Will NY need federal waivers to implement the NY Health Act? What about ERISA?

Answer

In order to efficiently integrate existing federal funds (Medicare, the federal share of Medicaid and CHIP, ACA subsidies) into the new system, the New York Health program will seek waivers from the federal government that will enable bulk transfer of these funds to the state based on global, prospective budgeting. 

For a more thorough overview of the issue, read the FAQs on federal waivers and ERISA.