Families USA Federal Comment Letter on TennCare III

Families USA submitted this letter in response to CMS’ request for comments on Tennessee’s Section 1115 demonstration that was approved in the final days of the Trump Administration.

Multiple elements of TennCare III are both legally problematic and poor policy choices for the state. The “aggregate cap” would cap the level of state expenditures that are eligible to receive federal matching funds, which will impact children, adults, elderly people, and disabled people. If state expenditures exceed this cap, Tennessee will be forced to choose between cutting benefits and coverage or raising taxes to cover the additional costs. Other provisions in the demonstration, such as the “shared savings mechanism” and the elimination of retroactive coverage, would harm TennCare beneficiaries by allowing the state to further cut benefits and coverage. These provisions undermine Medicaid’s objectives.

Families USA recommends CMS withdraws approval of TennCare III. Read the rest of our comment here.