On July 29, Federal Medicaid authorities notified Texas Medicaid that their waiver extension application was complete. That started a 30-day federal comment period for the general public and stakeholders to submit comments to the Centers for Medicare and Medicaid Services (CMS) on the extension application.
The comment period is open through August 30, 2021, and comments can be submitted (and viewed) here.
Texas’ Medicaid officials were not required to submit the actual comments the agency received from Texans to the federal Medicaid officials at CMS — only to summarize them.
State comments that were submitted in June through the special Texas portal developed by SickOfItTX and Young Invincibles will be forwarded to federal Medicaid officials, to make sure that the diverse community voices raised in the state comment period are also heard in Washington, DC.
Plus, this new portal will allow more individuals and groups to comment directly to the federal Medicaid officials.
Organizations that submitted written comments to Texas HHSC are encouraged to:
- Submit your earlier state comments to CMS during the federal comment period, because the HHSC summary cannot fully capture all the issues raised in longer written comments; and
- Include an added update on any issues you feel the HHSC summary does not adequately convey to federal Medicaid officials. You can read the Texas HHSC summary of the public notice and comments included in the extension application summary on pages 52-62 of this HHSC document.
In Addition to Submitting Your Earlier Texas HHSC Comments, Please Consider:
- Thanking Secretary Becerra and CMS for prioritizing Transparency and Public Notice requirements for 1115 waivers, enabling this federal comment opportunity.
- Especially in light of current Congressional proposals to provide a “federal fall-back coverage” option for low-income adults left uninsured today in the non-expansion states, supporting compliance with federal law to limit the 1115 waiver extension period to less than 10 years (federal law says 3 years for extensions; full waiver renewals are historically limited to 5 years).
- Confirming your organization’s support for Texas Coverage Expansion under the 1115 waiver, and noting that the HHSC summary of state comments in its application to CMS did not convey the very high percentage of Texas commenters who support Coverage Expansion.
- Noting any other topics important to your organization that were not fully conveyed in the Texas HHSC summary.
- Reiterating that while UC pools — funding for free care to uninsured at hospitals, mental health clinics, and local health departments — and a favorable Budget Neutrality funding cap for Texas are needed, they are not an acceptable substitute for comprehensive medical coverage. Financing agreements with Texas (and other states) under the 1115 waiver should be carefully designed to ensure they in no way undermine or preclude the state’s progress toward coverage of adults up to 138% FPL.
Associate Director Anne Dunkelberg (email@example.com) is available to discuss these and other topics relating to the Federal Comments due by 8/30/2021.