Comments to HHS on Michigan 1115 Waiver Project

Executive Summary

In comments to the U.S. Department of Health and Human Services, the National Health Law Program urges the department to reject Michigan’s Sec. 1115 Medicaid waiver application, because it would increase premiums and impose unlawful conditions of eligibility, including required healthy behavior and work-related activities.

In previous comments to HHS, the National Health Law Program has detailed why even the existing premiums and cost sharing structure decrease enrollment and access to care and should not have been approved. Subsequent evidence has shown that the existing premiums and healthy behavior policies are increasing medical debt and depressing enrollment. The proposed changes will only exacerbate these problems. Additionally, the proposed changes do not comply with § 1115 of the Social Security Act, as they will block, rather than facilitate, access to Medicaid coverage.

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