NHeLP Comments on Massachusetts’ Sec. 1115 Waiver Project

Executive Summary

In comments to the U.S. Department of of Health and Human Services (HHS), NHeLP urges it to reject Massachusetts’ Section 1115 waiver project because the state proposes changes to Medicaid that would undermine the purpose of law and harm low-income people who need Medicaid for health care. Massachusetts seeks to waive the requirement to cover non-emergency medical transportation (NEMT) for non-disabled adults in its MassHealth population and end provisional income eligibility.

NHeLP argues that the “state does not provide meaningful evidence to justify this waiver of this important Medicaid benefit, which is specifically aimed at reducing important barriers to care for low-income populations. That is, NEMT is one of various benefits that tailors Medicaid coverage to meet the unique needs of low-income populations, which is why it should differ from commercial insurance.”