ABSTRACT
Implementation at the federal level was a huge and complicated assignment, made more difficult by special circumstances and by continuing attacks upon the Affordable Care Act (ACA). The proposed regulation implementing the ACA's Medicaid eligibility changes was a challenge that demanded a high order of precision in defining and implementing language, and sensitivity in combining a complex process with a variety of technical constraints. The initial announcement for innovation grants was issued on November 14, 2011, with Letters of Intent due by December 19, 2011, and submission of a "Cooperative Agreement" to be completed by January 27, 2012. The initial announcement stressed that this would be a "cooperative" arrangement, with the Center for Medicare and Medicaid Innovation and Center for Medicaid and State Operations offering help but monitoring the results and quality of performance and reserving the right to terminate when in the best interests of the program.
