Section 1115 Waiver Update e-Memo - State of Alaska - CMS letter to providers

Division of Behavioral Health Letterhead

Dear Providers,

The application, approval, and implementation of the Alaska 1115 Waiver Demonstration Project has been a long and challenging effort.  Adding to the complexity, the implementation of the Behavioral Health component of the waiver occurred during the COVID pandemic.

In accordance with the commitment by the State of Alaska to the Center to Medicaid and Medicare Services (CMS), the last technical piece of implementation of the waiver is to “sunset”  the services listed in Appendix B of the Alaska 1115 Waiver Demonstration Project application.


The state has been engaged with stakeholders, over the years, around the proposed removal of these services from the State Plan.  The Alaska 1115 Waiver Demonstration Project presents a unique opportunity to backfill for those deleted services, and so the timing is very important that providers are able to pivot to 1115 services in time for the State Plan Amendments (SPAs).  At the same time, the state has a federally required obligation to remove those services from the State Plan in order to come into compliance with federal rules.


The Division has heard from our providers that the timeline to move to 1115 services from State Plan services (especially during COVID) poses some challenges, and there is concern that Alaska’s most vulnerable citizens could be at risk as a result.


In an effort to best serve Alaskans, and to advocate for our Behavioral Health providers, the State met with CMS and proposed a compromise.  CMS has agreed to the following:


  • The state will meet the obligation to CMS and submit SPAs, and conduct all necessary consultation and/or public notice, with a target of January 2021,
  • The state requested, and CMS agreed to an effective date of 31 March.


What this means is that the state can now offer the date of 31 March 2021 for providers to continue to bill for the services listed in Appendix B of the 1115 application.


The Division urges providers to prepare to transition out of sunsetting State Plan services to 1115 waiver services no later than 31 March 2021, to ensure that you are able to continue to claim for services for our vulnerable citizens.



Thank you for all you do, and we look forward to continuing to work as good partners throughout this transformational reform effort.



Gennifer Moreau,

Director Division of Behavioral Health

Department of Health and Social Services




Dear Provider,

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