On May 16, 2025, the Florida Agency for Health Care Administration (AHCA) submitted a five-year Medicaid Section 1115(a) demonstration proposal to the Centers for Medicare & Medicaid Services (CMS) titled "Florida Health Care Workforce Sustainability." Backed by nearly $1.4 billion in state general revenue over five years, with additional federal matching funds requested, the proposal seeks to strengthen the state’s health care workforce, particularly in medically underserved areas and Medicaid-participating settings.

Overview and Core Components

The proposal outlines four key initiatives to address longstanding workforce shortages and improve access to Medicaid services:

1. Training, Education, and Clinicals in Health (TEACH): Offers per-hour reimbursement to eligible Medicaid-enrolled facilities (federally qualified health centers, rural health clinics, community mental health centers, and certified community behavioral health clinics) for hosting clinical rotations. The initiative also covers preceptor training and administrative support.
2. Florida Reimbursement Assistance for Medical Education (FRAME): Provides loan repayment ranging from $45,000 to $150,000 over four years for physicians, nurses, physician assistants, and behavioral health professionals who commit to working in Medicaid-participating facilities located in health professional shortage areas or medically underserved areas.
3. Dental Student Loan Repayment Program: Provides up to $50,000 annually for dentists and $7,500 for dental hygienists serving Medicaid patients and volunteering in designated shortage areas, consistent with §381.4019, F.S..
4. Florida FIRST (Nursing Indirect Medical Education): Allocates semiannual payments to eligible public teaching hospitals to support nursing education, based on Medicaid inpatient volume and hospital teaching status.

These initiatives, authorized by Florida’s 2024 Live Healthy legislative package (SB 7016 and HB 5003), are designed to expand the pipeline, distribution, and retention of qualified health professionals who serve Medicaid populations.

Policy Context: Federal Pressure to Expand Pediatric Home Care

The demonstration proposal also responds to a federal court injunction stemming from a U.S. Department of Justice (DOJ) enforcement action. A federal court found that Florida violated the Americans with Disabilities Act (ADA) by unnecessarily institutionalizing children with complex medical needs in nursing facilities. The state was ordered to incrementally transition these children into home- and community-based settings and to ensure all authorized in-home nursing hours are fully staffed.

One of the greatest barriers to compliance has been the lack of a pediatric-trained home care workforce. The demonstration — if implemented with this population in mind — could help address this crisis by increasing the availability of qualified nurses and caregivers through expanded training opportunities and targeted incentives.

Why This Matters for Home Health Providers

This waiver goes beyond workforce development — it has the potential to directly affect the availability of qualified providers for home- and community-based services (HCBS), especially for pediatric patients. For home health agencies, particularly those serving children under Medicaid’s private duty nursing benefit or home- and community-based waivers, key implications include:

• Increased access to pediatric-trained nurses and aides
• Greater workforce stability due to loan repayment and retention incentives
• Improved continuity of care and decreased reliance on institutional settings

However, meaningful impact on the home care sector will depend on implementation. Without explicitly including home health agencies in the TEACH initiative or promoting FRAME participation among providers entering home-based roles, the demonstration could fall short of reaching this vital segment.

Make Your Voice Heard: Submit Feedback on the Proposal

HCAF will be submitting formal comments to CMS on behalf of our members to advocate for the inclusion and prioritization of home-based care providers. To inform our association’s comment submission, we welcome your feedback on the proposal. Please email your thoughts, concerns, and recommendations to Kyle Simon, Senior Director of Policy, Advocacy & Communications, at ksimon@homecarefla.org by Monday, June 23. Your input will help ensure that HCAF’s comments reflect the needs and priorities of providers across the state.

We also strongly encourage providers to submit individual comments to CMS, particularly to highlight specific workforce challenges and solutions from your agency’s perspective. This is a critical opportunity to influence how the waiver is implemented and ensure that HCBS are recognized as essential components of Florida’s health care workforce strategy.

Submit your comment by 11:59 PM ET on Tuesday, July 2, 2025, via the Medicaid Public Comment Portal.