Federal waivers allow states to test new ways to deliver and pay for health care services. Changes to the state’s Medicaid program often require waivers approved by the federal Centers for Medicare & Medicaid Services (CMS) to continue receiving federal Medicaid funding. The following are waivers that the Minnesota Department of Human Services (DHS) has applied for or received.
On August 16, 2019, CMS approved the Minnesota Substance Use Disorder System Reform section 1115 waiver effective from July 1, 2019, through June 30, 2024.
Public input on the proposed extension of PMAP+ waiver
The PMAP+ waiver provides federal authority to:
Cover children under Medical Assistance who are 12 to 23 months old with income eligibility above 275 percent and at or below 283 percent of the federal poverty level (FPL)
Waive the federal requirement to redetermine the basis of Medical Assistance eligibility for caretaker adults with incomes at or below 133 percent of the FPL who live with children age 18 who are not full-time secondary school students;
Provide Medical Assistance benefits to pregnant women during the period of presumptive eligibility; and
Fund graduate medical education through the Medical Education Research Costs (MERC) trust fund.
Federal authority for the PMAP+ waiver expires on December 31, 2020. The waiver extension request will seek to renew the current PMAP+ waiver through December 31, 2025.
DHS is holding a 30-day comment period from May 26, 2020 to June 25, 2020, to provide an opportunity for the public to comment on the proposed waiver renewal. DHS intends to submit the extension request to CMS following the public comment period.
Please submit your written comment by email to Section1115WaiverComments@state.mn.us. DHS would like to provide copies of comments received in a format that is accessible for people with disabilities. Therefore, we request that comments be submitted in Microsoft Word format or incorporated within the email text. If you would also like to provide a signed copy of the comment letter, you may submit a second copy in Adobe PDF format. Comments must be received by June 25, 2020.
Teleconferences
In addition to the opportunity to submit written comments during the 30-day public comment period, two teleconferences will be held to provide stakeholders and other interested persons the opportunity to comment on the waiver request. The dates and times of the two conferences are provided below.
Teleconference #1
Date: Monday, June 1, 2020
Time: 9:00 a.m.
Teleconference #2
Date: Wednesday, June 3, 2020
Time: 4:00 p.m.
The PMAP+ renewal request seeks to continue longstanding authorities for Minnesota’s Medicaid program including the following:
MA One-Year-Olds
The PMAP+ waiver provides expenditure authority for Medicaid coverage for children from age 12 months through 23 months, who would not otherwise be eligible for Medicaid, with incomes above 275% and at or below 283% of the federal poverty level (FPL).
Caretaker Adults with 18-Year-Old
The PMAP+ waiver provides for Medicaid coverage for Caretaker Adults who live with and assume responsibility for a youngest or only child who is age 18 and is not enrolled full time in secondary school. PMAP+ waiver authority allows Minnesota to waive the requirement to track the full-time student status of children age 18 living with a caretaker. Beginning in 2014, Minnesota covers both adults without children and caretaker adults to 133% of the FPL under the state plan. Adults without children and caretaker adults are eligible for the full MA benefit set. Without waiver authority, a caretaker adult with the youngest child or only child turning 18 would need to be re-determined under an “adult without children” basis of eligibility. This exercise is meaningless because Minnesota covers adults and parents to the same income level. Health care coverage and cost-sharing are the same.
The household size for the parent is independent of the required tracking of the child’s full-time student status. For non-tax filing families, Minnesota has chosen age 19 as the age at which a child is no longer in the household. In a tax filing household, the parent’s household size would depend on whether they expect to claim the child as a dependent, regardless of age. By waiving the requirement to track the full-time student status, Minnesota avoids requesting private data that will not be consequential to the consumer’s eligibility for health care. In addition to relieving the burden on consumers and not requesting personal information that is not relevant to eligibility, coverage, or cost-sharing, Minnesota expects the waiver to result in administrative efficiency by simplifying the procedures that caseworkers need to follow.
Pregnant Women
The Patient Protection and Affordable Care Act (ACA) established the hospital presumptive eligibility (PE) program effective January 2014 allowing qualified hospitals to make MA eligibility determinations for people who meet basic criteria. Under hospital PE, covered benefits for pregnant women during a presumptive eligibility period are limited to ambulatory prenatal care. Minnesota has secured PMAP+ waiver authority to allow pregnant women to receive services during a presumptive eligibility period that are in addition to ambulatory prenatal care services. The benefit for pregnant women during a hospital presumptive eligibility period will be the full benefit set that is available to qualified pregnant women in accordance with section 1902(a)(10)(i)(III) of the Act. Implementation of presumptive eligibility began in July 2014.
MERC
Through expenditure authority granted under the PMAP+ waiver, payments made through the Medical Education and Research Costs (MERC) Trust Fund through sponsoring institutions to medical care providers are eligible for federal financial participation.
Delivery System
Minnesota currently utilizes both fee-for-service and managed care delivery systems under the Medicaid State plan. Coverage for a large portion of enrollees in Medical Assistance is purchased on a prepaid capitated basis. Managed care enrollment is mandatory for Medicaid State plan groups that are not otherwise exempt from mandatory managed care. The remaining recipients received services from enrolled providers who are paid on a fee-for-service basis. Most of the fee-for-service recipients are individuals with disabilities. DHS contracts with MCOs in each of Minnesota’s 87 counties.
Enrollment and Expenditures
Following are the state’s estimates of the expected enrollment and expenditures under the demonstration.
MA One-Year Olds
SFY 2022
SFY 2023
SFY 2024
SFY 2025
SFY 2025
Total
Member Months
761
802
845
890
469
PMPM Cost
$136.80
$141.05
$145.44
$149.96
$154.62
Expenditures
$104,057
$113,062
$122,853
$133,486
$72,520
$545,979
Caretaker Adults with 18 Year Old
SFY 2022
SFY 2023
SFY 2024
SFY 2025
July-Dec 2021
Total
Member months
38,733
42,540
46,722
51,315
56,359
PMPM Cost
$605.39
$641.71
$680.21
$721.02
$764.28
Expenditures
$23,448,557
$27,298,619
$31,780,876
$36,999,099
$43,074,209
$162,601,359
Project Goals and Evaluation Plan
The PMAP+ waiver provides longstanding authorities for Minnesota’s Medicaid program including preserving eligibility methods currently in use for children ages 12 to 23 months and simplifying the definition of a parent or caretaker adult to include people living with child(ren) under age 19. This waiver request also seeks continued federal authority to provide full Medical Assistance benefits for pregnant women during the period of presumptive eligibility and to fund graduate medical education through the Medical Education Research Costs (MERC) trust fund.
A goal of the demonstration is to provide comparable access and quality of care to these three waiver populations (MA One-Year-Olds, Caretaker Adults with an 18 year old, and Pregnant Women) as compared to Minnesota’s other public health care program enrollees in managed care. The evaluation uses selected HEDIS performance measures, national Medicaid NCQA Quality Compass rates data, and MMIS claims data to compare access and quality of care under the demonstration to that of Medicaid managed care enrollees in Minnesota and to that of other states in the nation.
Another goal of the demonstration is to continue to provide a dedicated trust fund for graduate medical education that will support training activities which help to maintain or increase the number of primary care providers serving the Medicaid population in Minnesota. The PMAP evaluation will use MERC program data and Medicaid provider enrollment data to determine whether the number of students and residents at training sites was maintained in rural and urban areas and how the MERC fund grantees used the payments. The evaluation will also determine whether the ratio of rural to urban primary care providers was maintained or improved and whether the ratio of providers to beneficiaries was maintained or improved in urban and rural areas of the state.
Waiver and expenditure authorities
The state is requesting approval of the same waiver and expenditure authorities as those approved under the current demonstration. These are as follows:
Title XIX Waivers
Redeterminations for Caretaker Adults Section 1902(a)(17)
To the extent necessary to enable the state to not perform a redetermination of the basis of eligibility for caretaker adults with income at or below 133 percent of FPL because they assume responsibility for and live with a child age 18 who is not a full time student in secondary school.
Expenditure Authorities
Expenditures for Medicaid coverage for children from ages 12 months through 23 months, who would not otherwise be eligible for Medicaid, with income above 275 percent and at or below 283 percent of the federal poverty level (FPL).
Expenditures for Medicaid coverage for pregnant women described in section 1902(a)(47) of the Act, to the extent that services are provided during a hospital presumptive eligibility period, that are in addition to ambulatory prenatal care services.
Expenditures for payments made directly to medical education institutions or medical providers and restricted for use to fund graduate medical education (GME) of the recipient institution or entity through the Medical Education and Research Costs (MERC) trust fund. In each demonstration year, payments made under this provision are limited to the amount claimed for federal financial participation (FFP) under this demonstration as MERC expenditures for state fiscal year (SFY) 2009. Except as specifically authorized in the STCs, the state may not include GME as a component of capitation or as a basis for other direct payment under the State plan. This expenditure authority will be subject to changes in federal law or regulation that may restrict the availability of federal financial participation for GME expenditures.
Requirements Not Applicable to the Expenditure Authorities
Managed Care Payment, Section 1903(m)(2)(A)(ii) and Section 1902(a)(4)
To the extent necessary to allow the state to make payments directly to providers, outside of the capitation rate, for GME and other medical education through the MERC trust fund.
The PMAP+ waiver special terms and conditions require the state to provide updates to CMS on the program’s implementation. We submit reports quarterly and annually. Reports from prior demonstration years have been archived and can be made available by request via dhs.waiver.comments@state.mn.us.
PMAP+ Demonstration Year 21 (July 1, 2015 - June 30, 2016)
The MFPP was implemented beginning July 1, 2006, as a federal waiver demonstration project approved by CMS. The MFPP waiver gave Minnesota the authority to receive federal matching funds for family planning services delivered to men and women, ages 15 to 50, who have family incomes at or below 200 percent of the federal poverty level and who are not enrolled in Medical Assistance or MinnesotaCare. The 2014 Minnesota Legislature directed DHS to seek federal authority to operate the MFPP under the Medicaid state plan. Effective Jan. 1, 2017, the program was converted to state plan authority under the Family Planning State Plan Option.
Under the Family Planning State Plan Option, the following MFPP benefits and other criteria will remain unchanged:
MFPP benefits will be unchanged;
Presumptive eligibility determinations through approved providers will continue;
The income of parents, spouses or sponsors will continue to be disregarded for applicants and enrollees under the age of 21, and only the income of the applicant or enrollee under age 21 will be counted;
Modified adjusted gross income (MAGI) methods will continue to apply; and
The income limit will remain at 200 percent of the federal poverty guidelines.
Please see Bulletin #16-21-13 (PDF) for more information regarding changes to certain eligibility rules for the MFPP under the Family Planning State Plan Option.
In October 2013, CMS approved Minnesota’s Reform 2020 section 1115 demonstration project through June 30, 2018.
The five-year demonstration provides federal support for the Alternative Care program, which provides supports to help seniors at risk of nursing home placement to stay in their homes. The Reform 2020 demonstration waiver will also provide access to expanded self-directed options under the Community First Services and Supports (CFSS) program for people who would not otherwise be eligible for these services. Implementation of this part of the demonstration is contingent upon federal approval of additional state plan and waiver authority.
On July 10, 2017, DHS submitted a request to CMS to renew the Reform 2020 Section 1115 waiver. The current waiver expires June 30, 2018. The renewal request seeks to continue the current waiver for another three-year period, through June 30, 2021.
A 30-day public comment period from May 22, 2017, to June 21, 2017, was held by DHS to provide the public the opportunity to weigh in on the proposed waiver renewal.
The Reform 2020 waiver special terms and conditions require the state to provide updates on the program’s implementation to CMS. Reports are submitted on a quarterly and annual basis. Reports from prior demonstration years have been archived and can be made available by request via dhs.waiver.comments@state.mn.us.
Reform 2020 Demonstration Year III (July 1, 2015 - June 30, 2016)
Request for comments on the revised IHB of Minneapolis Section 1115 Medicaid waiver application
A 30-day comment period on the revised Indian Health Board of Minneapolis (IHB), section 1115 Medicaid waiver application, began on April 17. The IHB waiver application was initially submitted to the Centers for Medicare & Medicaid Services (CMS) on Jan. 13, 2017. Key changes can be found on page 5 of the application, which has been revised to include information on the research hypothesis and evaluation parameters related to the demonstration’s proposed goals. DHS plans to submit the revised request in May of 2017.
Comments received will be posted on the DHS website. To ask for a paper copy of the waiver request, please contact Elizabeth Bonnell at 651-431-2836. Written comments may be submitted to dhs.waiver.comments@state.mn.us or by mail to the address below. DHS would like to provide copies of comments received in a format that is accessible for people with disabilities. Therefore, we request comments be submitted in Microsoft Word documents or incorporated within the email text. If you would like to provide a signed copy of the comment letter, you may submit a second copy in Adobe PDF format or mail it to the address below. Comments must be received by May 16, 2017.
The 2016 Minnesota State Legislature directed DHS to seek federal waiver authority to allow tribal organizations to receive the Indian Health Services encounter rate for Medicaid services provided to American Indian and Alaskan Native populations. Only organizations that are dually certified as Urban Indian Health Programs and Federally Qualified Health organizations qualify. The Legislature also asked DHS to seek authority for the state to be eligible for 100 percent federal financial participation for such services. (See Minn. Stat. § 256B.0625, specifically subdivisions 30 and 34.)
On Jan. 13, 2017 DHS submitted the Indian Health Board of Minneapolis Section 1115 waiver request to the Centers for Medicare & Medicaid Services (CMS). Currently, the Indian Health Board of Minneapolis (IHB) is the only entity eligible under this waiver authority, should it be granted by CMS. As a demonstration project under section 1115 of the Social Security Act, DHS plans to test new ways to help urban American Indians served by the IHB to access quality health care. This approach includes the use of an abbreviated application process for American Indians eligible for Medicaid and targeting additional funding for the IHB into enhanced care coordination and application assistance for this population.
The MSC+ waiver allows Minnesota to require seniors to enroll in managed care to receive Medicaid services. This includes people who are dually eligible for both Medicaid and Medicare and who have not opted to enroll in Minnesota Senior Health Options (MSHO). The waiver operates in combination with Minnesota’s existing Elderly Waiver to enable the integration of community-based long-term care services into the managed care service delivery system.
The CCDTF waiver allows recipients to be directed to a provider designated by the locality. While the state has developed a transition plan to move toward a direct-access model for people seeking SUD services, it is expected that implementation will require a phased-in approach. Therefore, the CCDTF waiver has been extended while the transition to a direct-access model is completed.
The Case Management waiver allows Minnesota to continue to limit case management providers for the home and community-based waivers to counties and tribes under contract with DHS or their subcontractors. The waiver applies only to enrollees whose waiver services are covered fee-for-service and who receive services under one of the following Section 1915(c) home and community-based waiver programs:
Developmental Disabilities Waiver (DD)
Elderly Waiver (EW)
Community Access for Disability Inclusion (CADI) Waiver
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