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Page 4 – Ms. Lisa Olson

CMS has determined that this Wisconsin COVID-19 Vaccine Administration PHE amendment to its section 1115 demonstration titled, “Wisconsin SeniorCare” is necessary to assist the state in delivering the most effective care to its beneficiaries in light of the COVID-19 PHE. The demonstration is likely to assist in promoting the objectives of the Medicaid statute because it is expected to help the state furnish medical assistance in a manner intended to protect, to the greatest extent possible, the health, safety, and welfare of individuals and providers who may be affected by COVID-19. Ensuring that there is broad coverage for COVID-19 vaccinations, including in circumstances where section 1903(b)(1) would ordinarily preclude Medicaid coverage for such vaccinations, will help further that goal. In addition, in light of the unprecedented emergency circumstances associated with the COVID- 19 pandemic and consistent with the President’s declaration detailed above – and because of the time-limited nature of this demonstration amendment – CMS did not require the state to submit budget neutrality calculations for this Wisconsin COVID-19 Vaccine Administration PHE amendment. In general, CMS has determined that the costs to the federal government are likely to have been otherwise incurred and allowable. Wisconsin will still be required to monitor and evaluate the expenditure authority that CMS approved, including tracking demonstration expenditures and assessing how such outlays would facilitate the state’s response to the COVID- 19 PHE. Due to the highly limited scope of the changes under the amendment, CMS is incorporating this amendment as Attachment D to the STCs for the Wisconsin SeniorCare section 1115 demonstration.

Monitoring and Evaluation Requirements

Given the unique circumstances and time-limited nature of this demonstration amendment, and the fact that the entire approval period for this amendment is retroactive, CMS expects Wisconsin to undertake data collection and analyses that are meaningful but not unduly burdensome for the state, while also being consistent with the applicable provisions of 42 CFR 431.424 and 431.428. It is still important to gather evidence regarding the operation and effectiveness of this amendment, but, recognizing the challenges associated with the COVID-19 PHE and the retroactive approval period for this demonstration amendment, CMS has simplified the monitoring and evaluation requirements for this amendment. The state’s streamlined monitoring and evaluation activities for this demonstration amendment, including an outline of an Evaluation Design, will be encapsulated in a Final Report, the draft of which will be due to CMS no later than eighteen months after the state’s receipt of the approval of the amendment. The monitoring and evaluation requirements are reflected in Attachment D.

The Final Report should include a background description of the scope and objectives of the amendment and outline the evaluation questions, suggested ideas for which are provided in Attachment D. The Final Report should also narrate how the state would leverage the simplified expectations for data collection and analyses for this amendment, in alignment with information outlined in Attachment D, to support contextualizing and addressing the evaluation questions. Briefly, the Final Report should provide a discussion of the findings that will support understanding the successes, challenges, and lessons learned in implementing the amendment, to help inform best practices for similar situations in the future. Additionally, the state should provide summary data on demonstration expenditures under this amendment, and describe briefly how these outlays were effective at achieving the objectives of the