Section 1115 Medicaid Waiver Comments

(Last updated: May 17, 2024)

Federal law and regulations set guidelines for how states operate their Medicaid and CHIP programs. States, though, can request that the Secretary of Health and Human Services waive certain laws or regulations in order to demonstrate new methods for providing coverage, cover populations not ordinarily covered, or make other changes to Medicaid and CHIP. Waivers have become an important source of variation in Medicaid and CHIP programs across states and impact the way that many children and families receive care.

Alabama

October 21, 2018 letter to HHS on Alabama’s proposal for the “Medicaid Workforce Initiative” Medicaid demonstration project
October 18, 2018 letter to HHS on section 1115 Medicaid demonstration, titled the “Medicaid Workforce Initiative,” submitted by the state of Alabama
July 16, 2014 letter to CMS on the Alabama Proposal for Section 1115 Medicaid Demonstration Project

Arizona

December 19, 2023 comments on Arizona’s proposed amendment to its Arizona Health Care Cost Containment System (AHCCCS) Section 1115 Demonstration.
February 3, 2021 comments on Arizona’s request to extend the AHCCCS section 1115 demonstration project
May 22, 2018 comments to HHS on Arizona’s request to amend the Arizona Health Care Cost Containment section 1115 Demonstration Project
February 5, 2018 comments to CMS on Arizona’s December 19, 2017 request for an amendment to the AHCCCS section 1115 demonstration project that would allow Arizona to implement the AHCCCS Works program
December 4, 2015 comments to CMS on Arizona’s proposed new Section 1115 Medicaid demonstration, the AHCCCS CARE program.
November 23, 2015 comments to CMS on Arizona’s proposed amendment to its demonstration to extend its expenditure authority for its Phoenix Children’s Hospital (PCH) Safety Net Care Pool (SNCP)
February 14, 2011 letter expresses concern to HHS about a Section 1115 demonstration proposal that was submitted by Arizona to waive the maintenance of effort requirement

Arkansas

March 27, 2024 comments to HHS on Arkansas’ proposed section 1115 demonstration project, Opportunities to Test Transition-Related Strategies to Support Community Reentry from Incarceration and Institutions for Mental Disease
July 14, 2023 comments to HHS on Arkansas’ proposed amendment to the Arkansas Health and Opportunity for Me (ARHOME) Section 1115 Demonstration
October 22, 2021 comments to HHS on Arkansas’ proposed section 1115 demonstration project, Arkansas Health and Opportunity for Me (“ARHOME”)
November 21, 2018 comments to HHS on loss of coverage resulting from Arkansas’ section 1115 waiver
August 10, 2017 comments to CMS in response to the amendments Arkansas is proposing to its section 1115 demonstration project, known as Arkansas Works
July 21, 2016 comments to CMS in response to Arkansas’s to extend and amend their Section 1115 Medicaid demonstration waiver, Arkansas Works
October 17, 2014 comments to CMS on the amendment to the Arkansas Health Care Independence Program demonstration project
September 6, 2013 letter to CMS on the Arkansas Health Care Independence Program (“Private Option”) Demonstration proposal
September 6, 2013 comments to CMS on the Arkansas Health Care Independence Program (“Private Option”) Demonstration proposal

California

October 21, 2011 letter asks HHS to reject aspects of California’s demonstration waiver proposal that threaten to reduce coverage

Colorado

September 27, 2024 letter to HHS on Colorado’s proposed amendment to its “Expanding the Substance Use Disorder Continuum of Care” section 1115 demonstration.
May 16, 2024 letter to HHS on Colorado’s proposed amendment to its “Expanding the Substance Use Disorder Continuum of Care” section 1115 demonstration.

Connecticut

May 13, 2024 comments to HHS on Connecticut’s proposed amendment, “Connecticut Medicaid Coverage for Justice-Involved Population Re-entry,” to its current Substance Use Demonstration
May 13, 2022 comments to HHS on Connecticut’s proposed “Covered Connecticut” section 1115 demonstration

District of Columbia

July 23, 2024 comments to HHS on DC’s Demonstration Renewal Request

Florida

April 26, 2024 comments to HHS on Florida’s request to implement a section 1115 waiver to increase eligibility for the Children’s Health Insurance Program (CHIP)
October 19, 2021 comments to HHS on Florida’s request to amend its Managed Medical Assistance (MMA) Program section 1115 demonstration
September 11, 2020 letter to HHS on Florida’s request to extend the Managed Medical Assistance (MMA) Program section 1115 demonstration
June 5, 2018 letter to HHS address concerns over Florida proposal to eliminate retroactive coverage for all non-pregnant adults

Georgia

January 7, 2022 comments to HHS to rescind the approval of the Georgia Access Model component of Georgia’s 1332 waiver
January 22, 2021 comments on Georgia’s amendment to its section 1115 demonstration to extend postpartum coverage
February 7, 2020 sign-on letter to HHS on Georgia’s “Pathways to Coverage” Section 1115 demonstration application. Read CCF’s comments.

Hawai’i

March 1, 2024 comments to HHS on Hawai’i’s “QUEST Integration” 1115 Demonstration Extension and Amendment.

Idaho

November 1, 2019 letter to HHS to comment on Idaho’s proposed section 1115 demonstration project, known as the Idaho Medicaid Reform Waiver

Illinois

July 27, 2023 letter to HHS on the proposed extension of Illinois’ Behavioral Health Transformation Section 1115 demonstration, renamed the Healthcare Transformation Section 1115 Demonstration.
February 12, 2020 letter to HHS on Illinois Continuity of Care and Administrative Simplification Section 1115 demonstration proposal. Read the sign-on letter.

Indiana

December 9, 2020 letter to HHS on Indiana’s application for Maternal Opioid Misuse Indiana Initiative (MOMII) Section 1115 waiver
March 20, 2020 letter to HHS on Indiana’s proposal for a ten-year extension of its section 1115 demonstration project
September 6, 2019 letter to HHS on Indiana’s request to amend its section 1115 demonstration project
July 6, 2017 letter to CMS in response to Indiana’s request to amend its proposal to extend the Healthy Indiana Plan (HIP) 2.0 demonstration project
March 17, 2017 letter to CMS in response to Indiana’s request to extend the Healthy Indiana Plan (HIP) 2.0 demonstration project
September 8, 2016 comments to CMS in response to Indiana’s proposed Section 1115 Medicaid demonstration waiver amendment, Healthy Indiana Plan 2.0
January 27, 2016 letter to CMS to express support to undertake an independent federal evaluation of the Healthy Indiana Plan (HIP) 2.0 Section 1115 Research and Demonstration Waiver
September 21, 2014 comments to CMS on the Healthy Indiana Plan (HIP) 2.0 Demonstration proposal from Georgetown CCF and the Center on Budget and Policy Priorities
September 21, 2014 comments to CMS on the Healthy Indiana Plan (HIP 2.0) Demonstration proposal, submitted by fourteen national organizations

Iowa

August 2, 2019 comments to HHS on proposed Section 1115 Medicaid Waiver, Iowa Wellness Plan
September 7, 2017 comments to CMS on Iowa’s request to eliminate retroactive eligibility
June 22, 2015 comments to CMS on Iowa’s proposal to extend waiver amendment regarding the non-emergency transportation (NEMT) benefit
October 23, 2014 comments to CMS on Iowa’s waiver amendment regarding the non-emergency transportation (NEMT) benefit
September 26, 2013 letter to CMS on Iowa’s two proposals for Section 1115 Medicaid Waivers—Iowa Marketplace Choice Plan and Iowa Wellness Plan
September 26, 2013 comments to CMS on Iowa’s two proposals for Section 1115 Medicaid Waivers—Iowa Marketplace Choice Plan and Iowa Wellness Plan

Kansas

January 27, 2023 letter to HHS on Kansas’s request to extend its “KanCare” Medicaid Section 1115 demonstration
November 5, 2021 letter to CMS on amendment to KanCare Section 1115 demonstration waiver
January 27, 2018 letter to CMS on KanCare Section 1115 demonstration waiver extension application
September 19, 2012 letter to CMS on Kansas’s resubmitted waiver that would move all in the Medicaid program into managed care

Kentucky

August 18, 2018 letter to HHS on the Kentucky Medicaid 1115 waiver proposal
August 17, 2018 letter to HHS on the Kentucky Section 1115 Medicaid Research and Demonstration proposal
August 2, 2017 letter to CMS on Kentucky HEALTH, Kentucky’s 1115 Medicaid Demonstration Waiver proposal
October 7, 2016 letter to CMS on Kentucky HEALTH, Kentucky’s 1115 Medicaid Demonstration Waiver proposal
October 7, 2016 sign-on letter to CMS on Kentucky HEALTH, Kentucky’s 1115 Medicaid Demonstration Waiver proposal

Maine

September 15, 2017 sign-on letter to CMS on the MaineCare 1115 Demonstration Project

Maryland

April 18, 2024 comments to HHS on Maryland HealthChoice Program’s Amendment: Reentry Demonstration
December 7, 2023 comments on Maryland’s proposed amendment to its Maryland HealthChoice Program section 1115 demonstration.

Massachusetts

November 29, 2023 comments to HHS on Massachusetts’ request to amend its “MassHealth ” section 1115 demonstration
February 3, 2022 comments to HHS on Massachusetts’ request to renew its “MassHealth ” section 1115 demonstration
July 23, 2021 amendment to Massachusetts’ “MassHealth” section 1115 demonstration
October 20, 2017 comments to CMS in response to the Massachusetts proposed amendment to its Medicaid section 1115 waiver
September 1, 2016 comments to CMS in response to Massachusetts proposed Medicaid Section 1115 waiver on the restructuring of its MassHealth delivery system

Michigan

November 5, 2022 letter to CMS on Michigan’s request to extend “Healthy Michigan Plan” Section 1115 demonstration project
June 17, 2020 letter to HHS on Michigan’s request to extend its Section 1115 Flint demonstration for ten years
October 25, 2018 letter to HHS on Michigan’s proposed amendment to its application for an extension to its “Healthy Michigan Plan” (HMP) Section 1115 demonstration project
March 2, 2016 comments to CMS in response to Michigan’s Section 1115 Medicaid Demonstration Request to Assist in Addressing Health Impacts from Potential lead Exposure in Flint, Michigan
October 2, 2015 comments to CMS on Michigan’s proposed amendment to its Section 1115 Medicaid demonstration, the Healthy Michigan Plan
December 18, 2013 letter to CMS on the “Healthy Michigan” proposal

Minnesota

March 1, 2024 comments to HHS on Minnesota Prepaid Medical Assistance Project Plus Amendment

Mississippi

August 18, 2018 comments on Mississippi revised Section 1115 Medicaid demonstration.
February 22, 2018 comments on Mississippi’s proposed Section 1115 Medicaid demonstration

Missouri

May 25, 2016 comments to CMS in response to Missouri’s proposal to offer an expanded set health benefits to a limited number of residents through a Section 1115 Medicaid demonstration, known as the Missouri Mental Health Crisis Prevention Program.

Montana

October 20, 2021 comments to HHS on Montana’s amendments to its Montana Health and Economic Livelihood Partnership (HELP) Extension Application and the Montana Waiver for Additional Services and Populations (WASP)
October 11, 2019 comment on Montana’s proposed amendment to its Section 1115 Demonstration project, known as the Montana Health and Economic Livelihood Partnership (HELP) Demonstration Program
October 15, 2015 comments to CMS on Montana’s proposal to expand Medicaid through a Section 1115 Medicaid demonstration, known as the Health and Economic Livelihood Partnership (HELP) Program

Nebraska

January 17, 2020 comments to HHS on the proposed Heritage Health Adult (HHA) program

New Hampshire

September 2, 2018 comments to HHS on New Hampshire’s requests to extend its New Hampshire Health Protection Program demonstration project
December 2, 2017 comments to CMS in response to New Hampshire’s proposed amendment to its Section 1115 Health Protection Program Premium Assistance
September 16, 2016 comments to CMS in response to New Hampshire’s proposed Section 1115 Medicaid demonstration waiver amendment, New Hampshire Health Protection Program Premium Assistance

New Jersey

April 8, 2022 comments to HHS on New Jersey’s extension request for its section 1115 demonstration
May 1, 2020 comments to HHS on New Jersey’s amendment to its FamilyCare Comprehensive section 1115 demonstration

New Mexico

January 27, 2023 letter to HHS on New Mexico’s application to extend and rename its “Centennial Care 2.0” section 1115 demonstration
August 7, 2019 letter to HHS on New Mexico’s request to amend the Centennial Care 2.0 section 1115 demonstration project
January 30, 2018 comments on New Mexico’s request to extend the Centennial Care 2.0 section 1115 demonstration project

New York

July 26, 2024 comments to HHS on New York’s request to amend its “Medicaid ReDesign Team” section 1115 demonstration.

North Carolina

December 20, 2023 comments to HHS on North Carolina’s Medicaid Reform Section 1115 Demonstration renewal request.
January 5, 2018 comments on the North Carolina Medicaid and NC Health Choice Amended section 1115 demonstration waiver application

Ohio

June 14, 2018 letter to HHS in response to Ohio’s proposed Section 1115 Demonstration project, which would take Medicaid coverage away from adults under age 50
August 4, 2016 comments to CMS in response to Ohio’s proposed section 1115 Medicaid demonstration, the Healthy Ohio Program

Oklahoma

February 3, 2023 letter to HHS on Oklahoma’s application to extend its “SoonerCare” waiver
April 21, 2021 to HHS on Oklahoma’s SoonerCare section 1115(a) research and demonstration waiver amendment request
July 29, 2020 to CMS on Oklahoma’s application for a section 1115 Medicaid demonstration, “Sooner Care 2.0.”
June 26, 2020 letter to HHS on Oklahoma’s “SoonerCare 2.0” section 1115 demonstration application. See the sign-on letter.
May 1, 2020 letter to CMS on Oklahoma’s application for a section 1115 Medicaid demonstration, “Sooner Care 2.0.”
January 18, 2019 letter to HHS on Oklahoma’s section 1115 Medicaid demonstration, or “waiver” application known as the “SoonerCare 1115(a) Research and Demonstration Waiver Amendment Request.”

Oregon

December 16, 2022 comments on Oregon Bridge amendments
April 13, 2022 comments to HHS on Oregon’s renewal application for the “Oregon Health Plan” section 1115 demonstration (CCF)
April 13, 2022 comments to HHS on Oregon’s renewal application for the “Oregon Health Plan” section 1115 demonstration (sign-on)
April 13, 2022 comments to HHS on Oregon’s renewal application for the “Oregon Health Plan” section 1115 demonstration (child-focused groups sign-on)
January 6, 2022 letter to state of Oregon on the draft renewal application for the “Oregon Health Plan” 1115 demonstration waiver

Pennsylvania

March 15, 2024 letter to HHS on Bridges to Success: Keystones of Health for Pennsylvania Request
April 10, 2014 letter to CMS on the Healthy Pennsylvania Private Coverage Option Demonstration
April 10, 2014 letter to CMS on Pennsylvania with a focus on children
April 10, 2014 comments to CMS on the Healthy Pennsylvania Private Coverage Option Demonstration

Rhode Island

February 3, 2023 letter to HHS on the Rhode Island Comprehensive Demonstration section 1115 five-year extension application

South Carolina

July 10, 2019 letter to HHS on the Community Engagement Section 1115 Demonstration Waiver application submitted by the state of South Carolina. Final comments here.

South Dakota

September 26, 2018 letter to HHS on South Dakota’s Section 1115 Medicaid demonstration, or “waiver” application known as the “South Dakota Career Connector.”

Tennessee

December 19, 2023 comments on proposed amendment to Tennessee’s “TennCare III” section 1115 demonstration project.
October 6, 2022 comments on proposed “Amendment 4” to “TennCare III” (sign-on)
January 20, 2022 comments on the notice of change to the TennCare III Program regarding maternal health enhancements
September 9, 2021 comments on the special terms and conditions of Tennessee’s section 1115 demonstration, “TennCare III”
December 23, 2019 letter to HHS on Tennessee’s proposed amendment to its section 1115 demonstration project
December 20, 2019 letter to HHS on “Amendment 42” to the TennCare II Demonstration
February 8, 2019 letter to HHS on Tennessee’s Section 1115 Medicaid demonstration amendment
February 5, 2016 letter to CMS in response to Tennessee’s proposed renewal of TennCare, its longstanding Section 1115 Medicaid demonstration program

Texas

May 3, 2024 comments to HHS on Texas’s proposed extension for its Healthy Texas Women demonstration.
July 8, 2022 comments on Texas’s proposed postpartum coverage amendment to the “Texas Healthcare Transformation and Quality Improvement Program” section 1115 demonstration
August 30, 2021 comments on Texas’s proposal for a ten-year extension of its section 1115 demonstration, the “Texas Healthcare Transformation and Quality Improvement Program”
January 15, 2021 comments on Texas’ amendment to its section 1115 demonstration entitled, “Healthy Texas Women”
January 11, 2021 comments to CMS on Texas’ proposal to extend its Section 1115 Medicaid Demonstration Project, the Texas Healthcare Transformation and Quality Improvement Program
November 16, 2015 comments to CMS on Texas’ proposal to extend its Section 1115 Medicaid Demonstration Project, the Texas Healthcare Transformation and Quality Improvement Program

Utah

August 6, 2024 comments to HHS on Utah’s proposed amendment to its “Utah Medicaid Reform 1115 Demonstration”
June 23, 2023 comments to HHS on Utah’s proposed amendment to its “Utah Medicaid Reform 1115 Demonstration” which would extend postpartum coverage to 12 months
October 21, 2021 comments to HHS on Utah’s request to extend its “Utah Primary Care Network” section 1115 demonstration
December 6, 2019 comments to HHS on Utah’s “Fallback Plan” that would amend its Primary Care Network (PCN) demonstration
September 13, 2019 comments to HHS on Utah’s “Per Capita Cap 1115 Demonstration” proposal
August 4, 2018 comments to HHS in response to Utah’s proposal to amend its section 1115 Primary Care Network demonstration project
September 29, 2017 comments to CMS in response to Utah’s proposed Section 1115 Primary Care Network Demonstration Waiver amendment
September 16, 2016 comments to CMS in response to Utah’s proposed Section 1115 Primary Care Network Demonstration Waiver
August 3, 2011 letter asks CMS to reject aspects of Utah’s demonstration waiver proposal that threaten to reduce children’s coverage

Virginia

May 7, 2021 comment on Virginia’s section 1115 demonstration “FAMIS MOMS and FAMIS Select”
January 4, 2019 comment on Virginia’s proposed extension of its Section 1115 Demonstration project

Washington

September 7, 2023 comments on Washington’s proposed amendment to its “Medicaid Transformation Project” section 1115 demonstration.
August 31, 2022 comments on Washington’s request for a five-year extension of its “Medicaid Transformation Project” section 1115 demonstration project (MTP 2.0).

Wisconsin

December 21, 2022 comments on Wisconsin’s application to extend its “BadgerCare” 1115 waiver
July 21, 2022 comments on Wisconsin’s “Postpartum Coverage 1115 Waiver” application
February 22, 2018 comments on Wisconsin’s proposed extension of its 1115 Medicaid waiver, the BadgerCare Reform Demonstration Project which was resubmitted on January 22, 2018 incorporating the amendment submitted on June 15, 2017
July 14, 2017 comments on Wisconsin’s Medicaid proposed amendment to its 1115 waiver, the BadgerCare Reform Demonstration Project (“the amendment”)
January 26, 2012 letter asks HHS to reject Wisconsin’s maintenance-of-effort waiver proposal

Comments on federal Medicaid Section 1115 waiver policy

August 17, 2022 letter to Secretary Xavier Becerra signed by 51 organizations to improve the 1115 waiver process
July 23, 2021 letter to HHS signed by 34 organizations to rescind Tennessee’s SMD #20-001 and approve the TennCare III demonstration
April 5, 2021 letter to CMS on pending section 1115 Medicaid demonstrations that would extend postpartum coverage beyond the current 60-day cutoff
January 25, 2021 letter to HHS signed by 116 organizations to rescind and unwind Section 1115 Medicaid work requirements demonstrations
July 20, 2020 letter to HHS signed by 279 organizations urging HHS Secretary to reduce racial disparities
March 6, 2018 letter to HHS signed by 44 organizations objects to the creation of barriers to Medicaid coverage
July 7, 2015 letter to CMS on waiver transparency and availability of information on Medicaid.gov in accordance with the administrative record provisions set forth in 42 CFR 431.416 (f)
June 27, 2012 letter to CMS on the new review and approval process for section 1115 demonstrations
October 17, 2011 letter asks the White House to finalize the proposed regulations on public participation in Section 1115 research and demonstration proposals (75 FR 56946) as soon as possible
April 13, 2011 letter asks HHS to finalize the proposed regulations on public participation in Section 1115 research and demonstration proposals (75 FR 56946) as soon as possible
November 16, 2010 comments on the proposed federal regulations on public process for Medicaid and CHIP demonstration waivers