Last week, the Center on Budget and Policy Priorities, Georgetown CCF and 15 other national and state groups submitted comments to the federal Centers for Medicare and Medicaid Services outlining concerns with proposed changes to the state’s Section 1115 Medicaid waiver which authorizes the state’s Medicaid expansion – known as the “private option.”

We expressed concerns about some of the state’s plan provisions – including the request to charge premiums (through the establishment of “Independence Accounts” which require monthly contributions) that will deter enrollment of eligible beneficiaries or require them to pay unaffordable copays.

Note to waiver watchers – this construct is similar to Indiana’s HIP 2.0 proposal that is currently pending with the feds.

We also expressed concern about the state’s desire to waive the non-emergency transportation benefit.  There will be more information about this topic in a forthcoming blog regarding Iowa’s request to extend its one-year waiver of this benefit.  CCF is submitting comments on that proposal as well.

On a positive note, it is good news that CMS (and the state of Arkansas before submitting the request) voluntarily took comments on this amendment since federal regulations do not require them to do so in the case of a waiver amendment. As I have opined before – we should fix this gap in transparency and require a comment period so that stakeholders will have the opportunity to weigh in with both the state and federal governments when important changes are up for consideration.