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Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

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With respect to self-attestation, if a provider only meets the 60 percent threshold or only meets the Board certification under CMS 2370-F, would the provider only have to attest to that one component to be eligible or is it necessary to meet both components?

Physicians must first self-attest to a primary care designation of internal medicine, family medicine or pediatrics. This attestation signifies that the physicians consider themselves to be eligible specialty practitioners. The self-attestation must then indicate whether the physicians consider themselves to be qualified because of appropriate Board certification or practice history as represented by a 60 percent claims history. Some physicians may be appropriately Board certified and have a 60 percent claims history.


There may be physicians with Board certification in a specialty not recognized for higher payment under the rule who actually practice as pediatricians, family practitioners or internists who would be eligible for higher payment. For example, an Obstetrician/Gynecologist (OB/GYN) who no longer practices in that specialty but practices as a family practitioner could appropriately self-attest to being a primary care provider. Such a provider would need to qualify based on the 60 percent threshold and not Board certification. Physicians that support their initial self-attestation with an attestation of appropriate Board certification can qualify only if they actually have the appropriate Board certification. Practice habits would not be applicable.

There may also be physicians with Board certification in one of the three eligible specialty areas who do not actually practice in those areas. They should not self-attest to being a primary care provider.

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FAQ ID:94016

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How should a physician who is certified in internal medicine, family practice or pediatrics by a Board other than the ABMS, the AOA or the ABPS self-attest under CMS 2370-F?

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FAQ ID:94031

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We understand that Deloitte (Center for Medicare & Medicaid Services contractor) will be calculating the average GPCI values across counties for each state to use in paying primary care providers under CMS 2370-F. When can we expect those values to be disseminated? Will the formula weight each county equally, or will some alternative weight be used based on county population or some other factor?

The Center for Medicare & Medicaid Services (CMS) disseminated the Deloitte fee for service tool to states through the CMS Regional Offices in early January. It permits states to develop rates for each code based on the decisions it makes about site of service and geographic adjustments. The formula used to develop the rate weights each county equally and does not incorporate a weighting factor for population. Using a rate weighted by population is not an option for states to use in developing their fee schedules.

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FAQ ID:94036

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We received the Deloitte Excel model but have been unable to open some of the files. Can you help?

CMS can produce the fee schedules for states that are unable to run the program. States should contact Christopher Thompson at Christopher.thompson@cms.hhs.gov.

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FAQ ID:94046

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What federal match rate is available to the states for administrative costs incurred from implementation of the CMS 2370-F rule?

The regular administrative federal match rate is applicable to administrative costs associated with implementation of this rule. Section 1905(dd) of the Social Security Act (the Act) authorizes increased Federal Medical Assistance Percentage (FMAP) only for eligible services provided by eligible providers pursuant to section 1902(a)(13)(C) of the Act

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FAQ ID:94226

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Are bonus payments and other incentive arrangements for health plans included in the CMS 2370-F methodology for determining the rate differential that is eligible for 100 percent (Federal Financial Plan) FFP?

We addressed the treatment of bonus payments and other incentive arrangements in terms of identifying the 2009 base rate in the final rule and take this opportunity to clarify that such arrangements are similarly excluded from the methodology for determining the rate differential.

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FAQ ID:94236

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Is the relevant Medicare rate both the 'floor' and 'ceiling' for health plan payments to eligible providers for eligible services under CMS 2370-F?

The applicable Medicare rate does effectively become the "floor" for payments to eligible providers for eligible services, but not the "ceiling." Health plans may pay above that rate depending on their specific contractual arrangements with providers.

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FAQ ID:94246

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Will Medicaid health plans be required to pay eligible providers the higher rate prior to receiving payment from the State for the higher rate?

While some plans may be able to pay the higher rate prior to receiving state funds, the final rule does not obligate a health plan to pay eligible providers the higher rate until they have been provided the funds to do so.

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FAQ ID:94251

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May providers self-attest through the use of a claims modifier to qualify for CMS 2370-F?

The State will issue a communication instructing providers that only those who are board-certified in a specified specialty/subspecialty or who meet the 60 percent threshold of appropriate claims history are eligible to receive the rate increase.

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FAQ ID:94271

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Can a state review providers whose claims meet the 60 percent threshold and assume that those providers would be automatically eligible?

Each physician must self-attest to being a qualified provider. It is not appropriate for a state to rely on a modifier to a claim for the initial self-attestation. Under the final rule, states are not required to independently verify the eligibility of each and every physician who might qualify for higher payment. Therefore, it is important that documentation exist that the physicians themselves supplied a proper attestation. That attestation has two parts. Physicians must attest to an appropriate specialty designation and also must further attest to whether that status is based on either being Board certified or to having the proper claims history. Once the signed self-attestation is in the hands of the Medicaid agency, claims may be identified for higher payment through the use of a modifier.

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FAQ ID:94276

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