October 6, 2022 — Comments

Comments to the U.S. Department of Health and Human Services

In previous comments filed on September 8, 2021, NCLC raised several concerns about aspects of the proposed TennCare III waiver, i.e., that the Tennessee Medicaid program should not waive the 90-day retroactive eligibility period for Medicaid applicants, should not be designed as a block grant, should not impose an aggregate cap on spending, and should provide comprehensive coverage to children with special health care needs rather than requiring these children to enroll through commercial managed care organizations. In its current waiver application, Tennessee still seeks a waiver of retroactive coverage, and asks that the waiver remain in place for up to 10 year.

NCLC continues to oppose this request for waiver of retroactive Medicaid coverage, as well as similar requests in other states for the waiver of this important protection.