(1) What waiver provisions have been approved? Common themes in the seven Medicaid expansion waivers approved to date in Arizona, Arkansas, Indiana, Iowa, Michigan, Montana, and New Hampshire include using Medicaid as premium assistance; charging premiums above federal limits; eliminating non-emergency medical transportation; and offering healthy behavior incentives to reduce premiums and/or co-payments. Additional provisions approved in Indiana include making coverage effective with the first premium payment instead of on the application date; eliminating retroactive eligibility (later approved in New Hampshire and Arkansas); and barring certain expansion adults from re-enrolling in coverage for six months if they are dis-enrolled for unpaid premiums (later approved for three months in Montana). (2) What waiver provisions have been denied? Under the prior Administration, CMS denied Medicaid expansion waiver provisions that would have reduced coverage; required premiums for beneficiaries with incomes under 100% FPL as a condition of eligibility; waived Early and Periodic Screening, Diagnostic, and Treatment benefits for children and beneficiaries' free choice of family planning provider; and imposed work requirements as a condition of eligibility. To date, CMS also has required states to cover all expansion adults up to 138% FPL to receive enhanced federal matching funds. (3) What issues should we watch? As the new Administration considers waiver requests, including those currently pending for Kentucky and Indiana, areas to watch include provisions that reduce coverage under existing expansions; seek enhanced federal matching funds for partial coverage expansions; require work as a condition of eligibility; or impose lifetime limits. Other key areas to watch are the application of federal budget neutrality requirements and the waiver transparency rules and consideration of waiver evaluation results when determining whether certain provisions are approved in other states.
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