February 28, 2020 Administrator Seema Verma Centers of Medicare and Medicaid Department of Health and Human Services Washington, DC 20201 Dear Administrator Verma: As leading national, state, and local organizations, representing health care consumers and patients, providers, and other stakeholders, we are writing in strong opposition to recent guidance from CMS, Healthy Adult Opportunity, which allows states to fundamentally change the nature of their Medicaid programs. We urge the Administration to rescind this guidance, which could hurt millions of families that rely on Medicaid. Medicaid is an essential source of coverage for over 70 million people. Medicaid’s current state-federal partnership helps states provide quality health insurance to their residents – it ensures that children are able to get a healthy start in life, provides long-term care to seniors and people with disabilities, and vital health care for many adults including pregnant women. The current state-federal funding structure provides states and taxpayers a level of financial security, ensuring that as Medicaid spending fluctuates from year to year, the state and its taxpayers are not made solely responsible for covering any increased costs. Efforts to restructure or cut Medicaid would shift health care costs to the states, hurt local economies, and threaten care and coverage for millions. The Administration’s long-anticipated State Medicaid Director Letter, which was published on January 30, encourages states to adopt caps on their federal Medicaid funds voluntarily under a Medicaid section 1115 demonstration waiver. This arrangement involves major fiscal risk for states; the “flexibility” states will have is to cut services or take away coverage if and when they hit their new federal funding cap. Capping and restructuring Medicaid would create an awful choice for states in the event of increasing health care costs. Once that happens, the state will start rolling back coverage for kids, people with disabilities, and seniors and cost- effective optional benefits like dental care, without oversight. Further, the Administration does not have jurisdiction to waive Medicaid’s financing structure through the 1115 waiver process. Such a fundamental change to Medicaid’s structure requires a change in statute and therefore an act of Congress. In 2017, when Congress considered federal funding caps, millions of people from around the country raised their voices in opposition, and lawmakers rejected the proposal on a bipartisan basis. We urge the Administration to rescind this guidance that promises flexibility, but will surely lead to catastrophic implications for state budgets, and state Medicaid programs and the communities they serve. We implore you to reconsider this proposal, and protect the children, seniors, people with disabilities, women, parents, people of color, and working families that rely on Medicaid for health care. Sincerely, National Organizations Families USA ACCESS 1,000 Days ADAP Advocacy Association AARP AFL-CIO ACA Consumer Advocacy African American Health Alliance 1 Aging Life Care Association Global Justice Institute, Metropolitan Community Churches AIDS United Go2Foundation for Lung Cancer Allergy & Asthma Network Health Care for American Now (HCAN) American Academy of Pediatric Dentistry Health Over Profit for Everyone American Association of Public Health Dentistry HealthConnect One American Association on Health and Disability Healthy Schools Campaign American Federation of State, County & Municipal Hispanic Federation Employees HIV Medicine Association American Federation of Teachers Human Rights Campaign American Medical Student Association International Ventilator Users Network American Muslim Health Professionals Jewish Federations of North America American Physical Therapy Association Justice in Aging American Public Health Association Labor United for Class Struggle/Labor Today American Speech-Language-Hearing Association Lakeshore Foundation Americans for Democratic Action (ADA) Little Lobbyists Asian & Pacific Islander American Health Forum Lupus and Allied Diseases Association, Inc. Association of Asian Pacific Community Health Organizations Lutheran Services in America Association of Asthma Educators March for Moms Association of School Business Officials International Meals on Wheels America Asthma and Allergy Foundation of America Medicare Rights Center Autism Society of America Ministry Across Generations Team, Disciples Home Missions, Autistic Self Advocacy Network Christian Church (Disciples of Christ) Bazelon Center for Mental Health Law MomsRising Bruderhof Movement for Peoples’ Democracy Campaign for America's Future MoveOn Caring Across Generations NAACP Center for Law and Social Policy (CLASP) NALLTCO (National Association of Local Long Term Care Center for Medicare Advocacy Ombudsman) Center for Public Representation NASTAD Center for the Study of Social Policy National Academy of Elder Law Attorneys Child Welfare League of America National Adult Day Services Association (NADSA) Children's Defense Fund National Advocacy Center of the Sisters of the Good Children's HealthWatch Shepherd Children's Hospital of Philadelphia National Alliance for Caregiving Children's Trust Fund Alliance National Alliance on Mental Illness Coalition for Disability Health Equity National Association for Children's Behavioral Health Coalition of Labor Union Women National Association for Home Care and Hospice Coalition on Human Needs National Association of Area Agencies on Aging (n4a) Community Access National Network (CANN) National Association of Councils on Developmental Community Catalyst Disabilities Congregation of Our Lady of the Good Shepherd, U.S. National Association of Pediatric Nurse Practitioners Provinces National Association of School Nurses Cystic Fibrosis Foundation National Association of Social Workers Disciples Center for Public Witness National Association of State Long-Term Care Ombudsman Easterseals Programs (NASOP) Faith in Healthcare National Center for Transgender Equality First Focus on Children National Coalition for the Homeless Friends Committee on National Legislation National Coalition on Health Care Futures Without Violence National Consumer Voice for Quality Long-Term Care 2 National Council of Jewish Women United Church of Christ Justice and Witness Ministries National Council on Independent Living United Way Worldwide National Crittenton URGE: Unite for Reproductive & Gender Equity National Equality Action Team Voices for Progress National Family Planning & Reproductive Health Association Women Creating Change National Latina Institute for Reproductive Health Women for Racial and Economic Equality National Multiple Sclerosis Society Young Invincibles National Partnership for Women & Families ZERO TO THREE National WIC Association National Women's Health Network Alabama National Working Positive Coalition AIDS Alabama NETWORK Lobby for Catholic Social Justice Alabama Academy of Pediatric Dentistry Network of Jewish Human Service Agencies Health Services Center, Inc. NMD United, Inc. Lighthouse Community Development Corp Nurse-Family Partnership National Association of Social Workers, Alabama Chapter One Health Resource Company Party of Communists USA Alaska Pathways for Rare and Orphan Studies Alaska Children's Trust Patient Advocate Bristol Bay Area Health Corporation Planned Parenthood Federation of America National Association of Social Workers, Alaska Chapter Positive Women's Network-USA Power to Decide Arizona Prevent Blindness Children's Action Alliance Provincial Council Clerics of St. Viator National Association of Social Workers, Arizona Chapter Public Advocacy for Kids West Valley Neighborhoods Coalition Public Citizen Raising Women's Voices for the Health Care We Need Arkansas Redstone Global Center for Prevention and Wellness Arkansas Advocates for Children and Families RESULTS Arkansas Community Institute Service Employees International Union Arkansas Community Organizations SIECUS: Sex Ed for Social Change National Association of Social Workers, Arkansas Chapter Sisters of Charity, BVM Sisters of Mercy of the Americas Justice Team California Sisters of St. Joseph of Cluny USA/Canada APLA Health Social Security Works Asian Law Alliance Society for Public Health Education Brighter Beginnings Society of Saint Vincent de Paul California Association of Food Banks SocioEnergetics Foundation California Consortium of Addiction Programs & Professionals The AIDS Institute California Coverage & Health Initiatives The Arc of the United States California Health Advocates The Augustinians California Pan-Ethnic Health Network The Coelho Center for Disability Law, Policy and Innovation County Welfare Directors Association of California The Global Justice Institute Equality California The Leadership Conference on Civil and Human Rights Jewish Family Service LA The National Alliance to Advance Adolescent Health Long Term Care Ombudsman Services of San Luis Obispo The National Center for Children in Poverty County Treatment Communities of America Los Angeles LGBT Center Trust for America's Health National Association of Social Workers, California Chapter Union for Reform Judaism NextGen California 3 Orange County United Way Idaho PathPoint Idaho Interfaith Roundtable Against Hunger San Francisco AIDS Foundation National Association of Social Workers, Idaho Chapter The Los Angeles Trust for Children's Health Illinois Colorado AgeOptions Center for Health Progress Champaign County Health Care Consumers