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Building and Transforming Coverage, Services and Supports for a Healthier Virginia Approval Period: August 1, 2026 through December 31, 2031 Page 27 of 51

3. A determination of selected 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; 4. For milestones or targets identified by the Independent Assessor as at medium to high risk of not being met, recommendations for adjustments in the state’s Implementation Plan, or to pertinent factors that the state can influence that will support improvement. 37. Corrective Action. If monitoring indicates that demonstration features are not likely to assist in promoting the objectives of Medicaid, CMS might require the state to submit a corrective action plan to CMS for approval. A state 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 10. CMS might withdraw an authority, as described in STC 10, if metrics indicate substantial and sustained directional change inconsistent with the state’s demonstration goals, the state has not implemented corrective action, and the circumstances described in STC 10, are met. CMS further has the ability to suspend implementation of the demonstration should corrective actions not effectively resolve these concerns in a timely manner.

38. Close Out Report. No later than the first business day following 120 calendar days after the expiration of the demonstration, the state must submit a draft Close-Out Report to CMS for comments. a. The Close-Out Report must comply with the most current guidance from CMS. b. In consultation with CMS, and per guidance from CMS, the state will include an evaluation of the demonstration (or demonstration components) that are to phase out or expire without extension along with the Close-Out Report. Depending on the timeline of the phase-out during the demonstration approval period, in agreement with CMS, the evaluation requirement may be satisfied through the Interim or Summative Evaluation Reports stipulated in STCs 73 and 74, respectively. c. The state will present to and participate in a discussion with CMS on the Close–Out Report. d. The state must take into consideration CMS’s comments for incorporation into the final Close-Out Report. e. A revised Close-Out Report is due to CMS no later than the first business day following 30 calendar days after receipt of CMS’s comments. f. A delay in submitting the draft or final version of the Close-Out Report may subject the state to penalties described in STC 31.

39. Monitoring Calls. CMS will convene, no less frequently than quarterly, monitoring calls