Association Executive Directors Community

Waiting on Section 1115 Guidance

  • 1.  Waiting on Section 1115 Guidance

    Posted 04-23-2020 16:12
    We just came off of a Maryland Medicaid call, getting detailed updates about the retainer payments going to DD providers via HCBS Appendix K, medical day providers, hospitals and health centers through various other mechanisms. When asked about retainer payments for behavioral health, our state authorities indicated:
    • CMS has not responded to the National Association of Medicaid Directors' letter about retainer payments;
    • CMS appears to have communicated to states that the Washington state section 1115 waiver for retainer payments is limited to personal care and habilitation ... and it intends to keep any other retainer payments within those parameters as well.

    Is Maryland's characterization of CMS's position in line with what other states are hearing?

    Can we get an update -- and support in any way -- National Council advocacy to CMS on the 1115 waiver option for retainer payments?

    Maryland Medicaid seemed quite clear that unless CMS changes its tune, we're on our own.


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    Shannon Hall
    Executive Director
    Community Behavioral Health Association of Maryland
    Catonsville MD
    410-788-1865 ext 2
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