Expert Perspectives

Aug 24, 2018 

CMS Issues Additional Guidance on Budget Neutrality for Section 1115 Waivers

On Wednesday, August 22, the Centers for Medicare & Medicaid Services (CMS) released a State Medicaid Director Letter (SMDL) memorializing CMS policy for ensuring that Section 1115 waivers remain budget neutral to the federal government. The SMDL describes CMS policy for calculating budget neutrality both for new waivers and for extensions of existing waivers with the implications for states with existing waivers, and those seeking to apply for waivers, discussed in this expert perspective.

Apr 13, 2018 

The 2019 Affordable Care Act Payment Rule: Summary and Implications for States

On April 9, 2018, the U.S. Department of Health & Human Services (HHS) released its final Notice of Benefit and Payment Parameters for 2019, referred to here as the Payment Notice. This is an annual rule that includes a wide range of policy and operational changes for the Affordable Care Act (ACA) marketplaces, insurance market reforms, and premium stabilization programs. Concurrent with the 2019 Payment Notice, HHS also released sub-regulatory guidance, including the final annual letter to issuers, key dates for health plans participating in the individual and small-group markets in 2019, and an expansion of the circumstances under which individuals can qualify for exemptions to the ACA’s individual mandate. This expert perspective focuses on major provisions of the Payment Notice and accompanying guidance documents that require state decision-making or have other significant implications for states.