The Need for Evaluations of Medicaid 1115 Demonstrations that Restrict Eligibility

Plans for evaluating the impacts of Medicaid Section 1115 demonstration programs are a core requirement under the law. Yet the Centers for Medicare and Medicaid Services (CMS) has permitted the nation’s first-ever Medicaid work demonstration to proceed despite the fact no approved evaluation to test the impact of the requirements is underway, points out a team of researchers led by Sara Rosenbaum, JD, the Harold and Jane Hirsh Professor of Health Law and Policy at George Washington University (GW) in a Commonwealth Fund Issue Brief.

“Section 1115 is not simply a grant of power to run alternative Medicaid programs; it is an experimental statute that permits demonstrations designed to promote program objectives and ensures that their results are properly evaluated,” Rosenbaum and colleagues at the GW Milken Institute School of Public Health write. “Because the authority that 1115 confers is experimental, the Health and Human Services secretary is obligated to carry out ‘periodic evaluation[s]’ of approved experiments, so policymakers can determine whether they are indeed promoting Medicaid’s purpose.”

The brief goes on to explain what Medicaid waiver evaluations evaluate. It points out that the Government Accountability Office’s examination of Section 1115 evaluations found that they have been “neither complete nor timely.”

Of the four states that had received approvals to conduct Section 1115 work experiments, only Arkansas had submitted evaluation plans for approval by November 2018. The other three, Indiana, Kentucky and New Hampshire, had not.

“With thousands in Arkansas losing their Medicaid benefits under the state’s work requirement demonstration, the importance of evaluating such experiments could not be clearer,” the Milken Institute School of Public Health researchers say.

In addition to Rosenbaum, the authors of “Will Evaluations of Medicaid 1115 Demonstrations That Restrict Eligibility Tell Policymakers What They Need to Know?” are Maria Velasquez, MPH; Rachel Gunsalus, MPH; Rebecca Morris; and Alexander Somodevilla, JD.