Families USA Submits Comments On the Iowa Health and Wellness Plan 1115 Demonstration Amendment

Families USA urges the Centers for Medicare and Medicaid Services (CMS) to delay decision making on the proposed IHAWP amendment, to provide time after the passage of the new federal law to do the proper analysis and promulgate regulations appropriately across states, and to deny the Iowa proposal as violating several provisions of that law.

Under this waiver proposal, the Iowa Department of Health and Human Services (Iowa HHS) will deny low-income Iowans access to Medicaid coverage if they cannot meet onerous paperwork requirements to prove they are engaged in work or other qualifying activities for 100 hours per month. What Iowa proposes to do is the same as what all states who establish work reporting requirements intend to do: push eligible residents off health coverage.

Families USA stands ready to engage with CMS on the pathway forward to ensure implementation guidance both respects Congressional intent under H.R. 1 and mitigates harms for state health care systems and the people who must comply with new paperwork burdens under the law.