation
- Transportation is the largest overhead expense for CHW programs
- 7 of 10 most recent Section 1115 waivers focus on pre-release services for incarcerated individuals
