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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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Can a state type information and data into unlocked fields in the Upper Payment Limit (UPL) templates or must the data from state-developed UPL reports/workbooks be mapped through, for example, V-Look-ups into the UPL templates?

Yes. Mapping data, through V-Look-ups, for example, is a much easier and consistent process for current and future UPL submissions. However, a state may choose to type information and data into unlocked fields in the UPL templates. When a state chooses to input data directly (not through a V-Look-up) into the template, it still must provide the supporting documentation with the source data. Additionally, the state should explain how it mapped data from the supporting documentation into the template. The Centers for Medicare & Medicaid Services utilizes the supporting information to confirm that the information in the templates is correct.

FAQ ID:92451

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Can a contractor that acts on behalf of the Medicaid agency submit the Upper Payment Limit (UPL) demonstrations to CMS?

No, the information must be submitted by the State Medicaid Director (or designated state official).

FAQ ID:92246

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Does CMS participate in the state's life cycle gate reviews?

No. CMS does not participate the state's in E&E or in MMIS system development life cycle (SDLC) level reviews.

FAQ ID:95056

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Does the IV&V 18-month compliance period apply to E&E systems?

Yes. The rules pertaining to procuring IV&V contracts (State Medicaid Director Letter 16-010) apply to both E&E and MMIS.

FAQ ID:95061

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Do the documents in the artifacts table need to be created for every module?

In most cases once they are created, the documents will simply be updated to account for the additional modules being planned or developed. A new document is not necessarily created for each module. If a state calls a document by a different name, the state should inform CMS of the name difference.

FAQ ID:95076

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CALT is no longer available. Where should state artifacts and evidence be posted?

Granting CMS direct access to the state's evidence repository is the preferred method for making evidence available to CMS. If that is not possible, the state may make other secure arrangements with CMS, such as using encrypted File Transfer Protocol (FTP). It is critical to follow all Health Insurance Portability and Accountability Act (HIPAA) regulations when submitting evidence that contains personal health information (PHI) and personally identifiable information (PII).

FAQ ID:95081

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Should IV&V progress reports include all the checklist sets every time they submit a progress report?

No. Only the checklists pertaining to the modules undergoing review need to be included, and that only for the report created in preparation for a milestone review. However, the IV&V progress report should include risks and recommendations for the entire project--not just those about to undergo a milestone review.

FAQ ID:95086

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Why are there Standards and Conditions (S&C) and Access and Delivery (A&D) criteria in the Information Architecture checklist?

When streamlining the core checklists (IA, TA and S&C checklists), we found that some criteria fit better in other checklists, so they were moved. To keep traceability simple for the states, we chose to keep the original identifiers for any criteria that were moved. The same holds true for criteria moved to the programmatic tab of the IV&V progress report template.

FAQ ID:95091

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Are Eligibility and Enrollment (E&E) systems now going to be certified the way MMIS systems are certified?

No, E&E systems are not subject to certification. Though the Medicaid Eligibility and Enrollment Toolkit (MEET) was based on the MMIS toolkit, the MEET was created as a way to align how CMS reviews Medicaid enterprise systems and is a means for CMS to provide technical assistance to the states.

FAQ ID:95096

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How can residential and adult day settings comply with the HCBS settings requirements while serving Medicaid beneficiaries who may wander or exit-seek unsafely?

Many Medicaid beneficiaries living with dementia and other conditions can have a heightened risk of wandering, or attempting to leave a setting (exit-seeking) unsafely. These behaviors are not necessarily constant or permanent.

Wandering occurs in ways that may appear aimless but often have purpose. People may wander simply because they want to move. Sometimes wandering responds to an unmet basic need like human contact, hunger, or thirst; a noisy or confusing environment; or because people are experiencing some type of distress, like pain or the need to use the toilet. Wandering can be helpful or dangerous, depending on the situation. Although people who wander may gain social contact, exercise, and stimulation, they can also become lost or exhausted.

Person-centered planning, staff training and care delivery are core components of provider operations to meet HCBS requirements while responding to unsafe wandering and exit-seeking behavior in an individualized manner.3 Person-centered services involve knowing individuals, and their conditions, needs, and history and using this knowledge to create strategies to assure that individuals are free to interact with others and the community in the most integrated way possible and still prevent injury for those who wander or exit-seek unsafely. Home and community-based settings must demonstrate that person-centered planning drives their operations and services for each person. The beneficiaries the settings serve must drive the person-centered planning process with assistance from a trained, competent, assessor, care manager or similar facilitator. The beneficiary should be able to get input from people who are important to him or her, while still reflecting the individual's input as much as possible. Person-centered plans and related decisions should be consistent with the person's needs and preferences, and informed by family members, caregivers, and other individuals that the beneficiary has identified as playing an important role in his or her life. The role of person-centered planning and the process for realizing this role is described in the final HCBS regulation and in guidance found on the Medicaid.gov website.

Person-centered service plans should be developed with the individual, and include their representatives as appropriate. The person-centered planning process should include a process that:

  • is informed by discussions with family members or other individuals who are important to them about key aspects of daily routines and rituals;
  • focuses on an individual's strengths and interests;
  • outlines the individual's reaction to various communication styles;
  • identifies the individual's favorite things to do and experience during the day, as well as experiences that contribute to a bad day;
  • proposes experiences that the person may enjoy as community engagement, and describes those factors or characteristics that the individuals would find most isolating or stigmatizing

To promote effective communication, which is at the core of person-centered planning and service delivery, provider staff serving beneficiaries who wander or exit-seek should receive education and training about how to communicate with individuals living with conditions that may lead to unsafe wandering or exit-seeking. Training programs may include important information on issues such as:

  • The most common types of conditions, diseases and disorders that lead to wandering behavior; the various stages of key conditions that result in increased risk of wandering and what to expect over time; and the potential impact of these conditions on the individual's ability to function.
  • Differentiating between most common types of conditions, diseases and disorders that lead to wandering behavior from serious mental illness or adverse environmental conditions such as overmedication or neglect.
  • Assessing individuals for co-occurring conditions (including barriers to sufficient adaptive skills and the ability to communicate with others) that increase risk for unsafe wandering or exit-seeking.
  • Understanding situations that led to past instances of unsafe wandering or exit-seeking or the desire to engage in them;
  • Principles of person-centered care planning and service delivery;
  • Strategies for identifying and handling behavioral expressions of need or distress.

In addition to previous guidance provided by CMS on the implementation of person-centered planning requirements outlined in the federal HCBS regulations defining home and community-based settings, integration of the following promising practices around person-centered planning specifically for people who wander or exit-seek unsafely is recommended:

  • Assessing the patterns, frequency, and triggers for unsafe wandering or exit-seeking through direct observation and by talking with the person exhibiting such behaviors, and, when appropriate, their families.
  • Using this baseline information to develop a person-centered plan to address unsafe wandering or exit-seeking, implementing the plan, and measuring its impact.
  • Using periodic assessments to update information about an individual's unsafe wandering or exit-seeking, and adjust the person-centered plan as necessary.

Supplemental Links:

FAQ ID:94926

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