States are pursuing a variety of models to provide critical support for community-based organizations (CBOs) that have not previously participated in the Medicaid program. Supports include capacity-building resources for administrative, billing, reporting, data and IT needs as well as training and technical assistance.
Models range from formalized approaches such as state-established third-party administrators (TPAs), accountable communities of health, and community care hubs, to ground-up approaches where a community-based provider with experience takes on certain administrative and fiscal functions on behalf of other providers. These fiscal and administrative intermediary approaches are one aspect of states’ broader efforts to connect with communities and support community-based organizations. This brief highlights a few examples specific to facilitating whole person care approaches in Medicaid projects.
These examples are drawn from NASHP’s deep work with states on housing support services across Medicaid, housing, and broader health and human services programs. In March 2025, CMS rescinded their previous guidance on health related social needs (HRSN). The rescission indicates that future requests to cover similar services will be considered on a case-by-case basis. While this brief draws from state examples of section 1115 demonstration waivers approved under the rescinded framework, they represent strategies that can support CBOs in a variety of arrangements with states.
State Examples of Medicaid Intermediaries
More formalized models, such as state-designed TPAs, allow the state to lay out expectations and requirements in contracts. They also typically include more expansive functions, including dispersing capacity-building or infrastructure funds, coordinating provider and CBO networks, and infrastructure support to work directly with the community and broader stakeholders. Ground–up models allow providers to direct the process, deciding and negotiating the services they need the most, often focusing on administrative functions only and relying on established processes.
Functions Intermediaries May Offer to States and CBOs
Note: Functions differ by state, community, and model, defined by a combination of state and federal agreements and contracts between intermediaries, CBOs, and state agencies.
- Fiscal services including billing or invoicing on behalf of CBOs
- Reporting to Medicaid and other state agencies on behalf of CBOs
- Access to data and systems infrastructure (such as electronic health records and health information exchanges) for CBOs
- Technical assistance to CBOs on Medicaid provider enrollment, business practices, billing and documentation to meet Medicaid rules, reporting, and other requirements
- Establishing or growing a network of CBOs on behalf of the state
- Distributing capacity-building and infrastructure funding on behalf of the state
- Assistance with directing referrals to services
- Engaging the community, CBOs, and other stakeholders to identify and provide feedback on priorities
- Accountability for certain metrics, oversight of CBOs, and more
North Carolina Healthy Opportunities Pilots Network Leads
Network Leads are regional hubs as part of the Healthy Opportunities Pilots that create, coordinate, and support networks of human service organizations (HSOs). Note: As of early December 2025, Healthy Opportunities Pilots are currently paused while the general assembly debates the 2025 – 2027 biennium budget. An initial version of the budget did not include funding for the work to continue, but negotiations are ongoing.
Within the Healthy Opportunities Pilots, Network Leads serve as local anchors to build the capacity of HSOs to participate in Medicaid, including by distributing capacity-building funds, providing technical assistance, and developing and managing the network of HSOs. They were established as part of North Carolina’s Medicaid section 1115 demonstration waiver and selected through a competitive procurement process. In order to standardize implementation, the state supplied model contracts for Network Leads that allowed consistency and oversight among the growing number of managed care plans across the state.
The Network Leads have gone through several iterations. Originally, the Network Leads were responsible for processing the invoicing from HSOs to the managed care organizations. However, the model has since removed the processing and transmission of invoicing from the Network Leads and built it into the platform used for closed loop referrals (NC Care Connect 360), to simplify the process by having one platform that HSOs can use. Now the Network Lead still validates the invoices, to remain involved in the process, but prioritizes supporting the HSOs and providing technical assistance.
Specific functions of the Network Leads include:
- Developing and managing a network of human service organizations
- Serving as a single point of accountability to bridge between health care and social services systems
- Distributing capacity-building funds and providing technical assistance to build the capacity of human service organizations to participate in Medicaid
- Reviewing invoices from human service organizations for completeness and accuracy and facilitating payment from managed care organizations, including an annual audit
- Conducting quality improvement activities
- Collecting and submitting data to support evaluation and oversight, including assessing performance of human service organizations
- Training and education on using closed-loop referral and invoicing systems
- Advocating for the grassroots community organizing and bringing to focus the needs of the people
Arizona Housing and Health Opportunities (H2O) Third Party Administrators
To facilitate the implementation of Arizona’s Housing and Health Opportunities (H2O) program, Arizona contracts with a single Program Administrator, called the H2O Program Administrator, to simplify administrative burden of participating in the program. The H2O program was authorized through Arizona’s Medicaid Section 1115 Demonstration waiver, and the H2O Program Administrator was selected through a competitive procurement process.
The nonprofit organization Solari was selected through a competitive procurement process to serve as the H2O Program Administrator. Solari brings housing expertise and contracts with Banner Health, a health plan active in Arizona, to bring expertise in claims processing and billing. Housing providers enter information into the Homeless Management Information System (HMIS) to ensure Medicaid-funded services that address social drivers of health outcomes are integrated with other housing services throughout the state. Additionally, Solari invested in the development of a simplified platform that Solari designed using a national contractors framework to assist H2O providers with submitting invoices to be transferred to Medicaid claims. Banner Health then takes that information and completes claims processes and reimbursements to providers. As the H2O Program Administrator, Solari is responsible for developing the determining member eligibility, contracting and training the H2O provider network, and many other administrative tasks imperative to the successful implementation of the program statewide. Solari is also responsible for coordinating with managed care organizations to ensure H2O becomes a supplement service to the established Medicaid system of care within Arizona.
Specific functions of the H2O Program Administrator include:
- Recruiting, onboarding, and training providers and CBOs
- Establishing and verifying member eligibility for services per Medicaid guidelines
- Establishing adequate statewide networks of providers
- Coordinating services between Member’s health plan and care coordination team
- Adhering to Medicaid billing procedures for housing provider services
- Monitoring and addressing member access to housing services
- Tracking and monitoring housing service utilization and limits
- Technical assistance to housing services providers
Massachusetts Medicaid Housing Parent Entities
A number of CBOs in Massachusetts identified the need for assistance with billing and administering Medicaid and selected one of the CBOs with more experience with Medicaid to serve as a parent entity. This arrangement was driven by the CBOs, and the state does not serve a direct role. More recently, the state has hosted webinars about different arrangements providers could pursue, including hubs that involve parent and satellite entities (information beginning on slide 33).
Massachusetts distributes infrastructure funds through their Medicaid Section 1115 Demonstration waiver, and one of the allowable uses is creating a hub. Massachusetts defines a parent entity as centralizing administrative functions and the parent entity may provide support to one or more Satellite Entities related to the following functions. Parent entities charge reasonable administrative rates to satellite entities for the services they provide that are not funded through infrastructure funds.
Specific functions include:
- Submitting claims and data
- Contracting with plans and CBOs
- Supporting provider credentialing and enrollment
- Data collection, aggregation, analysis, and reporting
Medicaid intermediaries represent a key infrastructure strategy to streamline fiscal and administrative partnerships between state programs and community partners to deliver whole person care interventions. State policymakers may consider these approaches as they explore arrangements that balance effectively resourcing community partners to deliver services while ensuring accountability.
For additional information on housing and the Medicaid program, see NASHP’s health and housing resource center or contact Sandra Wilkniss at swilkniss@nashp.org.
Acknowledgments
The NASHP team would like to sincerely thank the state officials from North Carolina, Arizona, and Massachusetts for their review and feedback of this brief. Support for this work was provided by the Robert Wood Johnson Foundation.
