An Early Look at Medicaid Expansion Waiver Implementation in Michigan and Indiana

MaryBeth Musumeci, Robin Rudowitz, Petry Ubri, and Elizabeth Hinton
Published: Jan 31, 2017

Appendix Table 1: Waiver and Expenditure Authorities Related to Medicaid Expansion in Michigan and Indiana
Authority	Michigan	Indiana
Premiums	Allows state to charge monthly premiums of 2% of income for beneficiaries from 100-138% FPL.	Allows state to require monthly premiums of 2% of income as a condition of eligibility for non-medically frail beneficiaries from 100-138% FPL. Allows state to charge monthly premiums of 2% of income for beneficiaries from 0-100% FPL to access an enhanced benefit package. Waives 5% cap on out-of-pocket costs so that beneficiaries from 0-5% FPL are charged $1.00/month to access enhanced benefits.
Comparability	Allows state to vary premiums, copayments and healthy behavior reductions by population.	Allows state to vary cost-sharing from state plan requirements so that beneficiaries who pay premiums only have non-emergency ER use copays and those not paying premiums have copays for other services at state plan amounts.
Expenditures for Healthy Behavior Incentives	Authorizes federal matching funds for healthy behavior incentives that offset beneficiary cost-sharing liability.	N/A
Reasonable Promptness	N/A	Allows state to begin coverage on 1^st day of month in which premium is paid or 1^st day of the month in which 60-day payment period expires for those under 100% FPL. Allows disenrollment and 6 month lock-out for those from 100-138% FPL who do not pay premiums.
Retroactivity	N/A	Allows state to not provide coverage prior to 1^st day of month in which beneficiary pays 1^st premium. Allows state not to provide coverage until 1^st day of month in which the 60-day payment period expires for those from 0-100% FPL.
Cost-Sharing for Non-Emergency Use of ER	N/A	Allows state to test graduated co-payment up to $25 for 2 years.*
Methods of Administration	N/A	Allows state to not provide NEMT to non-medically frail expansion adults.**
Cost-Effectiveness	Allows state-developed cost-effectiveness tests for Medicaid premium assistance to purchase Marketplace QHP coverage (effective April 2018).	N/A
Provider Payment	Allows state to limit provider payments for beneficiaries enrolled in Marketplace QHPs to QHP market rates (effective April 2018).	N/A
Prior Authorization	Allows prescription drug prior authorizations for Marketplace QHP enrollees to be addressed in 72 hours instead of 24 hours, with a 72-hour supply provided in emergencies (effective April 2018).	N/A
Expenditures for QHP Premiums and Cost-Sharing Reductions	Authorizes federal matching funds for QHP premium assistance costs that do not meet federal cost-effectiveness test or that include benefits not covered under Medicaid state plan.	N/A
NOTES: MI received other waiver authorities related to Medicaid managed care, and IN received other waiver authorities related to Medicaid premium assistance for employer-sponsored insurance. ER copay waiver authority is under § 1916 (f). *IN’s initial NEMT waiver was through Jan. 1, 2016, and was extended through Jan. 2018. SOURCE: CMS Expenditure Authority and Waiver List, Healthy Michigan Demonstration, Dec. 30, 2013-Dec. 31, 2018, amended Dec. 17, 2015; CMS Waiver List, Healthy Indiana Plan 2.0, Feb. 1, 2015-Jan. 31, 2108.

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