November 2, 2018, Wisconsin Medical Society Medigram  

The Centers for Medicare and Medicaid Services (CMS) announced yesterday its approval for Wisconsin’s 1115 Medicaid demonstration waiver. The approved waiver makes Wisconsin the fourth state to implement work requirements for its childless adult population (adults between the ages of 19 and 64). The initial waiver application also included drug testing requirements, but CMS did not approve those provisions.

The approved waiver also includes the following provisions:

• Limits eligibility for childless adults to 48 continuous months for those who do not meet specified obligations such as work requirements, education or job training or do not have a specified exemption. At the end of the 48 months, the enrollee will lose Medicaid eligibility for 6 months, at which time they could re-enroll in Medicaid and the 48-month clock would restart.
• Establishes monthly premiums of $8 per household (or less depending on income and healthy behaviors).
• Requires members to complete a health and wellness questionnaire. Monthly premiums for enrollees who complete the questionnaire will be cut in half.
• Expands coverage of residential treatment for substance use disorder.
• Establishes an emergency department (ED) copayment of $8 for non-emergency use of the ED. If enrollees appropriately use the ED for an emergency health issue they will not be charged a copay.
• Discontinues premiums for parents and caretaker relatives who qualify for transitional medical assistance.

 
The Wisconsin Medical Society commented on all these proposals in its May 2017 letter, which expressed concerns about potential impacts on patients and physicians, while offering support for expansion of substance use disorder treatment. The Society’s House of Delegates also passed policy on the waiver during its 2018 meeting last April.

1332 Waiver

In addition to its action on the 1115 waiver, last week CMS issued new guidance on 1332 waivers. The new guidance, which went into effect immediately, loosens existing guardrails on the 1332 waiver process. States will no longer be required to demonstrate that their 1332 waiver would cover the same amount of people as would be required absent the waiver, only that the same number of people would have access to coverage. Further, access could be defined as acquiring coverage from a short-term limited duration health plan or an association health plan, which do not have to adhere to Affordable Care Act patient protections.

Contact the Society’s Manager of Advocacy and Regulatory Affairs H.J. Waukau if you have questions about either waiver.