HRSN services in 1115 demonstrations: what CMS approved, what it rescinded in 2025, and how rides are paid
Overview
HRSN stands for health-related social needs, such as housing, food, and the rides needed to reach those services. Some states pay for HRSN services through section 1115 demonstrations. CMS withdrew its HRSN guidance on March 4, 2025, yet the New York and North Carolina approvals still carry their ride terms. Rides to HRSN services are paid through a state network or plan, not through the NEMT broker.
On this page
HRSN stands for health-related social needs: housing, food, and the other conditions of daily life that affect health. Some states pay for services that address them through section 1115 demonstrations, and the services can include rides to the housing appointment, the food pharmacy or the case manager. Those rides run on their own funding and rules, not through NEMT. Screening for transportation needs and the social needs quality measures are in the transportation insecurity guide. Substitute services inside managed care are in in lieu of services.
What CMS approved and what it rescinded
On March 4, 2025 CMS withdrew its HRSN guidance, and the approvals already granted, including New York’s and North Carolina’s, kept their terms. The Center for Medicaid and CHIP Services had published a bulletin and a coverage framework on November 16, 2023. A second bulletin of December 10, 2024 replaced both. The March 2025 bulletin withdrew those two bulletins and said CMS would judge each state’s request under the Social Security Act and its regulations, without reference to the old documents. It is silent on approvals CMS had already granted.
Those approvals continue under their own terms. CMS’s November 24, 2025 letter to New York repeats the rescission “while CMS evaluates policy options,” and its September 25, 2026 letters to New York and North Carolina carry the full special terms of each demonstration, HRSN terms included. All authorities in each demonstration expire at its end date unless renewed or amended: March 31, 2027 for New York and December 9, 2029 for North Carolina.
How New York pays for HRSN rides
New York pays through a Social Care Network, and the ride is a separate benefit from Medicaid transportation. Its demonstration lets the state cover “private and public transportation to transport members to covered HRSN services and case management activities” (special term 6.2(e)). CMS approved the HRSN amendment on January 9, 2024 and the service protocol on December 18, 2024. A rider must be a Medicaid managed care member who screens positive for a social need and meets the protocol’s population and risk criteria for enhanced services or care management.
Money moves in three steps:
- A managed care plan contracts with a Social Care Network, which builds the provider network. The plan and the network use rates the state sets.
- For rides, CMS approved cost-based payment under HCPCS T2025. Each network works within a cap set for its region and chooses its own rates under it.
- The network contracts with nonprofit community organizations first and may turn to a for-profit company only where no nonprofit can take the work. Every driver needs a valid license, and every vehicle needs registration, an inspection record and proof of insurance.
The protocol lists taxi, rideshare, bus and train pass as examples of the rides, and the need must be documented in the member’s care plan. By April 1, 2027 the state must fold HRSN services into the capitation rates it pays managed care plans.
North Carolina’s paused Healthy Opportunities Pilots
North Carolina approved HRSN rides but is not paying for them now. The Healthy Opportunities Pilots cover transportation to pilot services: bus passes and transit vouchers, and account credits for taxi or rideshare where public transit is not available. The approved fee schedule caps reimbursement at $130.78 a month for public transportation and $342.34 a month for private transportation. The terms say pilot rides do not replace the non-emergency medical transportation the state owes under 42 CFR 431.53, and that family, neighbors, friends or community agencies should be used when possible. The private service can also be a ride from a professional vendor, such as a privately operated wheelchair-accessible service. A NEMT company may provide it, but it is paid only for trips that follow the pilot’s rules, which send members to non-medical places such as the grocery store, a job interview or a health education event.
NCDHHS says the General Assembly did not fund the pilots after July 1, 2025, and operations are suspended. The legislature approved $9 million for the 2026-27 state fiscal year to bring services back for a subset of members who meet set eligibility requirements, and the department plans to contact partners directly once the details are final.
Where HRSN rides stay out of NEMT
Oregon draws the line in its administrative rules. In the version of OAR 410-141-3920(2)(c) effective July 1, 2026, the state’s NEMT benefit may not be used for HRSN services. A carrier there cannot bill a trip to an HRSN service as a NEMT trip. New York’s protocol draws the same separation from the other side.
Finding the work in your state
- Open the state’s section 1115 page on Medicaid.gov and search its special terms and conditions for “HRSN” and “transportation.”
- Find who contracts providers, such as the network, health plan or social service agency, and ask for its provider requirements.
- Ask which code and which cap apply, and whether for-profit carriers are accepted.
- Keep these trips off NEMT claims and invoices.
An HRSN ride is booked in HealthRide like any other trip, with GPS-recorded miles, timestamps and a signature, and you can export the trip log to set beside the care plan.
Frequently asked questions
- Did CMS end HRSN services in 2025?
- No. On March 4, 2025 CMS withdrew two bulletins that told states how to cover HRSN services and said it would weigh each state request on its own merits. The bulletin does not address approvals already in place. CMS letters dated September 25, 2026 to New York and North Carolina still carry the HRSN special terms, including the transportation terms.
- Can I bill an HRSN ride to the NEMT broker?
- Generally not. New York's approved protocol says HRSN transportation is not the same as Medicaid transportation and is not tied to it in any way. Oregon's NEMT rule, OAR 410-141-3920(2)(c), bars NEMT for HRSN services altogether. These rides are paid through the network or plan the state set up for them.
- Who can drive HRSN rides in New York?
- Nonprofit community organizations get the first contracts. If none is available, the Social Care Network can choose to contract a for-profit company instead. Whoever drives must hold a valid New York or other state driver license and show the vehicle's registration and inspection, plus proof of insurance and the insurance cards.
- Are North Carolina's Healthy Opportunities rides running?
- No. NCDHHS says the General Assembly did not fund the pilots after July 1, 2025, so services are suspended. The legislature approved $9 million in state funding for the 2026-27 state fiscal year to bring services back for some members, and the state was still deciding how to use it when its page was last updated on August 20, 2026.