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Families USA State Comment Letter on Tennessee Block Grant 1115 Amendment

Families USA submitted this letter in response to Tennessee’s request for comments on its proposed application to amend its section 1115 Medicaid waiver to add a block grant and additional flexibilities to generate federal savings by cutting beneficiary protections.

As noted in a Families USA analysis, the proposal, entitled “Amendment 42,” is a radical restructuring of the state’s Medicaid program (TennCare) that will harm women, children, and elderly Tennesseans. If approved by the Trump administration, the state would be given authority under section 1115 of the Social Security Act to waive statutory requirements for the financial structure of its Medicaid program.

Multiple elements of Tennessee’s proposal are both legally problematic and poor policy choices for the state. Block granting Medicaid greatly exceeds what is allowable under section 1115 authority and the state’s proposed amendment does not promote the objectives of Medicaid—indeed it poses a grave threat to Medicaid coverage in Tennessee. The proposal would create overwhelming financial incentives for the state to cut Medicaid eligibility and benefits. Furthermore, the proposal fails to address the significant issues currently facing the state’s program.

Families USA recommends that Tennessee should not submit its application to CMS. Read the rest of our comment here.