Some loudmouth over at the Health Affairs blog argues that we should expect states to more easily see their 1332 waivers approved this year as the pragmatic budget neutrality requirement for 2019 has been relaxed:
The current guidance has strict rules on budget neutrality. These criteria partially led to Iowa withdrawing its revised Iowa Stopgap Measure 1332 application. However, two developments—the repeal of the individual mandate and the replacement of eliminated cost-sharing reduction payments by higher advance premium tax credits (APTC)—both increase net federal costs under the ACA; they thus increase the amount of pass-through funds available to states implementing 1332 waivers.
What does this mean?
The lack of an individual mandate starting in 2019 means the Federal government will be clawing back less of the pass-through amount to cover the loss of individual mandate taxes. And the rise of the APTC payments to compensate for the lack of CSR payments means states have a lot of extra money to use to provide benefits that are at least as comprehensive and at least as affordable as mandated by law than they had for 2017. A lot more money is effectively sloshing through the system for states that want to design their own systems.