Date: 2026-08-03.
Findings
- The scorer already assumes states walk. CBO's BBB estimate embedded substantial state non-participation (CBO, PPP analysis) — the NFIB-style holdout problem is the official base case, not a tail risk. H11.3 (federal fallback is the highest-value design feature) strengthens: a fallback isn't insurance, it's the difference between a national program and a blue-state program.
- Part of the §14.1 administrative agenda already executed: the March 2024 CCDF final rule addressed payment practices, rate-setting, and family copays (Federal Register). The administrative-action-only path has been partially consumed — its remaining headroom is smaller than the protocol assumed. Verify current status of the rule (litigation/CRA exposure per §11.5).
- Germany's lesson imported (ws15): an enforceable entitlement without supply produces litigation and compensation payments, not slots. For architecture 2 (Medicaid-model entitlement): treat the entitlement as an appropriations-forcing device and model the litigation-era transition costs explicitly.
- Integrity design brief: the ARPA aftermath shows supply-side operating grants worked without headline fraud scandal at $24B scale — a moderate-confidence data point that provider-side grants with state administration are governable. The Netherlands case (§15) remains the binding caution for demand-side clawback design.
- Medicaid holdout-state count and tribal set-aside details: pending, flagged for verification (two-source rule not yet met).
Feeds: §14 fallback scoring; §16 year-one agenda (recalibrate what's left of the admin-only path).