What information should a SMA provide to CMS as support when requesting a time study notification or response window greater than 2 days?

While CMS encourages a zero-notice approach, CMS’ standard is up to 2 days prior notice of a time study moment. CMS will also allow up to 2 business days for participants to respond to the moment. If a state believes that up to 2 days prior notice (and 2 days response) is insufficient, the state should propose an alternative approach to CMS and provide its rationale. CMS understands that states may be limited by technology, geography, and/or funding to meet this time study criteria. CMS will attempt to understand the state’s limitations in reviewing time study proposals. In those instances where a state requests a longer response window, the state should provide details on the timeframe in which moments have historically been completed (i.e., within 24 hours, 48 hours, 72 hours, or beyond). This data, along with a plan for how and when the state will come into compliance with CMS policy, will be analyzed to determine whether to grant an exception. In those instances where CMS approves an exception, the state should take extra measures in its review of time study results to ensure all responses are reported in a non-biased manner and that all responses accurately reflect the activity the participant was performing during the assigned moment.