On December 20, 2018, AHIP submitted comments on the Administration’s guidance on State Relief and Empowerment Waivers, also known as section 1332 state innovation waivers.
Our letter generally expresses support for providing more flexibility for states, while also expressing appreciation for efforts by the Centers for Medicare & Medicaid Services (CMS) to streamline the approval of waiver applications to implement reinsurance programs. We support CMS’ emphasis on promoting choice, competition, and multiple options for consumers. However, we oppose the use of pass-through funding for short-term, limited duration insurance plans or other alternative coverage options.