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CMS to Improve 1115 Demonstration, State Plan Amendments, & 1915 Waiver Processes

Recent Releases and Announcements

Streamline and Improve 1115 Demonstration, State Plan Amendments, and 1915 Waiver Processes

On March 14th, 2017, the Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) issued a letter to Governors highlighting key areas for improved collaboration with states and more effective Medicaid program management. In the letter, CMS committed to engaging with states to make state plan amendment (SPA) and waiver reviews and approvals more transparent, efficient, and less burdensome. 

Earlier this week, CMS released two informational bulletins to outline activities they will undertake to improve the transparency and efficiency of the SPA/1915 approval process and the 1115 approval process.

View the State Plan Amendment and 1915 Waiver Process Improvements to Improve Transparency and Efficiency and Reduce Burden bulletin (PDF, 170.27 KB) (PDF 170.27 KB), and the Section 1115 Demonstration Process Improvements bulletin (PDF 133 KB).

A-87 Update

In 2011, the Office of Management and Budget offered a waiver of OMB Circular A-87 cost allocation rules to support the integration of eligibility systems between health and human services programs, such as the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF). This waiver allowed States that wish to build integrated systems to do so without having to allocate the costs of developing shared eligibility services to human services programs. Human services programs retained responsibility for covering any costs particular to their program needs.  Please refer to the January 23, 2012, Tri-Agency letter (PDF 189.44 KB) for requirements and additional details on considerations for using the exception and suggested system functionalities that can be integrated.

In 2015, a three-year extension of the A-87 waiver authority was offered through December 2018.  The extension enabled states to fund the initial development costs needed to retire their legacy eligibility determination systems and integrate their functionalities into improved systems. Moreover, this extension provided states more time to develop, refine, or test integrated systems to fully comply with Affordable Care Act functionalities.  Please refer to the July 20, 2015, Tri-Agency letter (PDF 80.07 KB) for further details on the A-87 waiver extension. Please note that many states have still not completed the process to integrate non-MAGI eligibility functionality into their newly modernized MAGI Medicaid eligibility systems. While human services integration is highly encouraged, it remains an optional task for states. Integration of all Medicaid eligibility into a single system, thereby reducing state and federal costs and facilitating a streamlined experience for Medicaid beneficiaries, is required per §42 CFR Part 435.912, 435.945, 435.949.

As a reminder, States will need to incur costs for goods and services furnished no later than December 31, 2018 to make use of this exception. This would mean that if an amount has been obligated by December 31, 2018, but the good or service has not yet been furnished by that date, then such expenditure must be cost allocated at the normal cost allocation.

States should consider the financial impact this will have on their state budgets, and amend their Public Assistance Cost Allocation Plan as appropriate to properly allocate costs to all the other benefitting non-Medicaid federal programs.

Please note, final regulations authorizing an enhancement to the Federal Medicaid matching rate for eligibility and enrollment systems modernization – increasing the level of Federal support from 50 percent to 90 percent for new systems builds and from 50 percent to 75 percent for maintenance and operations is permanent. 

Upcoming Calls and Webinars

Happening Today! Value-Based/Pay for Performance Rate Methodologies in a FFS Environment Training *REBROADCAST*

This session is being repeated due to technical difficulties with the original HCBS SOTA call conducted on October 17, 2017.

This training will highlight promising practices and strategies for developing value-based/pay for performance rate methodologies in a FFS environment. Lewis & Ellis with assistance from Navigant Consulting is currently the training lead through the Rate Review Multi-Award Contract overseen by the Division of Long Term Services & Supports (DLTSS). Lewis & Ellis and Navigant Consulting will present the training and Ralph Lollar, DLTSS Division Director, and the DLTSS Team will support the training and lead the Q&A Session.

Wednesday, November 8th 1:30-3pm

Audio Option #1: 1-844-396-8222 Your WebEx Meeting Number: 908 621 799

Audio Option #2 and Webinar 

Reminder! New Medicare Card Project Special Open Door Forum

Thursday, November 9 from 2 to 3 pm ET

This call will educate State Medicaid Agencies, Medicaid providers, Managed Care Organizations, Medicaid partners, and other Medicaid stakeholders about the change from Social Security Number-based Health Insurance Claim Numbers to new Medicare Beneficiary Identifiers (MBIs). A question and answer session follows the presentation. CMS discusses:

  • Background and implementation
  • MBI format
  • Timeline and milestones, including the transition period
  • Beneficiary outreach and education
  • How to get ready for the new number

To participate:

  • Dial-In Number: 800-837-1935; conference ID #: 49255212
  • TTY services dial 7-1-1 or 800-855-2880

For more information, visit the New Medicare Project  website and Transcripts  webpage.

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