Print Friendly and PDFPrinter Friendly Version

Fact Sheet
January 2019

State Plan Amendment vs Medicaid 1115 Waiver Process and Timelines

As more states consider expanding Medicaid, it is important for legislators and policy-makers to understand that adding expansion features which require federal approval—like a work requirement —will delay people from receiving health coverage, and the state’s receipt of any enhanced federal matching funds.

Requiring waiver approval by the Centers for Medicare & Medicaid Services (CMS) before implementing Medicaid expansion will add significant delays. Table 1 shows the steps required to approve a Medicaid expansion through an 1115 waiver versus a straight state plan amendment (SPA). An 1115 waiver is required to include a work requirement or enrollee reporting requirements, among other elements, whereas a SPA is the mechanism for how states expand Medicaid if the program changes do not require federal approval.

This fact sheet provides advocates and policymakers a step-by-step overview comparing the approval process and timeline to get a SPA vs. Medicaid 1115 Waiver approved. 

It is part of the Medicaid Expansion Leadership Team's Medicaid Expansion Toolkit.