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START 11Addresses SE-4, SA-3, SA-6

Start: Putting policy change on the table as part of Horizon 3 transformation

The bottom line

Modernizing systems without touching policy only automates yesterday's rules.

See the thinking

Every state diagnosis we have participated in eventually arrives at the same finding: the primary barrier to improvement is often not the system but the policy encoded in it. Statutes and rules written for paper processes decades ago, verification requirements that cost more to administer than they protect, timelines that made sense in a mainframe batch cycle, categories that force people to be sorted before they can be served. Technology-only modernization treats all of this as fixed. That is not transformation; it is preservation with better tooling.

Horizon 3 work must treat policy as a changeable variable. Practically, this means designing experiments so they surface, document, and escalate the specific statutes, rules, and requirements that block better outcomes. When an end-to-end slice demonstrates that a requirement adds burden without adding protection, that finding should not die in a lessons-learned document. It should become structured, evidence-backed input to the bodies that can change the requirement: CMS for federal regulation, and legislatures for statute. The experiments drive changes in the law, with the evidence attached.

The mechanics for this already exist in miniature, and we have drafted them at full scale as proposed legislation. In miniature: the waiver authority at 45 CFR 95.627, discussed in C2, and the demonstration authorities under sections 1115 and 1115A. At full scale: the proposed Healthcare Outcomes Demonstration Act linked below is built entirely on this premise. Solution teams identify the specific requirement blocking an outcome, relief is granted through existing waiver authorities, each waiver is narrowly tailored and published with its written justification, and the accumulated waiver record becomes something no state currently has: an evidence-based map of which laws the future state actually requires changing. Policy change stops being a lobbying exercise and becomes a measured output of delivery.

For the standards program, the recommendation is concrete: build a policy-relief pathway into the Horizon 3 engagement standards, so that every protected experiment carries the ability to request, receive, and document relief; and report publicly, on a regular cadence, which policies experiments have identified as barriers to the outcomes CMS says it wants. A modernization program that cannot touch policy will only ever modernize the enforcement of yesterday's policy.

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