Medicaid Waiver Map
Use this interactive map to help you determine if your state has a Section 1115 Medicaid waiver and the impact on Medicaid beneficiaries living with or at risk for HIV and hepatitis. Please see NASTAD’s related Medicaid resources: Medicaid 1115 Waivers: Considerations for HIV and Hepatitis Programs and Medicaid 1115 Waivers: Exemptions for People Living with HIV and Hepatitis. Additional information about approved and pending waivers can be found on the Centers for Medicare & Medicaid Services website.
This map was produced as part of a project supported by the Elton John AIDS Foundation.
Last Updated: December 16, 2021
Medicaid Waiver Fact Sheets
Map
Waiver Status
Alabama
Pending
Alabama Section 1115 Institutions for Mental Disease Waiver for Serious Mental Illness
- Status: Pending
- Proposed amendment would authorize inpatient behavioral health services for short-term residents in residential and inpatient treatment settings that qualify as an IMD. The waiver would be limited to IMDs operating in Mobile, Washington, and Baldwin counties, but Medicaid enrollees residing in any Alabama county may access services.
- State Resources
- Federal Application (March 2021)
Alaska
Approved
Alaska Substance Use Disorder and Behavioral Health Program
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Provides an enhanced set of mental health, behavioral health, and substance use treatment benefits.
- State Resources
- Federal Approval
American Samoa
No Waiver
Arizona
Both
Arizona Health Care Cost Containment System
- Status: Renewal and Amendments Pending
- Requires premiums for expansion adults above 100% FPL through contributions to AHCCCS CARE account (similar to a Health Savings Account). Premiums and coinsurance liabilities are billed to members on a quarterly basis. Beneficiaries that make timely payments and engage in specified healthy behaviors related to preventive health and/or chronic disease management will be exempt from premiums for six months. Members may access funds in AHCCCS CARE account upon completion of healthy behaviors. Disenrollment for failure to pay premiums, but no lockout for re-enrollment.
- Enacts payment and delivery reforms to improve behavioral health services, including incentive payments to providers for increasing physical and behavioral health care integration and coordination.
- “Medically frail” individuals are exempt from premiums. The state has proposed to develop a definition of “medically frail” that specifically includes people living with HIV, but has not yet done so.
- The state has received Appendix K approvals for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- Proposed amendment would authorize SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Proposed extension request would allow Arizona to continue most of its current programs, including the authority to implement the work requirements they had previously postponed.
- Proposed amendment would expand housing services and interventions for individuals experiencing homelessness or at risk of becoming homeless who meet at least one other criterion, including but not limited to individuals with a serious mental illness, individuals in need of substance use treatment, individuals determined high-risk or high-cost based on service utilization or health history, individuals with chronic conditions (including HIV/AIDS or SUD), and individuals at high risk of experiencing homelessness upon release from an institutional setting (including IMDs or incarceration settings).
- REJECTED: CMS rejected the state’s proposal to impose a five-year lifetime coverage limit for individuals who fail to comply with work requirements.
- UPDATE—February 12, 2021: CMS senta letter to the state explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- UPDATE—October 17, 2019: Arizona has postponed implementation of work requirements until further notice, citing the “evolving national landscape concerning Medicaid community engagement programs” and ongoing litigation in several other states. Arizona previously received federal approval to implement work requirements for “able-bodied” expansion adults age 19-49, with exemptions for “medically frail” individuals, with disenrollment and two-month lockout for failure to comply. Work requirements were set to take effect no earlier than January 2020.
- State Resources
- Federal Approval
- Federal Application (May 2021)
- Federal Application (December 2020)
- Federal Application (May 2017)
- National Organization Comments on Arizona 1115 Waiver Amendment (May 2018)
- National Organization Comments on Arizona 1115 Waiver Amendment (February 2018)
- HIV Health Care Access Working Group Comments on Arizona 1115 Waiver (December 2015)
Arkansas
Approved
Arkansas Works
- Status: Approved
- Premium assistance model for purchase of Qualified Health Plans for Medicaid expansion population.
- UPDATE—March 17, 2021: CMS has withdrawn its prior approval of Arkansas’ work requirements. CMS previously sent a letter to the state, to which the state responded, explaining that it had begun the process of determining whether to withdraw the state’s previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid.
- UPDATE—February 14, 2020: A federal appeals court upheld the March 2019 decision, and ruled that the Arkansas waiver approval violated federal law.
- UPDATE—March 27, 2019: Arkansas’ waiver has been invalidated following a lawsuit in federal court, on the grounds that HHS violated federal law when it approved the waiver without considering whether the waiver furthered the objectives of the Medicaid program. The waiver, which included work requirements, premiums, and other provisions, has been remanded to HHS to correct this error, and these provisions will not be implemented at this time.
- State Resources
- Federal Approval (March 2018) (NOTE: Pursuant to a May 14, 2019 notice from CMS, the state must adhere to the waiver special terms and conditions that were approved on December 8, 2016)
- National Organization Comments on Loss of Coverage Resulting from Arkansas’ Section 1115 Waiver (November 2018)
- National Organization Comments on Arkansas 1115 Waiver Amendments (August 2017)
- NHeLP Comments on Arkansas 1115 Waiver Amendments (August 2016)
California
Approved
Medi-Cal 2020 Demonstration
- Status: Approved
- Waiver began as "Bridge to Reform" to allow for early Medicaid expansion for Medi-Cal beneficiaries as well as payment and delivery reform initiatives. The waiver allowed the state to incorporate people with disabilities into the Medi-Cal managed care system and supported a range of projects aimed at improving care at safety net and public hospitals.
- “Health home” initiative allows the state to offer care coordination services to beneficiaries with chronic conditions in managed care plans. Health home services may be provided by community health workers.
- Authorizes pilot program programs to support infrastructure development to integrate services for enrollees with mental health or substance use disorders.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- The state has received Appendix K approval for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- The one-year renewal amends the demonstration to end California’s Designated State Health Program (DSHP). DSHP provided federal funds to otherwise state-funded programs, including the AIDS Drug Assistance Program (ADAP).
- State Resources
- Federal Approval
- Federal Application (October 2020)
- Federal Application (February 2020)
- National Organization Comments on California's 1115 Waiver (October 2011)
Colorado
Approved
Expanding the Substance Use Disorder Continuum of Care
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Connecticut
No Waiver
Delaware
Approved
Diamond State Health Plan
- Status: Approved
- Eliminates retroactive eligibility for most populations.
- Expands community-based behavioral health services.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Provides preventative and restorative dental care coverage.
- The state has received approval for Appendix K and COVID-19 amendments to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- State Resources
- Federal Approval
Federated States of Micronesia
No Waiver
Florida
Approved
Florida Managed Medical Assistance Program
- Status: Approved
- Extends most waiver provisions for 10 years. The behavioral health and supportive housing assistance pilots are extended for five years.
- Provides coverage for individuals diagnosed with AIDS with income at or below 222% FPL and assets not exceeding $2,000 (for an individual).
- Enrolls people living with HIV or AIDS in specialty plans, where available.
- Eliminates retroactive coverage.
- Includes community behavioral health providers as participating providers under the Low Income Pool.
- Authorizes a pilot program to provide behavioral health and supportive housing assistance services for enrollees age 21 and older with serious mental illness and/or substance use disorder who are homeless or at risk of homelessness due to disability.
- State Resources
- Federal Approval
- National Organization Comments on Florida 1115 Waiver Amendment (June 2018)
Georgia
Approved
Georgia Pathways to Coverage
- Status: Approved
- Implements partial expansion for adults age 19-64 up to 95% FPL who are already working or participating in work-related activities for 80 hours per month. The state’s waiver does not provide for any exemptions for applicants who do not meet the work requirements upon their initial application. Applicants with incomes above 50% FPL must also make an initial premium payment before their coverage can begin.
- Imposes work requirement as a condition of eligibility for all demonstration enrollees, with disenrollment and three-month lockout for failure to comply. Re-enrollment within three months is contingent upon proof of compliance. Members who demonstrate compliance for six consecutive months will be exempt from reporting compliance for the remainder of the 12-month benefit year, but the state will perform periodic and random audits to verify compliance. The work requirement is not yet in effect, but is set to be implemented July 1, 2021.
- Allows for waiting periods. Applicants must demonstrate compliance with work requirements in order to gain coverage.
- Imposes premiums for enrollees with incomes at or above 50% FPL, through contributions to a Member Rewards Account. Enrollees will be suspended after two months of non-payment and disenrolled after three months of non-payment, and may re-apply for coverage at any time following disenrollment.
- Imposes approximately 50% tobacco premium surcharge.
- Implements Member Rewards Accounts (similar to a Health Savings Account) for enrollees with incomes at or above 50% FPL. Accounts are funded with enrollee premiums, as well as with state funds for completion of healthy behavior activities. Copayments will be deducted from account balances. Beneficiaries are not responsible for negative balances, but future premium payments or healthy behavior incentive payments will be used to offset a negative balance. Once an enrollee’s account balance reaches $50, funds may be used to pay for certain health-related expenses not covered by Medicaid (such as over-the-counter drugs, dental services, and glasses).
- Imposes copayments for enrollees with incomes at or above 50% FPL. Copayment are not paid to providers at the point of service, but are instead assessed retrospectively for services already received. Copayments are deducted from Member Rewards Accounts, which may result in a negative balance if the account has insufficient funds. Future premium payments and healthy incentive points will be applied to the balance.
- Eliminates retroactive eligibility.
- Eliminates hospital presumptive eligibility.
- Allows for waiting periods. Enrollment begins at the start of the month following the state’s eligibility determination, or the month following the initial premium payment for enrollees that must pay premiums. Applicants must also demonstrate compliance with work requirements in order to gain coverage.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- State Resources
- Federal Approval
- National Organization Comments on Georgia 1115 Waiver (February 2020)
Georgia Postpartum Extension
- Status: Approved
- Extends postpartum coverage from 60 days to 6 months for individuals with income up to 220% FPL.
- Federal Approval
Guam
No Waiver
Hawaii
Approved
Hawaii QUEST Integration
- Status: Approved
- Provides community integration services for beneficiaries who are homeless or at risk of homelessness, and who also have a behavioral health need, complex physical health need, or a substance use need.
- The state has received Appendix K approval for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- State Resources
- Federal Approval
Hawaii COVID-19 Public Health Emergency Demonstration
- Status: Approved
- Authorizes the state to modify certain assessments and deadlines for beneficiaries receiving HCBS services.
- Modifies HCBS visitor requirements to minimize the spread of COVID-19.
- Authorizes retainer payments for certain providers.
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- State Resources
- Federal Approval
Idaho
Both
Idaho Medicaid Reform Waiver
- Status: Pending
- Proposal would impose work requirements for expansion adults age 19-59, with disenrollment and two-month lockout for failure to comply.
- State Resources
- Federal Application (October 2019)
- National Organization Comments on Idaho’s 1115 Waiver (November 2019)
Idaho Behavioral Health Transformation
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
- NHeLP Comments on Idaho 1115 waiver (February 2020)
Illinois
Approved
Illinois Behavioral Health Transformation
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Authorizes 10 SUD pilot projects that provide case management, withdrawal management, peer recovery, tenancy support, and other services to various populations in need of SUD care.
- Expands community-based behavioral health benefits.
- State Resources
- Federal Approval
- AIDS Foundation of Chicago Comments on Illinois 1115 Waiver (November 2016)
Illinois Behavioral Health Transformation
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Authorizes 10 SUD pilot projects that provide case management, withdrawal management, peer recovery, tenancy support, and other services to various populations in need of SUD care.
- Expands community-based behavioral health benefits.
- State Resources
- Federal Approval
- AIDS Foundation of Chicago Comments on Illinois 1115 Waiver (November 2016)
Illinois Continuity of Care and Administrative Simplification
- Status: Approved
- Allows managed care reinstatement within 90 days when a Medicaid beneficiary submits late redetermination paperwork, rather than requiring reinstatement into fee-for-service prior to going through the managed care enrollment process again, in order to reduce churn between fee-for-service and managed care.
- Waives hospital presumptive eligibility.
- Extends postpartum coverage from 60 days to 12 months for individuals with income up to 208% FPL.
- State Resources
- Federal Approval
Indiana
Both
Healthy Indiana Plan (HIP) 2.0
- Status: Approved
- Approves most provisions of the Healthy Indiana Program for 10 years. Work requirements and lockouts for non-compliance with various eligibility requirements are approved conditionally for five years, contingent on the Supreme Court issuing a decision in Azar v. Gresham that legally authorizes these provisions. SUD authorities are extended for five years.
- Establishes premiums through monthly contributions to a Personal Wellness and Responsibility (POWER) account (similar to a Health Savings Account). Disenrollment with 6-month lockout for failure to pay premiums (>100% FPL only) is conditionally approved, contingent on the Supreme Court issuing a decision in Azar v. Gresham that legally authorizes lockout periods. Premiums are optional for beneficiaries with incomes below 100% FPL, but those who do not pay premiums get fewer benefits and must pay cost-sharing charges.
- Eliminates non-emergency medical transportation.
- Eliminates retroactive coverage for non-pregnant HIP program enrollees.
- Allows for waiting periods for enrollees with incomes above 100% FPL who are subject to mandatory premiums. Coverage begins on the first day of the month in which the initial premium payment is made.
- Imposes 50% tobacco premium surcharge.
- Disenrollment with lockout for failure to complete annual redetermination on time. Enrollees have 90 days following disenrollment to submit redetermination paperwork and re-enroll. Failure to complete redetermination during this 90-day period results in additional 3-month lockout. Lockouts are conditionally approved, contingent on the Supreme Court issuing a decision in Azar v. Gresham that legally authorizes lockout periods.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- CMS is still reviewing the state’s request to extend Workforce Bridge Accounts, funded from aggregate remaining balances of HIP $2,500 POWER Accounts, to cover premiums and out-of-pocket costs for a 12-month period for enrollees who must transition from Medicaid to commercial insurance due to an increase in income. This was initially approved through the state’s ESRD Waiver, which expired on December 31, 2020, but implementation was delayed due to the ongoing COVID-19 public health emergency.
- HIV and “chronic” hepatitis B and C included in medically frail condition list, but exemption may not be automatic. Medically frail are exempt from work requirements, lockout periods, and non-emergency medical transportation waiver.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- UPDATE—October 31, 2019: Indiana has suspended implementation of work requirements until further notice, citing ongoing litigation in other states. Indiana previously received conditional federal approval, contingent on the Supreme Court issuing a decision in Azar v. Gresham that legally authorizes work requirements. The approval would authorize Indiana’s “Gateway to Work” for adults age 19-59 in the Medicaid expansion, low-income parents and caretakers, and Transitional Medical Assistance (TMA) eligibility groups, with exemptions for “medically frail” individuals (including people living with HIV and “chronic” hepatitis B and C). The penalty for non-compliance is disenrollment until next redetermination, or until compliance is achieved. The state had already begun phasing in its work requirements in July 2019, and penalties for non-compliance were set to begin in January 2020.
- State Resources
- Federal Approval
- National Organization Comments on Indiana’s Request to Amend 1115 Waiver Extension Request (July 2017)
- NHeLP Comments on Indiana’s SMI/SED 1115 Amendment Request (October 2019)
- NHeLP Comments on Indiana’s 1115 Waiver Amendments (September 2019)
- NHeLP Comments on Indiana’s Request to Amend 1115 Waiver Extension Request (July 2017)
- National Organization Comments on Indiana 1115 Waiver Extension Request (March 2017)
- National Organization Comments on Evaluation and Lockout Provisions of Indiana 1115 Waiver (January 2016)
- HIV Health Care Access Working Group Comments on Indiana 1115 Waiver (September 2014)
Maternal Opioid Misuse Indiana Initiative
- Status: Withdrawn
- UPDATE—June 2, 2021: The state has withdrawn its proposal to extend postpartum coverage through a section 1115 waiver. The state will provide 12 months of postpartum coverage under the American Rescue Plan Act beginning in April 2022.
- Federal Application (October 2020)
Iowa
Pending
Iowa Wellness Plan
- Status: Amendment Pending
- Allows state to charge premiums to enrollees with income above 50% FPL after the first year of enrollment. Enrollees that engage in specified “healthy behaviors” will not be subject to premiums. Individuals with incomes above 100% FPL will be disenrolled for failure to pay premiums, but may re-enroll any time with no lockout period. Individuals with incomes at or below 100% FPL will not be disenrolled for failure to pay premiums, but will lose comprehensive dental benefits.
- Eliminates non-emergency medical transportation.
- Eliminates retroactive coverage.
- State Resources
- Federal Approval
- Federal Application (February 2021)
- Georgetown University Center for Children and Families Comments on Iowa 1115 Waiver Amendments (September 2017)
- NHeLP Comments on Iowa 1115 Waiver Amendments (September 2017)
Kansas
Pending
KanCare
- Status: Amendment Pending
- Authorizes rehabilitation services designed to meet the more intensive needs of individuals with SUD in their community and avoid the need for inpatient hospitalization. Services are prior authorized and include various detox, treatment, and community-based services.
- Expands community-based behavioral health benefits.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- REJECTED: CMS rejected the state’s proposal to impose a 36-month lifetime coverage limit for individuals who are subject to work requirements.
- UPDATE—December 18, 2018: The state has asked CMS to defer consideration of proposals to impose work requirements and to limit coverage for TMA enrollees.
- State Resources
- Federal Approval
- Federal Application (July 2019)
- NHeLP Comments on Kansas 1115 Waiver Renewal (January 2018)
- National Organization Comments on Kansas 1115 Waiver Extension Request (January 2018)
Kentucky
Both
KY HEALTH
- Status: Amendment Pending
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Eliminates non-emergency transportation for methadone services. Medically frail, including people living with HIV and hepatitis, are exempt from this waiver and may receive non-emergency medical transportation for methadone services.
- Proposed amendment would authorize federal Medicaid matching funds for SUD treatment provided to adults with incomes at or below 138% FPL incarcerated in state and county facilities.
- UPDATE—June 16, 2020: The state withdrew the components of its waiver that were invalidated by the court in March 2019, and CMS reissued its approval of the remaining provisions.
- UPDATE—March 27, 2019: Kentucky's waiver has been invalidated following a lawsuit in federal court, on the grounds that HHS violated federal law when it approved the waiver without considering whether the waiver furthered the objectives of the Medicaid program. The waiver, which included work requirements, premiums, and other provisions, has been remanded to HHS to correct this error, and will not be implemented at this time. The waiver included exemptions from many of these provisions for people living with HIV and hepatitis.
- State Resources
- Federal Approval
- Federal Application (November 2020)
- CIDP Comments on Kentucky 1115 Waiver Resubmission (August 2018)
- HHCAWG Comments on Kentucky 1115 Waiver Resubmission (August 2018)
- NHeLP Comments on Kentucky 1115 Waiver Resubmission (August 2018)
- National Organization Comments on Kentucky 1115 Waiver Amendments (August 2017)
- NHeLP Comments on Kentucky 1115 Waiver (October 2016)
- National Organization Comments on Kentucky 1115 Waiver (October 2016)
- AAHIVM Comments on Kentucky 1115 Waiver (July 2016)
Louisiana
Approved
Healthy Louisiana OUD/SUD Demonstration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State resources
- Federal Approval
Maine
Approved
Maine Section 1115 Demonstration for Individuals Living with HIV/AIDS
- Status: Approved
- Provides coverage for PLWH with incomes at or below 250% FPL.
- Enrollees with incomes at or below 133% FPL who are eligible for MaineCare receive Medicaid state plan-covered services and case management services.
- Enrollees with incomes at or below 250% FPL who are not eligible for MaineCare receive a targeted essential set of services. The benefits provided to this group are not recognized as Minimum Essential Coverage under the ACA.
- State Resources
- Federal Approval
Maine Substance Use Disorder Care Initiative
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
MaineCare
- Status: Withdrawn
- UPDATE—January 2019: The state withdrew its application, which would have imposed work requirements, premiums (with exemptions for enrollees in the HIV/AIDS waiver), copayments for non-emergency use of the ER, and asset tests. The proposal would also have eliminated retroactive eligibility and hospital presumptive eligibility.
- Federal Application (August 2017)
Marshall Islands
No Waiver
Maryland
Approved
Maryland Health Choice
- Status: Approved
- Authorizes a pilot program to integrate physical and behavioral health services in primary care settings for a limited number of beneficiaries.
- Authorizes SUD treatment services for residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Massachusetts
Both
MassHealth
- Status: Amendments Pending
- Shifts certain Medicaid populations into 1115 demonstration, including PLWH with income at or below 200% FPL.
- Expands eligibility, with some limits on benefits, for PLWH with incomes between 133 and 200% FPL who would be eligible for Medicaid expansion but for their income. Enrollees may choose to receive premium assistance for ESI (with wraparound) in lieu of direct coverage.
- PLWH with income above 133% FPL do not receive EPSDT services or non-emergency medical transportation, and may be subject to waiting list.
- Discontinues provisional eligibility for certain adults. PLWH with incomes at or below 200% FPL may self-attest to income eligibility and receive 90-day provisional eligibility.
- Extends Massachusetts’ longstanding 1115 waiver to move to an Accountable Care Organization model. The ACO model incentivizes partnership between ACOs and community-based organizations to improve behavioral care and long-term services and supports in particular.
- Establishes a DSRIP program to incentivize investment to address social determinants of health.
- Expands benefits to address the opioid epidemic.
- Provides subsidies for individuals under 300% FPL who are not eligible for Medicaid and who purchase Marketplace coverage.
- Allows the state to consider family income and resources “not actually made available to the applicant,” as well as income from any member of the “family unit,” when determining income for eligibility purposes.
- Limits retroactive eligibility to 10 days prior to application date for most eligibility groups.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Expands community-based behavioral health benefits.
- Proposed amendment seeks partial expansion to 100% FPL, and would shift coverage for ACA expansion adults and non-disabled parents and caretakers to subsidized Exchange plans (>100% FPL) or 1115 demonstration (<100% FPL) depending on income. PLWH who were eligible for MassHealth prior to ACA would remain eligible for Medicaid.
- Proposed amendment would eliminate emergency Medicaid for immigrants who are eligible for subsidized coverage with a $0 premium and nominal cost-sharing through the Exchange.
- Proposed amendment would implement cost-sharing limit (5% of aggregate household income) on an annual basis rather than a quarterly or monthly basis.
- Proposed amendment would eliminate non-emergency medical transportation, except to SUD treatment services.
- Proposed amendment would expand existing authority for mental health and SUD services delivered in IMDs to include medically necessary treatment for co-occurring mental health conditions.
- Proposed amendment would expand existing authority for behavioral health and SUD services delivered in IMDs to improve care for adults with serious mental illness and children with serious emotional disturbance.
- REJECTED: CMS rejected the state’s request to impose a closed formulary.
- State Resources
- Federal Approval
- Federal Application (August 2020)
- Federal Application (September 2017)
- National Organization Comments on Massachusetts 1115 Waiver Amendments (October 2017)
- NHeLP Comments on Massachusetts 1115 Waiver Amendments (October 2017)
Massachusetts COVID-19 Public Health Emergency (PHE) Demonstration
- Status: Approved
- Allows the state to target mobile testing initiatives on a geographic basis that is less than statewide.
- Permits the state to restrict beneficiary choice to a limited network of telehealth and ambulance providers that are providing mobile testing services.
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- Federal Approval
Michigan
Approved
Healthy Michigan
- Status: Approved
- Imposes cost-sharing requirements. Cost-sharing rules depend on the enrollee’s income and how long they have been enrolled. Cost-sharing amounts are based on the enrollee’s utilization during the first 6 months of enrollment, and are billed to the enrollee on a quarterly basis.
- Imposes monthly premiums for enrollees with incomes above 100% FPL in the form of contributions to MI Health Account (similar to a health savings account). Enrollees who have had more than 48 months of cumulative enrollment will be disenrolled with lockout for failure to comply; re-enrollment is contingent upon payment of past due premiums. Premiums will increase after 48 months of cumulative enrollment, in lieu of cost-sharing. The state has postponed implementation of premiums.
- Provides “healthy behavior” incentives to offset cost-sharing and monthly premiums. Enrollees with income above 100% FPL and more than 48 months of cumulative enrollment are not eligible for healthy behavior incentives. The state has postponed implementation of healthy behavior requirements.
- Requires compliance with “healthy behaviors” or completion of a health risk assessment as a condition of eligibility for individuals with income above 100% FPL who have had at least 48 months of cumulative enrollment, with disenrollment for failure to comply. Re-enrollment is contingent upon completion of a health risk assessment. The state has postponed implementation of healthy behavior requirements.
- Allows requests for prior authorization for prescription drugs to be addressed within 72 hours for individuals enrolled in Marketplace premium assistance. A 72-hour supply must still be provided in the event of emergency.
- Eliminates cost-sharing for drugs related to treatment of HIV and substance use disorder.
- Eliminates cost-sharing for services related to chronic conditions, including HIV, substance use disorder, and viral hepatitis.
- HIV is included in the medically frail condition list. Medically frail are exempt from premiums and the 48-month cumulative enrollment provisions.
- UPDATE—April 6, 2021: CMS has withdrawn its prior approval of Michigan’s work requirements. CMS previously senta letter to the state, to which the state did not respond, explaining that it had begun the process of determining whether to withdraw the state’s previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid.
- UPDATE—September 23, 2019: Michigan postponed implementation of premium and healthy behavior requirements until October 1, 2020. As of April 2021, premiums have not yet been implemented.
- State Resources
- Federal Approval
- National Organization Comments on Michigan 1115 Waiver Amendment (October 2018)
- National Organization Comments on Michigan 1115 Waiver (October 2015)
- National Organization Comments on Michigan 1115 Waiver (December 2013)
Michigan 1115 Pathway to Integration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Minnesota
Approved
Minnesota Substance Use Disorder System Reform
- Status: Approved
- Authorizes intensive outpatient SUD services not otherwise covered under the state plan.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Mississippi
Pending
Mississippi Medicaid Workforce Training Initiative
- Status: Pending
- Proposal would impose work requirements on “able-bodied” adults currently covered under traditional Medicaid, including low-income parents and caretakers and individuals eligible for Transitional Medical Assistance (TMA). Individuals who fail to meet work requirements will be disenrolled with lockout until compliance is achieved.
- Proposal would provide additional 12 months of coverage for TMA enrollees who comply with work requirements.
- State Resources
- Federal Application (January 2018 and May 2018)
- NHeLP Comments on Mississippi Revised 1115 Waiver (August 2018)
- National Organization Comments on Mississippi 1115 Waiver (February 2018)
- HHCAWG Comments on Mississippi 1115 Waiver (February 2018)
Missouri
Approved
Missouri Targeted Benefits for Pregnant Women Section 1115 Demonstration
- Status: Approved
- Authorizes limited SUD and mental health services, including non-emergency medical transportation to and from treatment, for enrollees up to 196% FPL with an SUD diagnosis who were previously enrolled in pregnancy-related Medicaid.
- State Resources
- Federal Approval
Montana
Both
Montana Health and Economic Livelihood Partnership (HELP)
- Status: Amendment Pending
- Authorizes 12 months of continuous coverage for the Medicaid expansion population.
- Imposes premiums for individuals with income 50-133% FPL. Individuals with income above 100% FPL may be disenrolled for failure to pay premiums, with lockout until the end of the calendar quarter or upon payment of outstanding premiums.
- Uses an Alternative Benefit Plan for the expansion population with defined provider network.
- Proposed amendment would impose work requirements for non-exempt expansion adults age 19-55, with disenrollment and six-month lockout for failure to comply.
- Proposed amendment would gradually increase premiums based on the length of time an enrollee is enrolled in the program, capped at four percent of aggregate household income.
- State Resources
- Federal Approval
- Federal Application (August 2019)
- National Organization Comments on Montana HELP Program 1115 Waiver (October 2015)
Nebraska
Approved
Nebraska Substance Use Disorder Section 1115 Demonstration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Nebraska Heritage Health Adult 1115 Demonstration
- Status: Approved
- Implements Medicaid expansion through a tiered benefit system.
- Most enrollees (excluding medically frail) receive the “Basic” benefit package in the first six months of enrollment, and are eligible to receive the “Prime” benefits package (includes dental, vision, and over the counter medication) upon compliance with work requirements, healthy behaviors, and personal responsibility activities. Enrollees who fail to comply with work requirements, healthy behaviors, and personal responsibility activities will not lose Medicaid eligibility, but will be enrolled in the “Basic” benefits package. The work requirement is not yet in effect, but is set to be implemented April 1, 2022.
- HIV is included as “a serious or complex medical condition” in the medically frail condition list. Medically frail are automatically enrolled in the “Prime” benefits package.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- State Resources
- Federal Approval
Nevada
No Waiver
New Hampshire
Both
New Hampshire Granite Advantage Health Care Program
- Status: Approved
- Eliminates retroactive coverage for certain eligibility groups. Although New Hampshire passed legislation in 2019 requiring the state to revise its retroactive coverage waiver and CMS has notified the state that it must reinstate three-month retroactive eligibility, this waiver provision is included in the most recent federal approval (March 2021).
- UPDATE—March 17, 2021: CMS has withdrawn its prior approval of New Hampshire’s work requirements. CMS previously senta letter to the state, to which the state did not respond, explaining that it had begun the process of determining whether to withdraw the state’s previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid.
- UPDATE—August 19, 2019: CMS notified New Hampshire that the state must cease implementation of work requirements and reinstate three-month retroactive eligibility.
- UPDATE—July 29, 2019: New Hampshire’s waiver has been invalidated following a lawsuit in federal court, on the grounds that HHS violated federal law when it approved the waiver without considering the potential coverage losses or whether the waiver furthered the objectives of the Medicaid program.
- UPDATE—July 8, 2019: New Hampshire passed legislation providing for suspension of work requirements under certain circumstances. The administration suspended implementation through September 30, 2019 upon finding that 17,000 Medicaid members failed to report compliance with work requirements for June 2019. The legislation also requires the state to submit a revised waiver permitting 45 days of retroactive coverage.
- State Resources
- Federal Approval
- National Organization Comments on New Hampshire 1115 Waiver Extension (September 2018)
- National Organization Comments on New Hampshire 1115 Waiver Amendments (December 2017)
- Center on Budget and Policy Priorities and Georgetown University Center for Children and Families Comments on New Hampshire 1115 Waiver (September 2016)
New Hampshire SUD Treatment and Recovery Access
- Status: Amendment Pending
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
- Federal Application (August 2020)
New Hampshire COVID-19 Public Health Emergency (PHE) Demonstration
- Status: Approved
- Authorizes retainer payments for certain providers.
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- State Resources
- Federal Approval
New Jersey
Pending
New Jersey FamilyCare Comprehensive Demonstration
- Status: Amendment Pending
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- The state has received two Appendix K approvals for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- Proposed amendment would extend postpartum coverage to 180 days for enrollees with income up to 205% FPL.
- State Resources
- Federal Approval
- Federal Application (February 2020)
New Mexico
Approved
Centennial Care 2.0
- Status: Approved
- Access to expanded benefits for individuals who complete “healthy behaviors.”
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- The state has received two Appendix K approvals for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- In February 2020, CMS approved the state’s request to remove the following previously approved waivers: premiums, copayments for non-emergency use of the hospital emergency department and non-preferred prescription drugs, and elimination of retroactive eligibility.
- State Resources
- Federal Approval
- National Organization Comments on New Mexico 1115 Waiver (January 2018)
New York
Both
New York Medicaid Redesign Team
- Status: Renewal and Amendments Pending
- Implements capitated HIV Special Needs Plans (HIV SNP) for PLWH, transgender individuals, and people experiencing homelessness. Dependent children of eligible enrollees may also enroll in a SNP plan.
- Implements Medicaid Managed Care Health and Recovery Plans (HARPs) to integrate physical health, behavioral health, and behavioral health home and community-based services for enrollees with diagnosed severe mental illness (SMI) and/or substance use disorders (SUD).
- HIV SNPs provide behavioral health home and community-based services to enrollees meeting HARP targeting, risk, and needs-based criteria.
- Authorizes a Behavioral Health Self-Direction Pilot to make self-direction services available to HARP and HIV SNP enrollees receiving behavioral health home and community-based services.
- Waives non-drug cost-sharing for certain enrollees.
- Proposed amendment would eliminate administrative barriers to utilization of behavioral health services.
- Proposed amendment would extend the Behavioral Health Self-Direction Pilot, which expired on March 31, 2021.
- State Resources
- State Resources (HIV SNPs)
- State Resources (HARPs)
- State Resources (HARPs)
- Federal Approval
- Federal Application (March 2021)
- Federal Application (March 2021)
- Federal Application (November 2020)
- Federal Application (September 2020)
North Carolina
Approved
North Carolina's Medicaid Reform Demonstration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- REJECTED: CMS rejected the state’s proposals to impose premiums and work requirements on expansion group adults, on the grounds that the state currently lacks legislative approval to provide coverage to this group.
- State Resources
- Federal Approval
- National Organization Comments on North Carolina 1115 Waiver (January 2018)
- Duke Health Justice Clinic and North Carolina AIDS Action Network (NCAAN) Comments on North Carolina 1115 Waiver (April 2016)
North Carolina COVID-19 Public Health Emergency Demonstration
- Status: Approved
- Authorizes the state to expedite eligibility for long-term care services and supports (LTSS) by accepting self-attestation or alternative verification for certain eligibility requirements.
- Authorizes the state to delay certain assessments for beneficiaries receiving LTSS services.
- Authorizes retainer payments for certain providers.
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- Federal Approval
North Dakota
No Waiver
Northern Mariana Islands
No Waiver
Ohio
Approved
Ohio Group VIII Work Requirements and Community Engagement Section 1115 Demonstration Waiver
- Status: Approved
- Imposes work requirements as a condition of eligibility for expansion adults ages 19-49, with disenrollment for failure to comply. Enrollees may re-enroll at any time with no lockout period. The work requirement is not yet in effect.
- Exempts individuals with chronic conditions participating in the Specialized Recovery Services (SRS) Program, which includes people living with HIV who also have a serious mental illness, from work requirements.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- State Resources
- Federal Approval
- National Organization Comments on Ohio 1115 Waiver (June 2018)
- HHCAWG Comments on Ohio 1115 Waiver (June 2018)
Ohio Section 1115 Demonstration Waiver for Substance Use Disorder Treatment
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Healthy Ohio Program
- Status: Rejected
- CMS rejected the state’s proposal to impose premiums (with disenrollment for failure to pay and lockout until past due premiums are paid in full).
- Federal rejection letter (September 2016)
- Federal application (June 2016)
Oklahoma
Both
Oklahoma SoonerCare
- Status: Amendments Pending
- SoonerCare Choice program: primary care case management delivery system with patient-centered medical home (PCMH) model. The state withdrew its proposal to add Medicaid expansion population to the PCMH service delivery mode.
- Insure Oklahoma: premium assistance program (including Employer-Sponsored Insurance program and Individual Program) for individuals who do not qualify for SoonerCare or SoonerCare Choice.
- Eliminates retroactive coverage for certain eligibility groups.
- Eliminates EPSDT for full time college students age 19 through 22 with incomes above 200% FPL.
- Eliminates non-emergency transportation for certain eligibility groups.
- Proposed amendment seeks to phase-out the Insure Oklahoma Individual Program and establish to a new income band for the Insure Oklahoma Employer-Sponsored Insurance plan of 134%-200% of the FPL. Amendment would take effect July 1, 2021 to coincide with the State’s Medicaid expansion.
- Proposed amendment would eliminate retroactive eligibility for most adults.
- State Resources
- Federal Approval
- Federal Application (March 2021)
- Federal Application (November 2020)
- Federal Application (May 2020)
- Federal Application (December 2018)
- Federal Application (March 2016)
- National Organization Comments on Oklahoma 1115 Waiver Amendment (January 2019)
Oklahoma SoonerCare 2.0
- Status: Withdrawn
- UPDATE—August 2020: The state withdrew its application, which would have imposed work requirements, premiums (with exemptions for people living with HIV, SUD, or a serious mental illness), waiting periods, and lockout periods; reduced EPSDT benefits; eliminated non-emergency medical transportation, retroactive eligibility, and hospital presumptive eligibility; and authorized capped “block grant” funding.
- Federal Application (May 2020)
Oklahoma Institutions for Mental Disease Waiver for Serious Mental Illness/Substance Use Disorder
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Oregon
Approved
Oregon Health Plan Substance Use Disorder 1115 Demonstration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Palau
No Waiver
Pennsylvania
Approved
Pennsylvania Medicaid Coverage Former Foster Care Youth From a Different State SUD Demonstration
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Puerto Rico
No Waiver
Rhode Island
Approved
Rhode Island Comprehensive Demonstration
- Status: Approved
- The state received approvals for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- Federal Appendix K Approval (March 2020)
- Federal Appendix K Approval (May 2020)
- Federal Appendix K Approval (May 2020)
Rhode Island COVID-19 Public Health Emergency Demonstration (PHE)
- Status: Approved
- Authorizes retainer payments for some services using the rehabilitative service benefit
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- Federal Approval
South Carolina
Approved
South Carolina Healthy Connections Works
- Status: Approved
- Imposes work requirements as a condition of eligibility for non-disabled adults under age 65 in the low-income parents and caretakers and Transitional Medical Assistance (TMA) eligibility groups, with up to three-month lockout for failure to comply. The work requirements are not yet in effect.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal
- State Resources
- Federal Approval
South Carolina Palmetto Pathways to Independence
- Status: Approved
- Provides Medicaid coverage for parents and caretakers with incomes up to 100% FPL who meet all other criteria for the Parents and Other Caretaker Relatives group under the state plan.
- Provides coverage to certain “Targeted Adults” (“chronically homeless” individuals with incomes up to 5% FPL, justice-involved individuals in need of substance use or mental health treatment with incomes up to 100% FPL, and individuals in need of substance use treatment with incomes up to 100% FPL). Enrollment for Targeted Adults is limited to 12 months, unless the enrollee continues to be actively engaged in SUD treatment at the end of the 12-month period.
- Sets aside 1,000 slots for pregnant or postpartum individuals with income up to 194% FPL and a diagnosis of SUD and/or serious mental illness, and parents of foster children with income up to 133% FPL who are completing or complying with an SUD treatment program as part of a family reunification plan.
- Authorizes the state to cap enrollment for the Targeted Adult Group.
- Imposes work requirements for all populations included in the waiver, with disenrollment for failure to comply and lockout until compliance is achieved. Applicants must be in compliance with work requirements at the time of application to be enrolled.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- State Resources
- Federal Approval
South Dakota
Pending
South Dakota Career Connector
- Status: Pending
- Proposal would impose work requirements as a condition of eligibility for adults age 19-59 in the low-income parents and caretakers and Transitional Medical Assistance (TMA) eligibility groups in two counties. Individuals who fail to meet work requirements will be disenrolled.
- Proposal would implement premium assistance model for purchase of Qualified Health Plans for one additional year of Transitional Medical Assistance (TMA) coverage after expiration of original TMA period.
- State Resources
- Federal Application (August 2018)
- National Organization Comments on South Dakota’s 1115 Waiver (September 2018)
Tennessee
Pending
TennCare III (Subsumes TennCare II)
- Status: Amendments Pending
- Approves TennCare III for 10 years. The state had requested a permanent implementation of the demonstration, which CMS did not approve.
- Authorizes capped “block grant” funding. If the state spends less than the aggregate cap, they can retain up to 55% of the excess federal funds and spend them on non-Medicaid health programs.
- Authorizes the state to implement a closed drug formulary. The state will only have to offer one drug per therapeutic class but will still receive statutory drug rebates.
- Beneficiaries enrolled in the state’s patient-centered medical home (PCMH) are eligible for Medication Therapy Management (MTM).
- The state has received Appendix K approval for a number of amendments in order to respond to the COVID-19 pandemic. These provisions will terminate upon termination of the COVID-19 public health emergency.
- Proposed amendment would impose work requirements as a condition of eligibility for low-income parents and caretakers ages 19-64.
- Proposed amendment would authorize SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Proposed amendment would authorize capped “block grant” funding for the state’s Medicaid program.
- Proposed amendment would authorize the state to waive certain federal managed care regulations.
- State Resources
- Federal Approval
- Federal Application (March 2021)
- Federal Application (December 2018)
- Federal Application (August 2018)
- Federal Application (May 2018)
- Center on Budget and Policy Priorities and Georgetown University Center for Children and Families Comments on Tennessee 1115 Waiver (February 2016)
Texas
Pending
Texas Healthcare Transformation and Quality Improvement Program
- Status: Amendments Pending
- Authorizes the state to require most Medicaid populations be enrolled in managed care and establishes the Uncompensated Care (UC) pool and the Delivery System Reform Incentive Payment (DSRIP) pool.
- Reauthorization was “fast tracked” and therefore received a 10 year approval while skipping the public notice and comment period. The demonstration was previously set to expire on September 30, 2022.
- State Resources
- Federal Approval
- Federal Application (February 2021)
Utah
Both
Utah Primary Care Network
- Status: Amendments Pending
- Expands Medicaid to adults up to 138% FPL at the enhanced federal match rate.
- Imposes work requirement as a condition of eligibility for expansion adults age 19-64, with disenrollment for failure to comply and lockout until compliance is achieved. The work requirement is not yet in effect. Implementation has been postponed due to COVID-19.
- Provides full state benefits for adults without dependent children with income at 0% FPL who are chronically homeless, involved in the criminal justice system, or in need of SUD or mental health treatment (“Targeted Adults” group).
- Eliminates retroactive coverage for certain enrollees.
- Eliminates non-emergency medical transportation for certain enrollees.
- Weakens EPSDT benefits for 19- and 20-year-olds in certain eligibility groups.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Expands dental services to certain adults with income at 0% FPL who are receiving SUD treatment.
- Authorizes clinically managed residential withdrawal management services, referred to as “social detoxification,” to Medicaid-eligible adults in Salt Lake County.
- Authorizes mental health services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Provides dental benefits to beneficiaries who are living with a disability or blindness.
- Proposed amendment would eliminate hospital presumptive eligibility.
- Proposed amendment would impose premiums for enrollees with incomes above 100% FPL. The first premium payment would be due prior to the month of eligibility.
- Proposed amendment would allow the state to bypass the CMS waiver approval process and instead make certain changes through the state’s administrative rulemaking process. These changes would include waiting periods for the Medicaid expansion group (coverage would begin the month following application), elimination of retroactive eligibility for Medicaid expansion adults with incomes over 100% FPL, and changes to benefits packages for certain populations.
- Proposed amendment would provide Medicaid coverage for justice-involved individuals with a chronic physical or behavioral health condition, mental illness, or opioid use disorder in the 30-day period immediately prior to release from a correctional facility.
- REJECTED: CMS rejected the state’s request to receive the enhanced federal match rate for partial expansion. The enhanced match is unavailable for waivers that limit enrollment in the new adult group, either by implementing an income cutoff of less than 138% FPL or through an enrollment cap.
- REJECTED: CMS rejected the state’s request to implement an enrollment cap for the expansion population.
- UPDATE—February 12, 2021: CMS sent a letter to the state, to which the state responded, explaining that it is beginning the process of determining whether to withdraw the state's previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid. CMS also withdrew the 2018 State Medicaid Director Letter encouraging work requirement demonstrations by removing it from the CMS website and guidance portal.
- State Resources
- Federal Approval
- Federal Application (February 2021)
- Federal Application (December 2020)
- Federal Application (July 2020)
- Federal Application (November 2019)
- NHeLP Comments on Utah 1115 Waiver Amendment (December 2019)
- National Organization Comments on Utah 1115 Waiver Amendment (August 2018)
- National Organization Comments on Utah 1115 Waiver Extension Amendments (September 2017)
- NHeLP Comments on Utah 1115 Waiver Extension Amendments (September 2017)
Utah Per Capita Cap 1115 Demonstration
- Status: Pending
- Proposal would authorize a per capita cap funding mechanism for the expansion group, which will include the “Targeted Adults” group.
- Proposal would impose work requirements for the Medicaid expansion population.
- Proposal would eliminate hospital presumptive eligibility.
- REJECTED: CMS rejected the state’s request to receive the enhanced federal match rate for partial expansion. The enhanced match is unavailable for waivers that limit enrollment in the new adult group, either by implementing an income cutoff of less than 138% FPL or through an enrollment cap.
- State Resources
- Federal Application (August 2019)
Vermont
Approved
Vermont Global Commitment to Health
- Status: Approved
- Authorizes premium subsidies for individuals enrolled in a QHP with incomes at or below 300% FPL.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- The state has received Appendix K approval for a number of amendments in order to respond to the COVID-19 pandemic.
- State Resources
- Federal Approval
Virgin Islands
No Waiver
Virginia
Both
Building and Transforming Coverage, Services, and Supports for a Healthier Virginia
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Authorizes limited housing and employment supports to certain high needs enrollees with a behavioral health need, need for assistance with daily living, or a complex physical health need. CMS is still reviewing some aspects of the state’s proposal to provide housing supports.
- UPDATE—July 2020: CMS approved the state’s request to remove previously approved waivers allowing premiums and work requirements.
- State Resources
- Federal Approval
- National Organization Comments on Virginia 1115 Waiver (January 2019)
Virginia FAMIS MOMS and FAMIS Select
- Status: Amendment Pending
- Extends CHIP coverage to uninsured pregnant persons with income at or below 200% FPL.
- Pending amendment would extend postpartum coverage from 60 days to 12 months for enrollees with income up to 205% FPL.
- State Resources (FAMIS MOMS)
- State Resources (FAMIS Select)
- Federal Approval
- Federal Application (March 2021)
Washington
Pending
Washington Medicaid Transformation Project
- Status: Amendment and Renewal Pending
- Establishes Accountable Communities of Health (ACHs) comprised of clinical and community service providers to lead projects including capacity building, care delivery redesign, and prevention and health promotion for Medicaid beneficiaries.
- Authorizes SUD treatment services and mental health services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
- Federal Application (January 2021)
- Federal Application (January 2021)
Washington COVID-19 Public Health Emergency
- Status: Approved
- Authorizes the state to expedite eligibility for long-term care services and supports (LTSS) by accepting self-attestation or alternative verification for certain eligibility requirements.
- Authorizes the state to delay certain assessments for beneficiaries receiving LTSS services.
- Authorizes increased payments for certain providers.
- Authorizes retainer payments for certain providers.
- NOTE: This 1115 waiver will terminate upon termination of the COVID-19 public health emergency.
- Federal Approval
District of Columbia
Approved
D.C Behavioral Health Transformation
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Expands community-based behavioral health benefits.
- State Resources
- Federal Approval
West Virginia
Approved
West Virginia Creating a Continuum of Care for Medicaid Enrollees with Substance Use Disorder
- Status: Approved
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- State Resources
- Federal Approval
Wisconsin
Pending
Wisconsin BadgerCare Reform
- Status: Amendment Pending
- Authorizes state to implement partial expansion by providing benefits to non-pregnant childless adults ages 19-64 with incomes at or below 100% FPL. “Childless” adults may have children, but do not live with children under age 19.
- Imposes premiums for individuals with incomes above 50% FPL, with disenrollment and 6-month lockout for failure to comply. Premiums may be reduced for individuals who do not engage in “health risk behaviors,” including alcohol consumption and illicit drug use. Early re-enrollment permitted upon payment of past due premiums.
- Imposes work requirements as a condition of eligibility for adults ages 19-49. The work requirement is not yet in effect, but the state plans to implement it April 29, 2021.
- Imposes 48-month enrollment time limit, followed by 6-month lockout, for enrollees subject to work requirements. Months in which the individual meets work requirements do not count towards the 48-month limit.
- Requires completion of health risk assessment as a condition of eligibility.
- Authorizes SUD treatment services for short-term residents in residential and inpatient treatment settings that qualify as an IMD.
- Proposed amendment would establish Health Savings Accounts for individuals paying premiums.
- UPDATE—April 6, 2021: CMS has withdrawn its prior approval of Wisconsin’s work requirements. CMS previously sent a letter to the state, to which the state did not respond, explaining that it had begun the process of determining whether to withdraw the state’s previously approved authorities after making the preliminary decision that work requirements do not promote the objectives of Medicaid.
- State Resources
- Federal Approval
- Federal Application (December 2020)
- National Organization Comments on Wisconsin 1115 Waiver Amendments (February 2018)
- National Organization Comments on Wisconsin 1115 Waiver Amendments (July 2017)
Wisconsin Senior Care
- Status: Amendment Pending
- Provides comprehensive prescription drug benefits to Wisconsin residents age 65+ with income at or below 200% FPL who are not otherwise eligible to receive full Medicaid benefits.
- Proposed amendment would authorize coverage of vaccinations.
- State Resources
- Federal Approval
- Federal Application (November 2020)
Wyoming
No Waiver
Medicaid Waiver Map – Background Information
What is a Medicaid 1115 Waiver?
Section 1115 of the Social Security Act gives the Secretary of Health and Human Services authority to approve demonstration projects that promote the objectives of the Medicaid program. To encourage innovative demonstration projects, section 1115 gives states additional flexibility to “waive” certain federal Medicaid requirements. An 1115 waiver or demonstration project typically lasts for five years (with the option to renew). Demonstration projects must also be “budget neutral” to the federal government, meaning that during the course of the project, the federal Medicaid expenditures cannot be more than federal spending would have been without the project.
What Kinds of Things Can States Do with an 1115 Waiver?
States have used the flexibility provided through 1115 waivers for a number of different purposes, including to:
- Implement the Medicaid expansion in an innovative way, for instance through purchase of Qualified Health Plans for the Medicaid expansion population
- Expand services for a particular population, for instance, substance use disorder services to better address the opioid epidemic
- Test innovative ways to pay for and deliver care, for instance through expansion of the types of providers eligible to seek Medicaid reimbursement or programs that incentivize partnerships between hospital systems and community and public health providers to improve individual and population health
- Impose additional eligibility requirements, such as work requirements, increased cost-sharing, monthly premiums, and lifetime enrollment caps
- Expand eligibility for family planning services, for instance, by increasing the income threshold or not limiting eligibility to women
How Do Medicaid 1115 Waivers Impact HIV and Hepatitis Prevention Programs?
Because 1115 waivers can be used to develop innovative approaches to population health, with an emphasis on prevention, there may be reimbursement opportunities for HIV prevention services included in these types of waivers. For instance, some waivers have been used to cover services provided by Community Health Workers and other peer workers or to cover HIV linkage services. Waivers are also being used to increase drug user health services and address the opioid epidemic and could include new opportunities for partnerships with HIV and hepatitis public health programs.
How Can I Weigh in with My State or the Federal Government During the 1115 Waiver Approval Process?
There are a number of transparency and notice and comment requirements that must precede 1115 waiver approval. At the state level, states must post all 1115 waiver applications on the state Medicaid website and provide a public comment period to solicit input from interested parties. This often includes public hearings and listening sessions to discuss the proposal and solicit feedback. Following the state notice and comment process, the application is submitted for federal review by CMS, where it is posted on the CMS website and subject to another notice and comment period from interested parties. Public health stakeholders should weigh in at all stages of the 1115 waiver application process to ensure that proposals protect access to care and prevention services for people living with and at risk for HIV and hepatitis.
Glossary
- ACO: Accountable Care Organizations are groups of providers (e.g., doctors, hospitals, community health centers) that receive financial incentives to work together to provide coordinated care across provider types and settings for patients
- ACH: Accountable Communities of Health are similar to ACOs and bring together clinical providers as well as social services programs and providers to provide patient-centered care that addresses health care needs as well as social determinants of health
- CHIP: The Children’s Health Insurance Program provides coverage to eligible children through Medicaid or a separate program. Like Medicaid, it is administered by states subject to federal rules and jointly funded by states and the federal government
- CMS: The Centers for Medicare and Medicaid Services is the federal agency that oversees the Medicaid program
- DSRIP: Delivery System Reform Incentive Plans are a type of 1115 waiver states may use to restructure the way they deliver and pay for Medicaid and other safety net health services
- FPL: Federal poverty level, a federal income threshold used to determine eligibility for public programs that are based on financial need
- MCO: Managed Care Organizations are entities that serve Medicaid beneficiaries through a network of providers through a financial and contractual arrangement with the state Medicaid program
- Premium Assistance: A Medicaid option that allows states to use Medicaid funding to purchase commercial insurance for eligible beneficiaries on the private market (as opposed to through the traditional Medicaid fee-for-service or managed care systems)
What Other Resources Are There on 1115 Waivers?
- NASTAD’s Health Systems Integration team is happy to answer any questions about Medicaid 1115 waivers. Contact Dori Molozanov with questions.
- Centers for Medicare and Medicaid Services (CMS), State Waivers Page
- Kaiser Family Foundation, All About Section 1115 Medicaid Waivers and Medicaid Waiver Tracker
- Georgetown Center for Children and Families, Medicaid and CHIP Waivers
- Families USA, Medicaid 1115 Coverage Waivers Resource Center
- National Health Law Program, Section 1115 Waiver Request Tracker
- National Academy for State Health Policy, State Appendix K and Emergency Waivers to Support Home- and Community-Based Services in Response to COVID-19