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Letter to the Hon. Seema Verma, Administrator for the Centers for Medicare and Medicaid Services - Approve Illinois's 1115 Medicaid Waiver

Dear Administrator Verma:

In order to enhance the delivery of behavioral health care to the more than three million Illinoisans who depend on Medicaid, the State of Illinois submitted a Section 1115 Medicaid Demonstration Waiver to the Centers for Medicare and Medicaid Services (CMS) in October 2016. Illinois's waiver--an important initiative to address the opioid epidemic and improve mental health that has broad support within the state--has been pending at CMS for fourteen months, despite your commitment to streamlining the 1115 waiver process. We write to urge you to promptly approve the 1115 waiver that the state submitted last year.

Illinois's 1115 waiver aligns with the nationwide shift towards value-based and integrated care and is guided by an emphasis on prevention, targeting the highest service utilizers, expanding efforts to support whole-person wellness, coordinating services between providers and systems, and prioritizing the delivery of health care services in the most effective, low-cost setting. In particular, we support provisions of the waiver that help address the ongoing heroin and prescription opioid epidemic, including the furnishing of services and automatic enrollment in Medicaid for justice-involved individuals prior to release from incarceration, and expanding coverage for residential substance use disorder treatment in facilities presently inhibited by the outdated Institutions for Mental Disease (IMD) Exclusion. We also strongly support 1115 waiver provisions that promote supportive housing, employment assistance, and two-generational care for children and families who are exposed to trauma, such as witnessing violence.

To meet the needs of Illinoisans, the 1115 waiver aims to reflect CMS' own stated principles: to strengthen coverage, expand access to providers, improve health outcomes, increase the efficiency and the quality of care for individuals, and remain budget neutral. We urge you to protect beneficiary access to care by quickly approving the 1115 waiver, submitted last year, under Medicaid's existing structure. We also strongly urge you to work collaboratively with the state on appropriate and flexible funding strategies, including through innovative Delivery System Reform Incentive Payments and Designated State Health Program (DSHP) mechanisms. Though we are aware of CMS' recent announcement regarding DSHP funding, given that the state of Illinois submitted its 1115 waiver application in October 2016--fourteen months ago--we expect that any recent policy changes or reinterpretations by CMS would be implemented thoughtfully with states, and not unfairly punish our constituents through added delays, funding losses, benefit reductions, or new barriers to care.

We appreciate your engagement with the State of Illinois as you evaluate its 1115 waiver application. In the height of the opioid epidemic--that is killing nearly 2,000 Illinoisans each year--we urge you to expeditiously approve Illinois's 1115 waiver, which would give the state new tools to respond to this crisis and broader behavioral health needs.


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