Funding processes currently generate more money than most transformation efforts need, delivered in exactly the wrong shape: large, multiyear, tied to activities and deliverables defined before learning has occurred, and nearly impossible to course-correct. In our experience, by the time an approved funding request becomes running work, nearly everything about the original request has changed.
Horizon 3 APD increments should be sized to experiments, not to programs. A state should be able to seek approval for a bounded learning increment quickly, show measured results, and return for the next increment on the strength of those results, with the enhanced match following demonstrated value.
CMS may reasonably feel its current processes already allow this, and on paper they do. What is missing is the operating cadence: approval cycles measured in days rather than quarters, made by people close enough to the work to decide quickly. That is a job for the CMS transformation office described in S1, working directly with state teams to approve, review, and redirect small experiments at the speed the experiments move.
This gives CMS something it currently lacks: the ability to stop funding things that are not working while they are still small. Integrating standards compliance into this lifecycle then becomes simple, because each increment is small enough to assess directly against working software rather than against documentation.