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Wisconsin BadgerCare Reform Approval Period: October 29, 2024 through December 31, 2029 Page 16 needed to bring the deliverable into alignment with CMS requirements. b. CMS will issue a written notification to the state providing advance notification of a pending deferral for late or non-compliant submissions of required deliverables c. For each deliverable, the state may submit to CMS a written request for an extension to submit the required deliverable that includes a rationale for the cause(s) of the delay and the state’s anticipated date of submission. Extension requests that extend beyond the current fiscal quarter must include a Corrective Action Plan (CAP). Should CMS agree in writing to the state’s request, a corresponding extension of the deferral process described below can be provided. If the state’s request for an extension includes a CAP, CMS may agree to or further negotiate the CAP as an interim step before applying the deferral. d. If CMS agrees to an interim corrective plan in accordance with subsection 8.1.2, and the state fails to comply with the corrective action plan or, despite the corrective action plan, still fails to submit the overdue deliverable(s) with all required contents in satisfaction of the terms of this agreement, the deferral would be issued against the next Quarterly Statement of Expenditure reported in Medicaid Budget and Expenditure System (MBES/CBES) following a written deferral notification to the state. following the written deferral notification. e. If the CMS deferral process has been initiated for state non-compliance with the terms of this agreement with respect to required deliverable(s), and the state submits the overdue deliverable(s), and such deliverable(s) are accepted by CMS as meeting the requirements specified in these STCs, the deferral(s) will be released. When the state submits the overdue deliverable(s) that are accepted by CMS, the deferral(s) will be released. f. As the purpose of a section 1115 demonstration is to test new methods of operation or services, a state’s failure to submit all required deliverables may preclude a state from renewing a demonstration or obtaining a new demonstration.

8.2. Deferral of Federal Financial Participation (FFP) from IMD Claiming for Insufficient Progress Toward Milestone. Up to $5,000,000 in FFP for services in IMDs may be deferred if the state is not making adequate progress on meeting the milestones and goals as evidenced by reporting on the milestones in the Implementation Plan and the required performance measures in the Monitoring Protocol agreed upon by the state and CMS. Once CMS determines that state has not made adequate progress, up to $5,000,000 will be deferred in the next calendar quarter and each calendar thereafter until CMS has determined sufficient progress has been made.

8.3. Submission of Post-approval Deliverables. The state must submit all deliverables as stipulated by CMS and within the timeframes outlined within these STCs.

8.4. Compliance with Federal Systems Updates. As federal systems continue to evolve and incorporate additional 1115 waiver reporting and analytics functions, the state will work with CMS to: a. Revise the reporting templates and submission processes to accommodate timely compliance with the requirements of the new system;