Public comment period open for draft Medicaid waiver renewal application


Emily Boerger


The Oregon Health Authority (OHA) opened the public comment period for the state’s draft 1115 waiver renewal application on Tuesday, signaling the latest step forward in the state’s effort to reform the Oregon Health Plan (OHP). OHA is preparing to submit the new five-year Medicaid program waiver to the Centers for Medicare & Medicaid Services (CMS) in February 2022. 


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The new waiver, which would be in effect from 2022-2027, focuses on improving health equity within the Medicaid program. Concept papers released last month identified the five policy concepts that form the basis of the application. They include a focus on maximizing OHP coverage, stabilizing transitions to minimize disruptions in care, value-based global budgets, incentivizing equitable care, and focusing on equity investments. 

The public notice highlighting the public comment period lays out the state’s specific requests related to health equity. 

Through the waiver, the state is requesting authority to allow coordinated care organizations (CCOs) to spend 3% of their per-member per-month capitation rate on health equity investments, and for those to be counted as medical expenses when determining rates. The state is also requesting federal spending for infrastructure to support equity, and investments to support community-led equity interventions. 

The state is looking to change the process of selecting CCO incentive metrics to focus on equity and is requesting an expanded benefit for American Indian/Alaska Native OHP members so that Tribal-based practices are considered covered services. 

These are just a few of the many changes to the program that OHA is seeking public comment on. 

The public comment period will run from Dec. 7 through Jan. 7. The public can submit written comments through email at [email protected] or through 

The feedback will then be used to revise the draft and prepare it for final submission to CMS in February.