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Pennsylvania Keystones of Health Section 1115 Demonstration Approval Period: December 26, 2024 through December 31, 2029 Page 42 of 90 the independent assessor consult with key stakeholders including, but not limited to: providers participating in the state’s Reentry Demonstration Initiative, eligible individuals, and other key partners in correctional facility and community settings. For milestones and measure targets at medium to high risk of not being achieved, the state and CMS will collaborate to determine whether modifications to the Reentry Demonstration Initiative Implementation Plan and the Monitoring Protocol are necessary for ameliorating these risks, with any modifications subject to CMS approval. Elements of the Mid-Point Assessment must include, but not be limited to: a. An examination of progress toward meeting each milestone and timeframe approved in the Reentry Demonstration Initiative Implementation Plan and toward meeting the targets for performance metrics as approved in the Monitoring Protocol; b. A determination of factors that affected achievement on the milestones and progress toward performance metrics targets to date; c. A determination of factors likely to affect future performance in meeting milestones and targets not yet met and information about the risk of possibly missing those milestones and performance targets; and d. For milestones or targets at medium to high risk of not being met, recommendations for adjustments in the state’s Reentry Demonstration Initiative Implementation Plan or to pertinent factors that the state can influence that will support improvement. CMS will provide additional guidance for developing the state’s Reentry Initiative Mid-Point Assessment. 10.7. Corrective Action Plan Related to Demonstration Monitoring. If monitoring indicates that demonstration features are not likely to assist in promoting the objectives of Medicaid, CMS reserves the right to require the state to submit a corrective action plan to CMS for approval. A corrective action plan could include a temporary suspension of implementation of demonstration programs in circumstances where monitoring data indicate substantial and sustained directional change inconsistent with demonstration goals, such as substantial and sustained trends indicating increased difficulty accessing services. A corrective action plan may be an interim step to withdrawing waivers or expenditure authorities, as outlined in STC 3.10. CMS will withdraw an authority, as described in STC 3.10, when metrics indicate substantial, sustained directional change inconsistent with the state’s demonstration goals, and the state has not implemented corrective action. CMS further has the ability to suspend implementation of the demonstration should corrective actions not effectively resolve these concerns in a timely manner. 10.8. Close-Out Report. Within 120-calendar days after the expiration of the demonstration, the state must submit a draft Close-Out Report to CMS for comments. a. The draft Close-Out Report must comply with the most current guidance from CMS.