The Maryland Department of Health has issued a request for information for advancing Food is Medicine coverage in Medicaid through an In Lieu of Services (ILOS) model.  If your organization would like to sign onto a letter of support for this initiative, please review the letter below. The letter has been organized by the Maryland Food is Medicine Collaborative.  The letter is for everyone – not just formal members of the Collaborative.  

If your organization would like to sign onto this letter, please fill out this google form by 3pm on October 14th. 

You may have received the sign on letter of support and sign on information from an email as well.   If you have any questions, please contact Robyn Elliott at relliott@policypartners.net.

 

 

October 14, 2026

RE: Request for Information: Proposed In Lieu of Services (ILOS) for Food and Nutrition Interventions under Maryland’s Comprehensive Health Care Program

Dear Maryland Department of Health,

We are writing to thank the Maryland Department of Health (MDH) for issuing a request for information (RFI) on supporting Food is Medicine coverage in Maryland Medicaid through In Lieu of Services (ILOS). Our organizations have reviewed the RFI and would like to provide our collective response in this letter; and some organizations may also provide their own individual responses. This letter was coordinated by the Food is Medicine Access Collaborative (the Collaborative), a working group of community-based Food is Medicine providers, their healthcare partners, and consumer advocates.  The Collaborative’s mission is to advance sustainable Food is Medicine models to address the health needs of Maryland’s communities.  The signatories of this letter are not all formal members of the Collaborative, but we share the same commitment to advancing Food is Medicine in Maryland.

We strongly support establishing Medicaid coverage of Food is Medicine services through ILOS. Under this program, managed care organizations (MCOs) could choose to extend coverage to approved Food is Medicine interventions to their enrollees. The MCOs’ commitment would be incorporated into their annual contracts with MDH. Before launching ILOS, MDH would need approval of specific Food is Medicine interventions from the Center for Medicare & Medicaid Services (CMS).

As defined in MDH’s RFI, Food is Medicine is “an integration of nutrition-based interventions into healthcare to improve health outcomes and reduce healthcare costs by addressing root causes of poor health.”[i]  MDH’s definition aligns with the description of Food is Medicine by the Food is Medicine Coalition as interventions that have “a nexus to the healthcare system.”[ii] Food is Medicine interventions are based in the healthcare system and are different, but complement rather than replace programs that address more general food security needs of communities.[iii]

Food is Medicine interventions can be a cost-effective—and in many cases even cost-saving—approach to treating, managing, and/or preventing severe, complex, and diet-related chronic disease. This is due in large part to their ability to reverse nutritional deficits that lead to poor health outcomes and reduce the downstream need for more intensive healthcare services. For example, a 2022 study projected that if all eligible patients in Medicaid, Medicare, and private insurance received medically tailored meals, the U.S. healthcare system could avert 1.6 million hospitalizations and $13.6 billion in healthcare costs each year, even after accounting for the cost of the programs.[iv]

Food is Medicine (FIM) programs offer a powerful opportunity to improve health while strengthening local economies. As states expand coverage for Food is Medicine interventions for people with diet-related conditions, a new market for healthy food is emerging. States have the opportunity to facilitate local and regional partnerships and build infrastructure that support community-based Food is Medicine interventions at scale and spur statewide investments.  States can direct a portion of the investments to local small and mid-sized farms, create jobs, and keep dollars circulating within communities. At a time when diet-related disease is widespread and family farms face persistent financial strain, Food is Medicine presents a rare chance to address both challenges together. The Rockefeller Foundation recently published a report showing that Medicaid funded food is medicine programs could produce a total of $27,850,000 in revenue for local farmers and create 3,750 jobs.[v]

Our organizations see daily evidence that food and nutrition interventions improve health and wellbeing of the communities we serve. Our experience reflects a growing body of research that demonstrates that we can improve our clients’ health and reduce avoidable healthcare costs by matching the appropriate nutrition intervention to the specific patient population to address their preventive health and clinical needs.  Therefore, we strongly support ILOS as the next step in improving access to food is medicine services in Maryland because:

  • ILOS will advance equitable access to Food is Medicine interventions across Maryland. Maryland Medicaid provides coverage to nearly 1.5 million people across Maryland with the vast majority served by MCOs[vi].  Under ILOS, MCOs must provide coverage of the Food is Medicine interventions, as agreed to in their contracts, to eligible participants. Maryland Medicaid establishes clinical criteria, as approved by CMS, for eligibility for covered services;
  • ILOS will build upon Maryland’s existing investment in Food is Medicine interventions. Beginning in 2026, MDH has invested $13 million from the Population Health Improvement Fund for a medically tailored meals pilot and $10 million for a produce prescription pilot.[vii] This investment will support community-based food is medicine providers and their health care partners to build the infrastructure to support broader access under the Medicaid program; and
  • ILOS supports innovation grounded in evidence-based models. Maryland will be able to shape ILOS based on the outcomes of its pilot programs, other Maryland specific data, and the significant body of peer-reviewed research on Food is Medicine.

 

As MDH considers how to structure Food is Medicine coverage through ILOS, we would like to offer recommendations to consider in implementation:

Recommendation 1:  MDH should review and consider the experiences of other states in expanding Food is Medicine access through ILOS.  At least eight states have covered Food is Medicine interventions through ILOS, according to the Center for Health Law and Policy Innovation. With Michigan as an example of a state with a recently approved ILOS application, MDH may find examining Michigan as particularly informative.  Michigan provides coverage of the following Food is Medicine interventions through ILOS: medically tailored home delivered meals, healthy home delivered meals, healthy food packs, and produce prescriptions.[viii]

Recommendation 2:  MDH should partner with community-based health care providers, including Food is Medicine service providers, in developing and implementing ILOS.  Our provider community has deep knowledge and experience with making Food is Medicine interventions work in Maryland communities. Michigan’s ILOS model and Massachusetts’s 1115 waiver offer some useful information about how Medicaid can support community-based organizations involvement in ILOS. The recently released FIM State Medicaid Toolkit offers practical considerations for implementing FIM through ILOS.

Recommendation 3: MDH should review national standards and definitions for Food is Medicine interventions.  MDH may find the Food is Medicine Coalition,  the Aspen Institute, Rockefeller Foundation, and Center for Health Law and Policy Innovation as a particularly useful resources about information on best practices.

Recommendation 4:  MDH should structure Food is Medicine programs and clinical criteria for ILOS based on evidence from Maryland and clinical evidence more generally. For example, MDH should look to the experience of Maryland Food is Medicine providers, including but not limited to the results from the medically tailored meals and produce prescription pilots. Results could include findings on outcomes and the optimal length of interventions.

Recommendation 5:   MDH should begin ILOS in 2028 to dovetail with the medically tailored meals and produce prescription pilots.  ILOS should begin before the pilot programs end to avoid gaps in access.

Recommendation 6:  MDH should incorporate a robust evaluation component into ILOS, so that that Medicaid, in collaboration with stakeholders, can determine how to make adjustments to ensure ILOS is effective in addressing health outcomes of Marylanders and implementable for the Food is Medicine and healthcare provider community. Massachusetts and North Carolina have completed evaluations that serve as models.

Recommendation 7:  MDH should work with the Food is Medicine and healthcare provider community to ensure that the program structure, reimbursement, and referral systems support the true cost and provision of effective Food is Medicine interventions.

Recommendation 8:  MDH should work with the Food is Medicine and healthcare provider community to identify potential infrastructure needs to successfully launch the ILOS program and available sources of funding that could be utilized to proactively address these gaps.

 

We would like to thank MDH for its partnership in addressing the need for nutritional intervention in Maryland communities. We hope that our comments are helpful in highlighting the importance of ILOS in expanding access to Food is Medicine interventions. Some signatories of this letter will also be submitting individualized comments with information on their experience with Food is Medicine. We appreciate that the RFI offers all of us the opportunity to help MDH move forward with Food is Medicine.

If you have any questions about this letter or need information to reach the signatories, please contact Robyn Elliott at relliott@policypartners.net.

 

[insert name, organization, and email address of signatories]

 

[i] https://health.maryland.gov/AHEAD/docs/Medicaid%20ILOS%20Food%20RFI%202026.pdf

[ii] https://fimcoalition.org/about-fimc/our-model/

[iii] https://www.healthaffairs.org/doi/abs/10.1377/hlthaff.2024.01343

[iv] Hager K, Cudhea FP, Wong JB, et al. Association of National Expansion of Insurance Coverage of Medically Tailored Meals With Estimated Hospitalizations and Health Care Expenditures in the US. JAMA Netw Open. 2022;5(10):e2236898. doi:10.1001/jamanetworkopen.2022.36898. https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2797397

[v] https://www.rockefellerfoundation.org/reports/from-farm-to-fim-the-economic-impact-of-local-food-is-medicine/

[vi][vi][vi][vi] https://health.maryland.gov/mmcp/Documents/April-2026-MMAC-Enrollment-Slide.pdf

[vii] https://health.maryland.gov/newsroom/Pages/Maryland%20Department%20of%20Health%20launches%20Medically%20Tailored%20Meals%20Program%20to%20Improve%20Health%20Outcomes%20and%20Cost%20of%20Care.aspx

https://governor.maryland.gov/news/press-releases/maryland-announces-10-million-funding-increase-access-fresh-produce-high-poverty-commun

[viii] https://www.michigan.gov/mdhhs/-/media/Project/Websites/mdhhs/Assistance-Programs/Medicaid-BPHASA/MIHealthyLife-ILOS/ILOS-Provider-Readiness-Checklist-Final.pdf?rev=8ac4660ea6bb4aeaafca6372e08fe19e&hash=73344359E0DB51631C75E8FF04B219D4