Beyond the Waiver: How Correctional Healthcare Partners is Helping Build a Sustainable Correctional Healthcare Model
CHP’s approach combines healthcare delivery with operational and compliance support. | Photo Credit: Courtesy of CHP
By Lindsey Coulter
The implementation of Medicaid 1115 waiver programs represents more than a new reimbursement opportunity. It also requires facilities to connect correctional healthcare operations with community-based providers, Medicaid systems, county agencies and new (and sometimes complicated) administrative processes.
In California, the CalAIM Justice-Involved Reentry Initiative is one example of how that shift is playing out. It allows certain Medi-Cal services to begin up to 90 days before an eligible individual’s release, bridging care in custody and the community. California was the first of 18 states with federally approved Section 1115 reentry demonstrations. As of Feb. 1, all 31 state prisons and 33 county jail and youth facilities across 13 counties were live, according to the California Department of Health Care Services. Every remaining county correctional facility must go live by Oct. 1. For correctional healthcare providers, that means adapting clinical workflows while also addressing documentation, billing, eligibility, care coordination and information sharing.
Correctional Healthcare Partners (CHP) helps counties manage those overlapping responsibilities. CHP delivers medical and mental health services across 20 county correctional facilities in California and Washington. The company’s approach combines healthcare delivery with operational and compliance support, while allowing counties to determine how responsibilities are divided among correctional agencies, behavioral health departments, community providers and other partners.
For Anthony Sommer, CHP’s Controller, that partnership is particularly important as jurisdictions work through an evolving program.
“Ensuring trust with all our customers, facilities and everybody that we work with is important,” Sommer said.
For correctional leaders, successful 1115 waiver implementation crosses organizational boundaries and requires multiple systems to work together.
The Operational Challenge
Reentry clinical services are only one implementation challenge. CHP’s CalAIM framework addresses health screenings and assessments, medication management, medication-assisted treatment, clinical consultations, care coordination, reentry planning and connections to community providers. It also covers the infrastructure needed to document and bill those services. This differs from traditional correctional healthcare, historically focused on care inside the facility.
“CalAIM requires us to build a true Medi- Cal revenue cycle into correctional healthcare by connecting eligibility, clinical documentation, coding, claims and reimbursement in an environment that historically focused primarily on care delivery,” Sommer said. “Our job is to make that process repeatable, compliant and transparent for our county partners.”
Counties must develop clinical and financial readiness together. Even organizations capable of providing a service may face problems if eligibility, documentation, coding, authorization or claims processes are misaligned.
CHP uses existing electronic health records (EHR) systems, county technology and, where appropriate, third-party administrators (TPAs) to connect clinical encounters with claims processes. CHP staff document encounters using applicable coding requirements and work with TPAs and county partners to support claims submission and reimbursement.
Coordination Drives Reentry Success
An individual’s transition can involve numerous organizations, including correctional health providers, county health and human services agencies, behavioral health departments, county reentry or pre-release teams, managed care plans, Enhanced Care Management providers and community organizations. This makes clear lines of responsibility essential.
Edwin Quezadas, CHP’s Compliance Manager, said questions about how responsibilities are divided among non-custody partners are among the most common he hears.
“There are a lot of partners that are non-custody that are also a part of this program, including behavioral health. Another question is how we address linkage to the community and how we work with already established medical groups and managed care organizations,” Quezadas said.
The county’s role remains central. CHP’s framework defines county responsibilities while establishing the company’s role as a clinical and operational partner. County-designated personnel may handle eligibility and portal functions, with CHP supplying supporting clinical information. Counties also may retain primary responsibility for behavioral health or reentry planning, with CHP contributing clinical information and coordination.
For justice leaders, establishing those boundaries early can prevent duplication, responsibility gaps and disputes over ownership.
Build the System Around the Handoff
A successful transition requires more than a discharge date and referrals. CHP’s model incorporates clinical information into reentry planning, meetings with community providers and, for complex cases, multi-organization case conferences. This ensures receiving providers have the individual’s medical history, treatment information, health risk assessments and other relevant information.
That work also has a practical component. Medication continuity, durable medical equipment and other needs must be addressed before an individual leaves custody. CHP’s framework includes release medications, medication-assisted treatment, naloxone and DME as components of discharge planning.
The broader lesson for correctional leaders is to treat the release process as an operational workflow rather than a single event.
Compliance as Part of the Operating Model
Counties considering or expanding a 1115 waiver program cannot treat compliance as a post-service review. Documentation, coding, eligibility, authorization and claims processes need to be incorporated into everyday clinical operations.
CHP’s CalAIM framework calls for timely documentation, staff training, monitoring of billing activity, participation in audits and corrective-action processes, and secure retention of clinical and billing records. The company also identifies a compliance lead responsible for monitoring changes in state guidance and initiating policy updates.
A Partnership Model for an Evolving System
CHP’s experience with CalAIM illustrates a broader shift in correctional healthcare: providers are increasingly expected to contribute not only clinical expertise, but also operational knowledge, compliance infrastructure, revenue cycle management and connections to community care.
“We decided to build this capability because the market has changed,” said Dr. Peter Freedland, CHP’s Chief Executive Officer. “Counties no longer need a company that only delivers healthcare inside the facility. They need an operating partner that connects that care to everything CalAIM requires around it. We saw a clear gap in the market and chose to build the full system needed to make CalAIM work.”
Meanwhile, CHP supports embedded, in-reach or mixed delivery models based on each county’s program. “At the end of the day, the county owns this project, so how do we deliver this without overstepping?” Quezadas said. “That is where partnership becomes our biggest tool.”
For correctional healthcare providers such as CHP, the role is connecting care delivery to the administrative, financial, technology, compliance and reentry infrastructure required to help counties maintain clinical continuity and fiscal accountability as CalAIM evolves.
This article was sponsored by Correctional Healthcare Partners and originally published in the 2026 Healthcare edition of Correctional News. To learn more, visit www.chphealth.com.