MDH opens public comment on Section 1115 HealthChoice Demonstration Waiver Amendment


Nicole Pasia


The Maryland Medicaid Administration under the Department of Health (MDH) is currently accepting public comment this month on its Section 1115 HealthChoice Demonstration Waiver Amendment. The amendment looks to establish statewide coverage of two pilot programs—the Alternative Destination Pilot and Adult Dental Pilot—by transitioning them into the Maryland Medicaid State Plan. These changes come after the Maryland General Assembly recently passed legislation to extend these benefits. 


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Alternative Destination Pilot (ADP)

Maryland received CMS approval in December 2021 to implement the ADP in three Maryland jurisdictions (Baltimore City, City of Annapolis, and Montgomery County) as part of the five-year Emergency Triage, Treat, and Transport (ET3) Program. 

Under the ET3 Program, ambulance providers can transport a patient to an alternative destination (such as an urgent care clinic) rather than an emergency department (ED), if appropriate to the patient’s need. Providers would receive the same reimbursement as the fee-for-service rate for transportation to an ED. 

MDH began initial planning to implement the ADP and have it operational by July 2022. However, the General Assembly passed SB 295 this past legislative session, which requires MDH to cover ADP services. The bill appropriates at least $8.4 million in total FY 2023 funding to Medicaid for this coverage. 

“In lieu of implementing a really short-term pilot, we’re actually shifting all of our energies to focusing on statewide implementation of coverage through the State Plan,” said Alyssa Brown, Director of the MDH Office of Innovation, Research, and Development at a recent Medicaid advisory meeting. “We are anticipating a go-live date for that new benefit on or around January 1st, 2023.”

The waiver amendment further clarifies that this change will have no impact on Medicaid participants, as the pilot project had not yet been implemented. 

Adult Dental Coverage

Individuals aged 21-64 who are dually eligible for Medicaid and Medicare currently receive coverage for dental services through the Adult Dental Pilot Program. There is also an annual cap of $800 per enrollee for the services they receive. HB 6/SB 150, which also passed this session, will remove the cost cap and expand these services to all Medicaid-eligible adults beginning January 1st, 2023. 

Beneficiaries will also receive coverage for a greater array of dental services due to the expansion, similar to the package offered to pregnant women on Medicaid. These services include “enhanced restorative services including crowns, more comprehensive oral and maxillofacial surgery services, as well as endodontic and periodontic services,” according to the waiver amendment.

“We’re estimating that over 800,000 new adults will be eligible for dental benefits as a result of these changes,” Brown said. 

MDH’s 30-day public comment period on the waiver amendment ends on June 25th, 2022. Comments can be emailed to [email protected] or via hard copy to: Tricia Roddy, Deputy Medicaid Director, Office of Healthcare Financing, Maryland Department of Health 201 West Preston Street, Room 224 Baltimore, Maryland 21201.