In general, NAELA conditionally supports the proposal to allow states to expand eligibility for one or more non-MAGI subpopulations in a targeted manner. However, in reference to the brief discussion in the proposed rule that the proposed subpopulation be “reasonable” and “not violate other Federal statutes,” NAELA asks CMS to provide additional guidance to states and stakeholders on the guardrails associated with this flexibility, so that it is clear that a state plan amendment (and underlying state action) will not result in contracting any non-MAGI subpopulations’ Medicaid eligibility. Read NAELA’s full letter
here.