Section 1115 Medicaid Waiver Comments

(Last updated: January 2, 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

  • 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

Connecticut

  • May 13, 2022 comments to HHS on Connecticut’s proposed “Covered Connecticut” section 1115 demonstration

Florida

  • 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.

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

Maryland

  • 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

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

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

  • 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

  • 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

  • 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

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