Section 1115 Medicaid Waiver Comments

(updated as of October 29, 2018)

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

  • 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 Arizona Health Care Cost Containment System (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

  • 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

Florida

  • June 5, 2018 letter to HHS address concerns over Florida proposal to eliminate retroactive coverage for all non-pregnant adults

Indiana

  • 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

  • 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, 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

Massachusetts

  • 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

  • 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 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.

New Hampshire

  • 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 Mexico

  • January 30, 2018 comments on New Mexico’s request to extend the Centennial Care 2.0 section 1115 demonstration project

North Carolina

  • 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.

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

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

  • February 5, 2016 letter to CMS in response to Tennessee’s proposed renewal of TennCare, its longstanding Section 1115 Medicaid demonstration program.

Texas

  • 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 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

Wisconsin

  • 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

  • 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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