Medicaid Expansion Through Premium Assistance: Arkansas and Iowa’s Section 1115 Demonstration Waiver Applications Compared
Arkansas and Iowa both have proposed to implement the Affordable Care Act’s (ACA’s) Medicaid expansion by using Medicaid funds as premium assistance to purchase coverage for some or all newly eligible Medicaid beneficiaries in Marketplace (formerly called Exchange) Qualified Health Plans (QHPs). Both states have submitted § 1115 demonstration waiver applications to the Centers for Medicare and Medicaid Services (CMS).1 Arkansas and Iowa seek demonstration waiver authority primarily because they propose to make premium assistance enrollment mandatory for affected beneficiaries. Iowa also proposes to waive its obligation to provide wrap-around benefits. This fact sheet compares the two proposals. Key similarities and differences between the proposals are summarized in Table 1 and further details on the proposals are included in Table 2. A companion paper compares the two premium assistance authorities and identifies key beneficiary protections in Medicaid expansion premium assistance programs.2
The federal level public comment period closes on September 7, 2013 for Arkansas’ application and on September 26, 2013 for Iowa’s application.3 CMS then will determine whether to approve the demonstrations and negotiate terms and conditions with the states.
Arkansas Medicaid, Health Care Independence (a/k/a Private Options) § 1115 Waiver – FINAL (Aug. 2, 2013), available at <a href="https://www.medicaid.state.ar.us/general/comment/demowaivers.aspx"; Iowa Dep’t of Human Servs., Iowa Marketplace Choice Plan § 1115 Waiver Application (Aug. 2013), available at <a href="http://www.dhs.state.ia.us/uploads/IAMktplaceChoice1115_Final.pdf"; see also Kaiser Commission on Medicaid and the Uninsured, Medicaid Expansion through Premium Assistance: Key Issues for Beneficiaries in Arkansas’ Section 1115 Demonstration Waiver Proposal (July 2013), available at <a href="http://www.kff.org/medicaid/issue-brief/medicaid-expansion-through-premium-assistance-key-issues-for-beneficiaries-in-arkansas-section-1115-demonstration-waiver-proposal/". CMS has finalized regulations that permit states to implement the Medicaid expansion through premium assistance as a state plan option, without the need for a waiver, and also issued guidance governing possible § 1115 premium assistance demonstrations. 42 C.F.R. § 1015, 78 Fed. Reg. 42160-42322 (July 15, 2013), available at <a href="https://www.federalregister.gov/articles/2013/07/15/2013-16271/essential-health-benefits-in-alternative-benefit-plans-eligibility-notices-fair-hearing-and-appeal"; HHS, Medicaid and the Affordable Care Act: Premium Assistance (March 2013), available at <a href="http://www.medicaid.gov/Federal-Policy-Guidance/Downloads/FAQ-03-29-13-Premium-Assistance.pdf".
Kaiser Commission on Medicaid and the Uninsured, Medicaid Expansion Through Marketplace Premium Assistance (Sept. 2013), available at http://kff.org/medicaid/fact-sheet/medicaid-expansion-through-marketplace-premium-assistance.
For more information about the ACA’s transparency requirements for § 1115 demonstrations, see Kaiser Commission on Medicaid and the Uninsured, The New Review and Approval Process Rule for Section 1115 Medicaid and CHIP Demonstration Waivers (March 2012), available at <a href="http://www.kff.org/health-reform/fact-sheet/the-new-review-and-approval-process-rule/".
also of interest
- Medicaid Expansion Through Marketplace Premium Assistance
- Premium Assistance in Medicaid and CHIP: An Overview of Current Options and Implications of the Affordable Care Act
- Medicaid Expansion through Premium Assistance: Key Issues for Beneficiaries in Arkansas’ Section 1115 Demonstration Waiver Proposal