CMS-10383 - Supporting Statement Part A

Supporting Statement – Part A
Review and Approval Process for Waivers for State Innovation
CMS-10383/OMB control number# 0938-NEW
A. Background
Section 1332 of the Patient Protection and Affordable Care Act (PPACA) establishes authority for
a “Waiver for State Innovation.” Under this section, states can apply for a waiver—effective for
plan years beginning on or after January 1, 2017—of the PPACA requirements such as qualified
health plans, Exchanges, cost-sharing reductions1, premium tax credits, the individual
responsibility requirement, and shared responsibility for employers. The PPACA requires that the
U.S. Department of Health and Human Services (HHS) and the U.S. Department of the Treasury
(Treasury)—collectively known as the Departments—issue regulations regarding procedures for
section 1332 waivers.
Under this section, the secretaries are required to establish a process for the submission of an
application for a section 1332 State Innovation waiver (also now referred to as a State Relief and
Empowerment Waiver or section 1332 waiver), including a process for public notice and comment
at the state and federal levels that is sufficient to ensure a meaningful level of public input. The
secretaries are also required to establish reporting requirements for states and a process for the
periodic evaluation of approved waivers. This information collection request would establish
requirements pertaining to the provisions required under section 1332 of the PPACA.
B. Justification
1. Need and Legal Basis
The information required under this collection is necessary to ensure that states comply with
statutory and regulatory requirements related to the development and implementation of section
1332 waivers. States seeking waiver authority under section 1332 of the PPACA are required to
meet certain requirements for applications, public notice, and reporting. The authority for these
requirements is found in section 1332 of the PPACA. This information collection reflects the
requirements provided in the final rules published in February 2012. Additionally, on October 24,
2018, the Departments published guidance that provides supplementary information about the
requirements that must be met for the approval of a section 1332 waiver, the Secretaries'
application review procedures, the calculation of pass-through funding, certain analytical
requirements, and operational considerations.2 This guidance supersedes the guidance related to
section 1332 of the PPACA that was previously published on December 16, 2015. This
information collection also reflects the requirements outlined in a state’s specific terms and
1

So long as there is no available appropriation to support federal CSR payments, states may not receive pass-through
funds based on federal savings in CSR payments.
2
83 FR 53575; https://www.federalregister.gov/documents/2018/10/24/2018-23182/state-relief-and-empowermentwaivers

1

conditions (STCs), as part of the approval of a state’s section 1332 waiver application.
2. Information Users
The information required is used by the Departments when evaluating waiver proposals for
approval or disapproval and for approved waivers to determine compliance with section 1332 of
the PPACA. The Departments review waiver applications to determine whether a proposed
waiver program would meet the statutory guardrails. The application data and narrative inform
the Departments’ determination on whether to approve a waiver program.
Monitoring and compliance data—including various quarterly, annual, and periodic reporting—
is used by the Departments to maintain oversight over states. The reports include both qualitative
and quantitative data to provide updates on the state of the waiver program and, as applicable,
inform pass-through funding calculations. Reporting forms collect data as prescribed in the
regulation and the state’s STCs. The Departments review this information to confirm state
compliance with statutory guardrails and grantee requirements.
3. Use of Information Technology
States submit their waiver applications, as well as any supporting documentation or information,
electronically to an established 1332 mailbox and/or CCIIO staff. Quarterly and annual reports, as
well as grant required reports, are submitted electronically using online reporting functionality
through the GrantSolutions system.
4. Duplication of Efforts
This information collection does not duplicate any current information collection.
5. Small Businesses
This information collection does not impact small businesses or other small entities.
6. Less Frequent Collection
Close monitoring will be critical to ensuring that states receive prompt federal guidance and
technical assistance that is responsive to any state-specific issues that may arise, and that state
activities meet statutory and other federal requirements. In the absence of regular reporting, there is
a risk that states could invest resources and conduct activities that are not aligned with requirements.
As such, HHS or Treasury (depending on the scope of the waiver) will be in close contact with
awardees. Reporting is outlined in section 1332 regulations and the STCs. HHS may look for
opportunities, however, to streamline reporting, such as combining fourth quarter reporting with
annual reporting.
7. Special Circumstances
2

No special circumstances exist for this information collection.
8. Federal Register/Outside Consultation
A 60-day Notice published in the Federal Register on August 12, 2019 (84 FR 39851). Comments
are included and responded to in Appendix A.
9. Payments/Gifts to Respondents
There is no payment or gift to respondents.
10. Confidentiality
The information received by HHS is not confidential and will be made publicly available, in whole
or in part, in order to comply with statutory requirements designed to promote transparency in the
review and approval of section 1332 waivers.
11. Sensitive Questions
There are no sensitive questions included in this collection effort. HHS does not propose to collect any
private information.

12. Burden Estimates (Hours & Wages)

Wage Rate Data
Average labor costs (doubled to include fringe benefits and other associated costs) are calculated
using data available from the Bureau of Labor Statistics (BLS).3 The Centers for Medicare &
Medicaid Services (CMS) used the May 2018BLS’s most recent wage estimates available on the
BLS website at the following link (https://www.bls.gov/oes/current/oes_nat.htm) as the basis for
standard mean hourly wages to calculate the burden costs. As indicated, we are adjusting the
employee mean hourly wage estimates by a factor of 100 percent to account for benefits and
overhead. Table 12.1 below details the occupation titles and associated hourly wages from BLS
used in the burden calculations.
Table 12.1 National Occupational Employment and Adjusted Hourly Wages Used in Burden

Estimates

BLS Occupation Title

3

Occupational
Code

Mean Hourly
Wage ($/hr)

BLS Employer Costs for Employee Compensation—September 2018

3

Fringe Benefits and
Overhead ($/hr)

Adjusted Hourly
Wage ($/hr)

Actuaries
Management Analysts
Financial Analysts
Network and Computer
Systems Administrators
Information Security
Analysts
General and Operations
Managers

15-2011
13-1110

$55.21

$55.21

$110.42

13-2051

$44.92
$47.80

$44.92
$47.80

$89.84
$95.60

15-1142

$41.51

$41.51

$83.02

15-1122
11-1020

$47.93

$47.93

$95.86

$59.35

$59.35

$118.70

The Departments have approved eight section 1332 waivers to date and anticipate an average of
four new applicants each year. As such, we have used 12 respondents for all annual requirements.
We have used four respondents for any requirements that only occur in the first year of the waiver,
including the application for a section 1332 waiver. The number of responses per respondent is one
unless otherwise noted to reflect the recurrence of a requirement over the course of a waiver year, as
per regulation or STCs.
Coordinated Waiver Process and (31 CFR 33.102 and 45 CFR 155.1302) and
Application Procedures (31 CFR 33.108 and 45 CFR 155.1308)
Under certain conditions, 31 CFR 33.102 and 45 CFR 155.1302(a) and (b) provide that a state
may submit a single application for a waiver under section 1332 of the PPACA and a waiver
under one or more of the existing waiver processes applicable under titles XVIII, XIX, and XXI
of the PPACA, or under any other federal law relating to the provision of health care items or
services. 31 CFR 33.108 and 45 CFR 155.1308 of the regulations establish the application
process for section 1332 waivers. Under 31 CFR 33.108(a) and 45 CFR 155.1308(a), a state’s
application for approval of a section 1332 waiver must be submitted to the secretary as an
electronic document. Paragraph (f) of 31 CFR 33.108 and 45 CFR 155.1308 specifies that an
application for a section 1332 waiver will not be considered complete unless the application
meets all of the conditions set out in those sections. The burden associated with the requirements
in 31 CFR 33.102 and 33.108 and 45 CFR 155.1302 and 155.1308 is the time and effort
necessary for a state to develop and submit a complete application for a section 1332 waiver.
Table 12.2 Annualized Cost Estimate for States Completing Application
CMS estimates that it will take approximately 390 hours per applicant to develop and submit a
complete application to HHS, at a cost of approximately $37,508.40 per applicant. For states
completing an application, we estimate that it will require 300 hours for a management analyst (at a
cost of $45.38 per hour) to prepare the application and 60 hours for an actuary (at a cost of $55.89
per hour) to contribute to the application. We also estimate it will require 30 hours for a senior
manager (at a cost of $59.56 per hour) to review the application. The total annualized burden for
four applicants is 1560 hours and $150,033.60.

4

Type of respondent

Management Analysts

Number of
Respondents

Number of
Responses
per
Respondent

4

1

Average
Burden
Hours

Burden Costs

$90.76

$108,912.00

$111.78

$26,827.20

$119.12

$14,294.40

300

Actuaries

4

1

60

Senior Manager

4

1

30

Total – Annual

Wage per
Hour (incl
fringe)

390

Total - Three Years

$150,033.60
$450,100.80

State Public Notice Requirements (31 CFR 33.112 and 45 CFR 155.1312)
Paragraph (a) of 31 CFR 33.112 and 45 CFR 155.1312 of the regulations require a state to
provide a public notice and comment period prior to submitting an application for a section 1332
waiver. The public notice must address the information requirements listed in paragraphs (b)(1)
through (4) of 31 CFR 33.112 and 45 CFR 155.1312.
Paragraph (c) of 31 CFR 33.112 and 45 CFR 155.1312 specify that after issuing the public
notice and prior to submitting an application for a section 1332 waiver, a state must conduct
public hearings regarding the state's waiver application.
The burden estimate associated with this requirement is the time and effort necessary to develop
and publish a public notice that complies with the aforementioned information requirements and
hold a public forum.
Table 12.3 Annualized Cost Estimate for States Completing Application Public Notice
Requirement
CMS estimates that it will take approximately 27 hours per applicant to comply with the public
notice and forum requirements, at a cost of approximately $2,578.24 per applicant. For states
completing an application, we estimate that it will require 20 hours for a management analyst (at
a cost of $45.38 per hour) to prepare the public notice hold a public forum and 2 hours for a
network and computer systems administrator (at a cost of $41.86 per hour) to post the public
notice. We also estimate it will require 5 hours for a senior manager (at a cost of $59.56 per
hour) to review the public notice and participate in the public forum. The total annualized burden
for four applicants is 108 hours and $10,312.96.
5

Type of respondent

Number of
Responses
per
Respondent

Number of
Respondents

Average
Burden
Hours Per
Response

Senior Management

4

1

5

Management Analysts

4

1

20

Network and Computer
Systems Administrators

4

1

2

Total - Annual

Wage per
Hour (incl
fringe)

Burden Costs

$119.12

$2,382.40

$90.76

$7,260.80

$83.72

$669.76

$10,312.96

27

$30,938.88

Total - Three Years

Paragraph (a)(2) of 31 CFR 33.112 and 45 CFR 155.1312 require states with one or more
Federally-recognized Indian tribes to consult with such tribes before submitting a section 1332
waiver application. Paragraph (f)(2) of 31 CFR 33.108 and 45 CFR 155.1308 explains that
documentation of the state’s public notice, which incorporates this consultation, must be
included in the waiver application. The burden associated with these requirements is both the
time and effort necessary for a state to conduct its tribal consultations and the time and effort
necessary to notify CMS of the state’s compliance with paragraph (f)(2) of 31 CFR 33.108 and
45 CFR 155.1308.
Table 12.4 Annualized Cost Estimate for States Completing Tribal Consultation
Requirement
CMS estimates that it will take approximately eight hours per applicant to comply with the
tribal consultation requirements at a cost of approximately $839.52 per applicant. For states
completing an application, we estimate that it will require 4 hours for a management analyst (at a
cost of $45.38 per hour) to conduct tribal consultation. We also estimate it will require 4 hours
for a senior manager (at a cost of $59.56 per hour) to oversee and review a tribal consultation.
The total annualized burden for four applicants is 32 hours and $3,358.08.

Type of respondent

Number of
Responses
per
Respondent

Number of
Respondents

Average
Burden
Hours Per
Response

Senior Management

4

1

4

Management Analysts

4

1

4

Total - Annual

8

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$119.12

$1,905.92

$90.76

$1,452.16
$3,358.08
$10,074.24

6

Monitoring and Compliance (31 CFR 33.120 and 45 CFR 155.1320)
a. Periodic State Internal Implementation Reviews
31 CFR 33.120(b) and 45 CFR 155.1320(b) of the regulations require states to periodically
perform internal reviews of the implementation of an approved section 1332 waiver.
The burden associated with this reporting requirement is the time and effort necessary for a state to
periodically review the waiver’s implementation internally.
Table 12.5 Annualized Cost for Periodic State Internal Implementation Reviews
CMS estimates that it will take approximately 20 hours per state to periodically review the
waiver’s implementation, at a cost of approximately $1,988.70 per applicant. For those states,
we estimate that it will require 10 hours for a management analyst (at a cost of $45.38 per hour)
to conduct the periodic internal implementation review and 5 hours for a financial analyst (at a
cost of $48.55 per hour) to contribute to the implementation review. We also estimate it will
require 5 hours for a senior manager (at a cost of $59.56 per hour) to oversee the implementation
review. The total annualized burden for 12 states is 240 hours and $23,864.40.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

1

10

Financial Analyst

12

1

5

Senior Management

12

1

5

Total - Annual

20

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$10,891.20

$97.10

$5,826.00

$119.12

$7,147.20

$23,864.40
$71,593.20

b. Reinsurance Reports
31 CFR 33.120(b) and 45 CFR 155.1320(b) specify that states must complete a periodic review
related to the implementation of the waiver. Per the STCs, the state must submit a one-time report
by February 28th of the first year of the waiver, to include details on the operation of the waiver
program, including a plan for processing claims.
The burden associated with this reporting requirement is the time and effort necessary to submit
the reinsurance report to CMS.
7

Table 12.6 Annualized Cost for Reinsurance Periodic Reports
CMS estimates that it will take approximately five hours per state to assemble, review, finalize,
and submit each reinsurance periodic report at a cost of approximately $482.16 per applicant.
For those states, we estimate that it will require 4 hours for a management analyst (at a cost of
$45.38 per hour) to prepare the report. We also estimate it will require 1 hour for a senior
manager (at a cost of $59.56 per hour) to review the report. The total annualized burden for four
states is 20 hours and $1,928.64.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

4

1

4

Senior Management

4

1

1

Total - Annual

5

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$1,452.16

$119.12

$476.48

$1,928.64
$5,785.92

c. Post-Award Public Forum
Paragraph (c) of 31 CFR 33.120 and 45 CFR 155.1320 of the regulations further specifies that at
least six months after the implementation date of the waiver, and annually thereafter, the state must
hold a public forum to solicit comments on the progress of a section 1332 waiver. As specified in
paragraph (c)(1) of 31 CFR 33.120 and 45 CFR 155.1320, the state must publish the date, time,
and location of the public forum in a prominent location on the state’s public web site at least 30
days prior to the date of the planned public forum.
The burden associated with these provisions includes the time and effort necessary to conduct the
public meeting and the time and effort necessary for a state to publish the date, time, and location
of the public forum in a prominent location on the state’s public web site at least 30 days prior to
the date of the planned public forum.
Table 12.7 Annualized Cost for Post-award Public Forum
CMS estimates that it will take approximately 12 hours per state to hold a public forum at a cost
of approximately $1,115.88 per applicant. For those states, we estimate that it will require 8
hours for a management analyst (at a cost of $45.38 per hour) to prepare for and hold the postaward public forum and 2 hours for a financial analyst (at a cost of $48.55 per hour) to
contribute to and participate in the public forum. We also estimate it will require 2 hours for a
senior manager (at a cost of $59.56 per hour) to participate in the public forum. The total
annualized burden for 12 states is 144 hours and $13,390.56.
8

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

1

8

Financial Analyst

12

1

2

Senior Management

12

1

2

Total - Annual

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$8,712.96

$75.78

$1,818.72

$119.12

$2,858.88

12

$13,390.56

Total - Three Years

$40,171.68

State Reporting Requirements (31 CFR 33.124 and 45 CFR 155.1324)
a. Quarterly Reporting
Paragraph (a) of 31 CFR 33.124 and 45 CFR 155.1324 requires states to submit quarterly reports
to CMS in accordance with the STCs. These quarterly reports must include, but are not limited
to, reports of any ongoing operational challenges and plans for and results of associated
corrective actions. The burden associated with this reporting requirement is the time and effort
necessary to prepare and submit quarterly reports to CMS.
Table 12.8 Annualized Cost Estimate for State Quarterly Reporting
CMS estimates that it will take approximately 12 hours per state to assemble, review, finalize, and
submit each quarterly report to the Departments, at a cost of approximately $3,437.52 per state.
States submit three quarterly reports each year (the fourth quarter is included with the annual
report) for a total of 36 hours per year. For those states, we estimate that it will require 10 hours for
a management analyst (at a cost of $45.38 per hour) to prepare the report. We also estimate it will
require 2 hours for a senior manager (at a cost of $59.56 per hour) to review the report. The total
annualized burden for 12 states is 432 hours and $41,250.24.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

3

10

Senior Management

12

3

2

Total - Annual

36

9

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$32,673.60

$119.12

$8,576.64

$41,250.24

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Wage per
Hour (incl
fringe)

Total - Three Years

Burden Costs
$123,750.72

b. Annual Reporting
Paragraph (b) of 31 CFR 33.124 and 45 CFR 155.1324 of the regulations requires states to
submit annual reports to CMS documenting the information listed in paragraph (b)(1) through
(4) of 31 CFR 33.124 and 45 CFR 155.1324. As part of the submission process, paragraph (c) of
31 CFR 33.124 and 45 CFR 155.1324 requires states to submit draft annual reports to CMS no
later than 90 days after the end of each waiver year, or as specified in the STCs. Paragraph (c)(2)
of 31 CFR 33.124 and 45 CFR 155.1324 of the regulations specifies that the draft and final
annual reports must be published on the state’s public web site. The burden associated with this
reporting requirement is the time and effort necessary to prepare and submit draft and final
annual reports to CMS and the time and effort required for a state to post the aforementioned
information on the state’s public web site.
Table 12.9 Annualized Cost Estimate for State Annual Reporting
CMS estimates that it will take approximately 35 hours per applicant to assemble, review,
finalize, and submit each annual report to the Departments and post the report to the state’s
public web site at a cost of approximately $3,528.60 per state. For those states, we estimate that
it will require 20 hours for a management analyst (at a cost of $45.38 per hour) to prepare the
report and 10 hours for an actuary (at a cost of $55.89 per hour) to contribute to the report. We
also estimate it will require 5 hours for a senior manager (at a cost of $59.56 per hour) to review
the report. The total annualized burden for 12 states is 420 hours and $42,343.20.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

1

20

Actuaries

12

1

10

Senior Management

12

1

5

Total - Annual

35

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$21,782.40

$111.78

$13,413.60

$119.12

$7,147.20

$42,343.20
$127,029.60

c. Pass-through Funding Reports
10

[42 U.S. Code 18052] Section 1332(a)(3) specifies that states shall receive pass-through funding
annually, as determined by the Secretary. The STCs detail the requirement for states to submit
pass-through funding reports to CMS to inform this determination each year.
The burden associated with this reporting requirement is the time and effort necessary to submit
pass-through funding reports to CMS.
Table 12.10 Annualized Cost for Pass-through Funding Reports
CMS estimates that it will take approximately 45 hours per applicant to assemble, review,
finalize, and submit each pass-through funding report, at a cost of approximately $4,595.02 per
state. For those states, we estimate that it will require 20 hours for a management analyst (at a
cost of $45.38 per hour) to prepare the report, 5 hours for a financial analyst (at a cost of $48.55
per hour) and 12 hours for an actuary (at a cost of $55.89 per hour) to contribute to the report.
We also estimate it will require 8 hours for a senior manager (at a cost of $59.56 per hour) to
review the report. The total annualized burden for 12 states is 540 hours and $55,140.24.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

1

20

Financial Analyst

12

1

5

Actuaries

12

1

12

Senior Management

12

1

8

Total - Annual

45

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$21,782.40

$97.10

$5,826.00

$111.78

$16,096.32

$119.12

$11,435.52

$55,140.24
$165,420.72

d. Grant Reporting
The HHS Grants Policy Statement requires grantees to comply with fiscal and budgetary reporting
requirements and the STCs (including quarterly SF-424 reports and an annual SF-425 report).
The burden associated with this reporting requirement is the time and effort necessary to submit
grant reports to CMS.
Table 12.11 Annualized Cost for Grant Reporting
CMS estimates that it will take approximately four hours per state to assemble, review, finalize,
11

and submit each grant report, at a cost of approximately $2,023.90 per state. With five grant
reports submitted per year, the total burden per state each year is 20 hours. For those states, we
estimate that it will require 1 hour for a management analyst (at a cost of $45.38 per hour) to
prepare the report and 1 hour for an accountant or auditor (at a cost of $37.89 per hour) to
contribute to the report. We also estimate it will require 2 hours for a senior manager (at a cost of
$59.56 per hour) to review the report. The total annualized burden for 12 grantees is 240 hours
and $24,286.80.

Type of respondent
Management Analysts
Accountant and Auditors
Senior Management

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

12

5

1

12

5

1

12

5

2

Total - Annual

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$5,445.60

$75.78

$4,546.80

$119.12

$14,294.40

20

Total - Three Years

$24,286.80
$72,860.40

Periodic Evaluation Requirements (31 CFR 33.128 and 45 CFR 155.1328)
a. Federal Periodic Review
31 CFR 33.128 and 45 CFR 155.1328 specify that the Departments’ secretaries shall periodically
evaluate the implementation of section 1332 waivers.
The burden associated with this reporting requirement is the time and effort necessary for the state
to prepare for and participate in virtual meeting(s) with the Departments to periodically evaluate
the waiver’s implementation, the state’s most recently submitted annual report, and any operational
issues or challenges and need for technical assistance.
Table 12.12 Annualized Cost for Federal Periodic Review
CMS estimates that it will take approximately 15 hours per applicant to periodically evaluate the
waiver’s implementation, at a cost of approximately $1,503.20 per state. For those states, we
estimate that it will require 10 hours for a management analyst (at a cost of $45.38 per hour) to
prepare for and participate in the evaluation. We also estimate it will require 5 hours for a senior
manager (at a cost of $59.56 per hour) to prepare for and participate in the evaluation. The total
annualized burden for 12 states is 180 hours and $18,038.40.

12

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

1

10

Senior Management

12

1

5

Total - Annual

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$10,891.20

$119.12

$7,147.20

15

$18,038.40

Total - Three Years

$53,708.40

b. Monitoring Calls
The STCs specify that states must participate in monitoring calls with the Departments that the
Departments deem necessary. The purpose of these calls is to discuss any significant actual or
anticipated developments affecting the waiver, typically identified in state-submitted reports.
The burden associated with this reporting requirement is the time and effort necessary to hold
monitoring calls with CMS.
Table 12.13 Annualized Cost for Monitoring Calls
CMS estimates that it will take approximately three hours per applicant to prepare for and hold
each monitoring call, at a cost of approximately $901.92 per state. We anticipate states being
asked to participate in three grantee monitoring calls per year, for a total of 9 burden hours. For
those states, we estimate that it will require 2 hours for a management analyst (at a cost of
$45.38 per hour) to prepare for and participate in each call. We also estimate it will require 1
hour for a senior manager (at a cost of $59.56 per hour) to prepare for and participate in each
call. The total annualized burden for 12 states is 108 hours and $10,823.04.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

12

3

2

Senior Management

12

3

1

Total - Annual

9

Total - Three Years

Reinsurance Payment Schedule

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$6,534.72

$119.12

$4,288.32

$10,823.04
$32,469.12

13

31 CFR 33.128 and 45 CFR 155.1328 specify that the Departments’ secretaries shall periodically
evaluate the implementation of section 1332 waivers. The STCs require states with reinsurance
waivers to submit a payment schedule by January 1st of the first year of their waiver.
The burden associated with this reporting requirement is the time and effort necessary to submit
reinsurance payment schedules to CMS.
Table 12.14 Annualized Cost for Reinsurance Payment Schedule
CMS estimates that it will take approximately seven hours per state to assemble, review,
finalize, and submit each reinsurance payment schedule at a cost of approximately $676.36 per
states. For those states, we estimate that it will require 4 hours for a management analyst (at a
cost of $45.38 per hour) to prepare the reinsurance payment schedule and 2 hours for a financial
analyst (at a cost of $48.55 per hour) to contribute to the payment schedule. We also estimate it
will require 1 hour for a senior manager (at a cost of $59.56 per hour) to review the payment
schedule. The total annualized burden for four states is 28 hours and $2,705.44.

Type of respondent

Number of
Respondents

Number of
Responses
per
Respondent

Average
Burden
Hours

Management Analysts

4

1

4

Financial Analyst

4

1

2

Senior Management

4

1

1

Total - Annual

7

Total - Three Years

Wage per
Hour (incl
fringe)

Burden Costs

$90.76

$1,452.16

$97.10

$776.80

$119.12

$476.48

$2,705.44
$8,116.32

Table 12.15 Summary of Burden
Table 12.15 summarizes the estimated overall burden to states participating in this program. The
estimated annualized burden specified in this information collection is 4,016 hours for a total of
12,048 burden hours and $1,181,413.68 in burden cost across three years. This also the sum of
total burden cost across program activities, as laid out in Tables 12.2-12.14.

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Requirement

Waiver Application
Public Notice and
Forum
Tribal Notice
Quarterly Reports
Annual Report
Federal Periodic
Evaluations
Reinsurance Periodic
Reports
Pass Through
Funding Reports
State Implementation
Reviews
Annual Post-award
Public Forums
Grant Reporting
Monitoring Calls
Reinsurance Payment
Schedule
Total - Annual
Total - Three Year

13.

Type of
Respondent

Number of
Respondents

Number of
Responses per
Respondent

4

1

390

1560

4

1

27

108

1

8

32

12

3

12

432

12

1

35

420

12

1

15

180

4

1

5

20

12

1

45

540

12

1

20

240

12

1

12

144

12

5

4

240

12

3

3

108

4

1

7

28

State
Government
State
Government
State
Government
State
Government
State
Government
Federal
Government
State
Government
State
Government
State
Government
State
Government
State
Government
State
Government
Federal
Government

4

Capital Costs

Cost to Federal Government

There are no costs to the Federal government.
15.

Total
Estimated
Burden Hours

4,016
12,048

There are no capital costs associated with this collection.
14.

Estimated
Burden hours
per Response

Changes to Burden

This is a new information collection.
15

16.

Publication/Tabulation Dates

State waiver application packages are published on the CCIIO section 1332 website once the
Departments have completed a preliminary review of the application in accordance with 45 CFR
155.1308(c) and 31 CFR 33.108(c). 45 CFR 155.1324(c)(2) also requires states to publish the final
annual report on state’s public web site within 30 days of submission to and approval by the
Secretary, respectively.
17.

Expiration Date

There are no instruments associated with this information collection.

16