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 here to sign on to these
comments.