A working group consisting of the Center on Budget and Policy Priorities, Georgetown CCF, Families USA, and NHelp, with input from the National Women’s Law Center, NCQA and SEIU have produced comments on the proposed Section 1332 State Innovation waiver public process regulations issued by CMS on March 14, 2011. Take a look at the comments.

Yes it is hard to keep track of this which comments and waivers we are talking about here!! In the fall, we developed comments on proposed public process regulations on Section 1115 Medicaid and CHIP research and demonstrations. As I blogged about on March 3rd, State Innovations Waivers are a new, and at this point theoretical, option.  They were created by the Affordable Care Act and currently the law states that they would not become available until 2017. (NOTE: Legislation has been introduced to move this date up to 2014 but so far it is not moving in Congress.)

State Innovation Waivers are not Medicaid and CHIP waivers but rather an opportunity for states to request a waiver of provisions of the new law related to employer and individual responsibility requirements, the establishment of exchanges, subsidies, benefits and cost-sharing rules. A state could apply for this new waiver through a coordinated process with a Section 1115 Medicaid and/or CHIP waiver thus marrying the two into a “super waiver” proposal – hence some of the confusion about how this affects Medicaid and CHIP.

So these are going to be important transparency requirements and we urge you to submit comments of your own. The deadline is May 16th. Please feel free to use any or all of the attached comments. And for readers affiliated with national groups, please click hereto sign on to these comments.