Families USA’s Federal Comment Letter On Oklahoma’s Soonercare 2.0 1115 Waiver

Families USA submitted this letter in response to the Centers for Medicare & Medicaid Services’ request for comments on Oklahoma’s proposed section 1115 waiver to institute a work reporting requirement as well as a per capita cap that limits federal funding for the state’s Medicaid program. Oklahoma’s waiver proposal follows recent guidance from CMS that allows states to fundamentally alter their Medicaid program by instituting block grants and per capita caps. Additionally, Oklahoma is proposing new premiums and copayments, benefit cuts, and the elimination of retroactive and presumptive eligibility for beneficiaries.

Oklahoma’s proposed 1115 waiver is legally problematic, incomplete, and a bad policy decision for the state, especially during the current COVID-19 public health crisis. Families USA recommends that CMS reject this waiver proposal. Instead of making cuts and limiting coverage for needy beneficiaries, Oklahoma should expand its Medicaid program and make sure everyone in the state can access testing and treatment during this pandemic.