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Comment: CMS Should Reject Iowa’s State Innovation Waiver Because It Violates Federal Law

Young Invincibles submitted a letter to CMS Administrator Seema Verma highlighting our profound concerns with Iowa’s Section 1332 State Innovation Waiver. The state’s proposal violates federal law by not adhering to the ACA’s 1332 comparable coverage, affordability, and budget neutrality requirements. The proposal poses a particular threat to young Iowans, who have lower rates of health insurance literacy, yet would have to navigate an extremely onerous enrollment process. CMS should reject this flawed plan.