Notice of Public Comment for Proposed Alaska Traditional Health Care Practices 1115 Demonstration Application
Agency Action: Application for a Section 1115 Demonstration
The State of Alaska’s Department of Health (the Department) hereby gives notice that it intends to seek approval from the Centers for Medicare & Medicaid Services (CMS) for a five-year Section 1115 demonstration to provide coverage of traditional health care practices (THCPs).
Subject of Demonstration: The Department is seeking a Section 1115 demonstration, titled the Alaska Traditional Health Care Practices (ATHCP) demonstration to authorize federal Medicaid coverage for THCPs delivered by or through Tribal health programs to Alaska Medicaid beneficiaries who are Alaska Native or American Indian (AN/AI). The Department is soliciting public comment on this request prior to submitting the demonstration application to CMS.
Program Description
The Department seeks a Section 1115 demonstration to allow for Medicaid coverage of THCPs for Medicaid beneficiaries who are AN/AI. THCPs are practices based on principles that have been traditionally used in Tribal communities since time immemorial. THCPs embody a whole-person approach to health and wellness and are validated utilizing the process that has been established by the Tribes. The Department proposes that this demonstration will be effective from December 31, 2026, through December 31, 2031, with Medicaid coverage of THCPs beginning no earlier than January 1, 2028.
Goals and Objectives
The primary objective of this proposed demonstration is to sustainably provide culturally appropriate Medicaid service options for AN/AI Medicaid beneficiaries by covering traditionally grounded care services within the Alaska Tribal Health System (ATHS) to support whole-person health and wellness. By providing these services in a complementary fashion with provider-led health care teams, AN/AI Medicaid beneficiaries can achieve wellness and healing for ailments and afflictions.
Specific goals include:
- Allow Medicaid coverage of THCPs within the ATHS to maintain and sustain recipients’ whole-person wellness
- Incorporate THCPs into preventive health care
Beneficiary Eligibility
To be eligible to obtain THCPs under this demonstration, individuals must meet all of the following criteria:
- Meet the definition of AN/AI, defined as “Indians or Indian” in 25 U.S.C. § 1603(13);[1]
- Be enrolled in Medicaid; and
- Be eligible to receive services by or through a Qualified Entity.
A Qualified Entity is defined as a Tribal health program, using the definition in 25 U.S.C. § 1603(25).[2]
With this demonstration, the Department does not propose any changes to Alaska’s Medicaid eligibility; the standards and methodologies for eligibility remain set forth under the State Plan.
Benefit Coverage and Cost Sharing
Benefit Coverage
A broad array of THCPs exist in Alaska Native traditions given the regional nature of the ATHS and wide-ranging histories of Tribes across the state. They could include ceremonial practices, physical body work, counseling sessions based in traditional approaches, group work in learning and talking circles on traditional skills, knowledge, and practices, as well as traditional nutritional education.
Each Qualified Entity will establish and document processes to define covered THCPs, limitations, and exclusions, and medical necessity requirements at their facilities. THCPs will not limit, reduce, jeopardize, or adversely affect a beneficiary’s access to any other Medicaid services for which they would otherwise be eligible to receive.
Cost Sharing
Services will be subject to the same cost sharing as other clinic visits. AN/AI individuals, however, are exempt from cost sharing requirements, and thus the Department does not anticipate that any cost sharing will be collected for these services.
Implementation
Delivery System
Alaska is not seeking to make any changes to its Medicaid delivery system through this demonstration.
Payment for THCPs
The Department is seeking to claim Federal Financial Participation when Qualified Entities provide THCPs to eligible AN/AI Medicaid beneficiaries. Medicaid reimbursement will be available only for THCPs that a participating Qualified Entity has identified as covered for its region and that satisfy all applicable demonstration, documentation, and billing requirements. Reimbursement will be provided only for services delivered by or received through a facility operated by a Qualified Entity, but there is no requirement that reimbursement be limited solely to services delivered within the four walls of a facility operated by a Qualified Entity. Reimbursement will be equivalent to the outpatient All-Inclusive Rate.
THCPs covered under this demonstration may only be provided by or through facilities operated by Qualified Entities that are enrolled as Medicaid providers. To deliver THCPs, Qualified Entities will employ or contract with THCP practitioners (sometimes also referred to as traditional healers or Tribal doctors). The Qualified Entities must be enrolled in Medicaid, but the THCP practitioners will not be required to individually enroll in Medicaid.
Hypothesis and Evaluation
Through an independent evaluator, and informed by Tribal consultation processes, the Department will develop a plan to evaluate the hypothesis indicated below in Table 1. The Department, with Tribal consultation, will identify validated performance measures that assess the impact of the demonstration on these populations. The Department will submit the evaluation plan to CMS for approval in accordance with CMS’s Special Terms and Conditions and will conduct and submit ongoing monitoring reports as required by CMS.
Table 1: Hypothesis and Measure
| Hypothesis | Measure | Data Sources |
| Alaska Native/American Indian Medicaid beneficiaries receiving services from a Qualified Entity will have increased access to Tribally appropriate care, including traditional health care practices. | Recipients will utilize traditional health care practice services. | Medicaid Management Information System claims for traditional health care practice services and, as applicable, other administrative data. |
Projected Enrollment and Annual Aggregate Expenditures
The Department anticipates that this demonstration in its entirety will be “deemed” budget neutral, consistent with how CMS has treated other states’ Section 1115 demonstrations with approval to cover THCPs. In other words, this demonstration is not likely to increase overall Medicaid expenditures beyond what those expenditures could have been without the demonstration.
The projected average annual enrollment for individuals eligible for THCPs under this demonstration is presented in Table 2 below. This corresponds to the estimated average number of AN/AI individuals enrolled in Alaska’s Medicaid program at the end of SFY 2026 and projected to each demonstration year (DY) using a 0.7 percent annual growth rate.
Table 2: Average Annual Eligibility Projection for Individuals Eligible for THCPs Under Demonstration
| Traditional Health Care Practices | DY 1 (12/31/26–12/30/27) | DY 2 (12/31/27–12/30/28) | DY 3 (12/31/28–12/30/29) | DY 4 (12/31/29–12/30/30) | DY 5 (12/31/30–12/31/31) |
| Average Eligibility | 80,335 | 80,897 | 81,463 | 82,033 | 82,608 |
Table 3 below includes the projected number of individuals who will utilize services through the ATHCP, their per-member per-month (PMPM) costs, and total expenditures associated with this demonstration.
Table 3: Number of Individuals Projected to Use THCPs and Associated Expenditures
| DY 1 | DY 2 | DY 3 | DY 4 | DY 5 |
| Traditional Health Care Practices | Member Months | 0 | 5,314 | 7,222 | 8,812 | 10,013 |
| Unique Annual Utilizers | 0 | 1,156 | 1,572 | 1,918 | 2,179 |
| PMPM Costs | $0 | $2,779.34 | $2,963.89 | $3,160.69 | $3,370.56 |
| Total Expenditures | $0 | $14,769,406 | $21,405,190 | $27,851,990 | $33,749,403 |
Consistent with CMS’s longstanding interpretation of section 1905(b) of the Social Security Act, the Department anticipates the Department will receive a 100 percent federal medical assistance percentage for all expenditures on the services for which coverage is authorized under this demonstration.
Proposed Waiver and Expenditure Authority
The Department requests the following proposed expenditure and waiver authority to operate the demonstration.
Expenditure Authority
The Department is seeking expenditure authority for THCPs received through a Tribal health program as defined in 25 U.S.C. § 1603(25), by AN/AI Medicaid beneficiaries who are able to receive services delivered by or through a Qualified Entity.
Waiver Authority
Comparability; Freedom of Choice. Section 1902(a)(23), Section 1902(a)(10)(B). To the extent necessary to allow the Department to offer the coverage described in the expenditure authority above only if the covered THCPs are received through a Tribal health program as defined in 25 U.S.C. § 1603(25) by AN/AI Medicaid beneficiaries who are able to receive services delivered by or through these Qualified Entities.
Section 1115 Demonstration Application Public Comment Process
The 30-day public comment period for the proposed Section 1115 demonstration application is from October 5, 2026, through November 4, 2026. All comments must be received no later than 5 p.m. Alaska Time on November 4, 2026, to be assured consideration prior to submission of the ATHCP Demonstration application to CMS.
The full draft of the demonstration application is attached to this notice. All information regarding the proposed demonstration application can be found on the Department website at: https://health.alaska.gov/en/services/alaskas-traditional-health-care-practices-1115-demonstration-waiver/. The Department will update this website throughout the public comment process.
Hard copies of the demonstration application are available at:
Department of Health – Office of the Commissioner
3601 C Street, Suite 902, Anchorage, AK 99503
Public Comment Process
To submit public comments on the Section 1115 demonstration application, please send them via email to doh.thcp.1115@alaska.gov or mail them to:
Department of Health
Commissioner's Office
Attn: Christal Hays
3601 C Street, Suite 902
Anchorage, AK 99503
Public comments and additional information will be posted and updated regularly on the web throughout the duration of the public comment period here:
https://health.alaska.gov/en/services/alaskas-traditional-health-care-practices-1115-demonstration-waiver/.
Public Hearing Schedule
The public is also welcome to attend or call into the following public hearings to learn more about the demonstration application, ask questions, and provide public comments:
Public Hearing #1
- Date & Time: Wednesday, October 14, 2026, from 3–4 p.m. AKT
- Location: Alaska Office Building, 350 Main Street, 4th Floor, Conference Room/Ste. 404, Juneau, AK 99801
- Virtual Option:
Public Hearing #2
- Date & Time: Friday, October 16, 2026, from 3–4 p.m. AKT
- Location: Frontier Building, 3601 C Street, 8th Floor, Conference Room/Ste. 898, Anchorage, AK 99503
- Virtual Option:
- Meeting ID: 987 1355 1968
- Passcode: 927995
Individuals with disabilities who require special accommodations in order to attend these public meetings should contact doh.thcp.1115@alaska.gov to ensure that any necessary accommodations can be provided.
After reviewing comments received during the state public comment period, the Department will submit the demonstration application to CMS. Interested parties will also have an opportunity to provide comments during the federal public comment period following CMS publication of the application.
[1] Indian Health Care Improvement Act § 4(25), Pub. L. No. 94-437, as amended by Pub. L. No. 117-58, codified at 25 U.S.C. § 1603(13).
For reference, the definition of “Indians or Indian” is:
“any person who is a member of an Indian tribe, as defined in subsection (d) hereof, except that, for the purpose of sections 1612 and 1613 of this title, such terms shall mean any individual who
(A), irrespective of whether he or she lives on or near a reservation, is a member of a tribe, band, or other organized group of Indians, including those tribes, bands, or groups terminated since 1940 and those recognized now or in the future by the State in which they reside, or who is a descendant, in the first or second degree, of any such member, or
(B) is an Eskimo or Aleut or other Alaska Native, or
(C) is considered by the Secretary of the Interior to be an Indian for any purpose, or
(D) is determined to be an Indian under regulations promulgated by the Secretary.”
[2] Indian Health Care Improvement Act § 4(25), Pub. L. No. 94-437, as amended by Pub. L. No. 117-58, codified at 25 U.S.C. § 1603(25).
For reference, the definition of “Tribal Health Program” is:
“an Indian tribe or tribal organization that operates any health program, service, function, activity, or facility funded, in whole or part, by the Service through, or provided for in, a contract or compact with the Service under the Indian Self-Determination and Education Assistance Act (25 U.S.C. 450 et seq.).”