CMS Ends Fast-Track Review Process for Medicaid 1115 Waiver Extensions
CMS announced July 7 that it is eliminating the fast-track review process for certain Medicaid section 1115 demonstration extensions, formally rescinding 2015 guidance that established the expedited pathway. The change stems from a July 2025 reconciliation bill requirement that the CMS chief actuary certify budget neutrality for all 1115 demonstrations, effective January 1, 2027. CMS stated the fast-track process would make it difficult to evaluate renewal applications under the new budget neutrality certification requirements. The bulletin did not specify when the elimination takes effect, but states should anticipate longer review timelines for waiver extensions.
Managed care organizations operating under 1115 waivers face increased uncertainty and longer approval timelines for waiver extensions, requiring earlier engagement with states on renewal planning and potential operational adjustments if extensions are delayed.
Managed Care · Finance
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