Policy Unit

What We Do

Primary Functions of the Medicaid Policy Unit

  • Oversight and Coordination of Vermont's Global Commitment to Health 1115 Demonstration Waiver
  • Policy Development and Implementation
  • Medicaid Administrative Rulemaking
  • Policy Research and Analysis
  • Administration of:
    • 1115 Global Commitment to Health Waiver
    • Medicaid State Plan
    • Global Commitment Register
    • PBR (Policy, Budget, Reimbursment) Process
Who We Serve

The Medicaid Policy unit serves all of AHS in the policy development and implementation of the Vermont Medicaid program. Additionally, the Unit serves broader external stakeholders including the Vermont Legislature, Vermont Legal Aid, Vermont’s Congressional Delegation, the Medicaid and Exchange Advisory Board, Vermont’s Medical Society, and the Vermont Hospitals Association to both navigate and improve on Medicaid policy statewide.

How We Impact

The Medicaid Policy Unit works to ensure that DVHA and other AHS departments administer the Medicaid program in compliance with federal and state regulations. Additionally, the Policy Unit works with AHS staff and other public and private partners to develop and implement effective Medicaid policy aimed at advancing the agency’s goals of improving access and quality while reducing overall costs.

Action Plan

The priorities/initiatives for the Policy Unit in SFY20 include:


  1. Psychiatric IMD 1115 Waiver Amendment
    1. Summit application by Sept. 2019
    2. Negotiation with CMS
    3. Finalize terms
    4. Begin drawing down FFP
  2.  1115 Waiver Administration and Planning
    1. Administration of existing waiver.
    2. Planning/preparation for new waiver in 2022
  3. Administrative Rulemaking
    1. The Medicaid Policy Unit is currently undergoing a 5-7-year project to rewrite all of Vermont’s Medicaid administrative rules under one centralized framework. Rule work of significant importance underway in SFY2020 include:
      1. Gender Affirmation Surgery
      2. Medical Necessity
      3. EPSDT
    2. Updated and consolidated Medicaid rules promotes transparency, reduces provider/beneficiary confusion.
  4. Medicaid Policy Development and implementation at AHS, including:
    1. Payment reform initiatives for Developmental Services, Residential Treatment for Substance Use Disorder, and Children’s Integrated Services
    2. Federal and/or state legislation
  5. Home and Community Based Services (HCBS)
    1. Continue systems work to comply with federal HCBS conflict of interest rules
    2. Begin work to move HCBS from 1115 Waiver to State Plan authority (required by 2022)
  6. Improved Early, Periodic, Screening, Diagnostic, and Treatment (EPSDT) process
    1. Operational process improvements to ensure EPSDT services that are not listed as covered services under Vermont Medicaid are reviewed for medical necessity and, if appropriate, covered on an individual basis. 
    2. As a result of this operational improvement, Medicaid-enrolled children under 21 and their providers will be able to receive a decision on EPSDT coverage faster, as requests will be reviewed as part of the normal prior authorization process, rather than going through a separate, prolonged, and administratively arduous exception request process. 
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