Policy and Regulation News

CMS Adjusts Medicaid 1115 State Innovation Waiver Processes

CMS is improving the Medicaid 1115 state innovation waiver application process by streamlining the path to approval.

CMS is expediting 1115 waiver approvals

Source: Thinkstock

By Thomas Beaton

- CMS is attempting to streamline the approval process for Medicaid 1115 state innovation waivers by implementing new policies that prioritize transparency, the agency announced in a bulletin.

The agency has adjusted 1115 waiver policies in an attempt to further encourage states to tailor their state Medicaid programs to their unique needs.

“CMS recognizes the need to improve the section 1115 demonstration process to facilitate expedited approval of demonstration projects.” said Center for Medicaid and CHIP Services (CMCS) Director Brian Neale.

“The process improvements described below are aimed at reducing burden, increasing efficiency, and promoting transparency in the review were developed in partnership with states and after thorough review of the current approval process.”

CMS will improve the application process by removing duplicative information fields on the submission template and by providing additional guidance and technical assistance. The agency will also help applicants develop a timeline for application completion, including scheduling necessary meetings and deliverables.

CMS will also pay particular attention to making sure that states are meeting the Special Terms and Conditions (STCs), which include agreements between applicants and CMS about quality measures and performance benchmarks for Medicaid program innovations.

Oversight from CMS includes implementing procedural changes that lower the amount of delays in a state’s implementation schedule. These changes include improved access between CMS and state leaders, readily available virtual stakeholder meetings, open submission of STC drafts, and active request for information (ROI) periods.

States also will be made aware of the approval process from beginning to end with a new transparency review checklist, and an open checklist that highlights the progress of the waiver approval process.

The fast-track process streamlines federal review processes for certain demonstration requests, such as previous 1115 waiver-approved programs with at least one completed demonstration cycle looking for renewal. States may also use an abbreviated template for submitting a waiver to further increase the speed of approval.

Additional new measures include budget neutrality clarifications for states as well as enhanced collaboration around creating federal-state partnerships. These partnerships would help identify funding solutions and optimal data reporting measures for facilitating 1115 demonstrations.

CMS has also reduced the number of monitoring requirements so that states can focus on using the best metrics and quality measures.  

CMS will allow currently established 1115 demonstrations to operate as they are without requiring them to adhere to new collaborative programs, as a measure to limit disruption. New 1115 demonstrations will be required follow the procedures in the bulletin.

Ever since the agency previously urged state governors to submit 1115 waivers in a letter on March 14, CMS has coordinated with state governments to develop approaches that can make the waiver application process more efficient.

States that want to establish their own public payer and market stability solutions may have enhanced opportunities to do so through fast and efficient 1115 waiver processes.