The unwinding related section 1902(e)(14) strategies newly available to Medicaid and CHIP agencies can provide significant relief to states facing pending eligibility and enrollment actions and processing delays, workforce and systems limitations, and other operational challenges. Ensuring eligible individuals do not lose coverage for procedural or administrative reasons and supporting those who are ineligible for Medicaid/CHIP transition to Marketplace coverage will be paramount for all states as they begin to resume normal operations when the federal public health emergency (PHE) ends. This expert perspective outlines the time-limited targeted enrollment flexibilities that CMS has availed to states through section 1902(e)(14) waiver authority and discusses considerations beyond the strategies described in federal guidance and supplemental resources.
Overview of Alternative Medicaid Expansion Waivers
Patricia Boozang, Deborah Bachrach, and Mindy Lipson, Manatt Health
Section 1115 waivers allow states to waive certain Medicaid statutory requirements in order to advance state policy priorities and test innovations in their Medicaid programs, provided that they are budget neutral and “further the goals of the Medicaid program.” Since 2014, seven states have used 1115 waivers to implement alternative Medicaid expansions, and these waivers are likely to be leveraged by states in the next four years to advance changes to Medicaid. This issue brief, developed by Manatt Health, provides an overview of the features of these alternative Medicaid expansion waivers. The document describes how approved waivers have approached aspects including premiums, cost-sharing, Health Savings-like Accounts, healthy behavior incentives, and several others, and can provide insight into state policy priorities and suggest areas where states may seek future waivers.