Letter Calls on Seema Verma to Reject Oklahoma’s Section 1115 Request as Incomplete

Executive Summary

In an April 23rd letter to Seema Verma, the Administrator of the Centers for Medicare & Medicaid Services, the National Health Law Program asked the Administrator to withhold issuing a letter of completeness for Oklahoma’s Section 1115 SoonerCare 2.0 application. A letter of completeness would trigger federal review of the project. As proposed, SoonerCare 2.0 would impose coverage restrictions, including work requirements, and transform Medicaid from entitlement to per capita funding.

On March 17, 2020, the National Health Law Program wrote to Administrator Verma asking her to require the State to postpone the public comment process for this application due to the COVID-19 emergency. The State did not do that, and instead held four “virtual” meetings. As explained in the letter, these meetings failed to satisfy the State’s public comment obligations under Section 1115 and CMS’s implementing regulations and disproportionately excluded the low-income individuals most likely affected by the project.

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