Frequently Asked Questions

State Medicaid Director (SMD) Letter #11-004 and SMD Letter #10-016 indicate that states may request 90/10 HITECH administrative funding for HIE infrastructure under the Medicaid EHR Incentive Program. To request this funding, states must submit an Implementation Advance Planning Document Update (IAPD-U) using the approved template, which can be found at http://www.cms.gov/Regulationsand-Guidance/Legislation/EHRIncentivePrograms/Downloads/Medicaid_HIT_IAPD_Template.pdf. In particular, the IAPD-U template Appendix D outlines all the information required for an HIE funding request. The HIE funding request may be submitted in a separate IAPD-U, or it may be included in an IAPD-U that requests other funding for the state's Medicaid EHR Incentive Program.

CMS asks that states reach out early to their regional CMS HITECH contacts if they are considering submitting an IAPD-U for HIE funding. Given the complexity of an HIE request, along with the parameters set out in SMD Letter #11-004, CMS prefers to have one or more preliminary discussions to go over the state's current IAPD landscape, the state's technical model, and the state's approach to meeting the fair share and cost allocation principles.

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FAQ ID:92536

Under State Medicaid Director (SMD) Letter #11-004 and SMD Letter #10-016, states may request 90/10 HITECH administrative funding to on-board providers that are eligible for the Medicaid EHR Incentive Program. In this context, on-boarding refers to the HIE's activities involved in connecting a provider to the HIE so that the provider is able to successfully exchange data and use the HIE's services. This HITECH funding is available to cover an HIE's reasonable costs (e.g., interfaces and testing) to on-board eligible providers-that is, the costs incurred by an HIE to on-board a provider. This funding cannot cover the providers' costs to supplement the functionality of providers' specific EHR, nor can it cover the EHR vendors' costs. It is CMS' view that such on-boarding activities meet the criteria set forth in SMD Letter #10-016, Enclosure C.

Funding for on-boarding must comply with the guidance in SMD Letter #11-004 with respect to the fair share principle and cost allocation. However, funding for on-boarding can be used only to connect providers to the HIE if those providers are eligible for Medicaid EHR Incentive payments. Because funding for on-boarding will not directly benefit parties who do not participate in the Medicaid EHR Incentive Program, the fair share principle will be satisfied without contributions from other payers. All appropriate on-boarding costs can be cost allocated entirely to the 90/10 HITECH funding.

Please note that all Medicaid HITECH funding for HIE activities must enable Medicaid providers to meet meaningful use.

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• This FAQ was released as part of a larger set. View the full set. (PDF, 288.05 KB)

FAQ ID:92541

Yes, we encourage states to request 90/10 HITECH administrative funding for DDI of public health HIE infrastructure under the guidance provided in State Medicaid Director (SMD) Letter #10-016 and SMD Letter #11-004. States may request HITECH funds to design, develop, and implement a public health HIE infrastructure that will enable providers to meet the meaningful use objectives related to public health (i.e., electronic lab reporting, immunization registries, cancer registries, specialized registries, and syndromic surveillance). Please note that this funding for public health activities is available for states that plan to create an interface through their HIE to allow providers to submit data to public health departments through a single portal. CMS encourages states to take advantage of this funding to create the functionality at the HIE level. If providers who are not eligible for the Medicaid EHR Incentive Program will also benefit from this infrastructure, the state's request must address the fair share principle and cost allocation. CMS will only reimburse these costs at the 90 percent match rate to the extent they benefit the Medicaid EHR Incentive Program. Other entities that contribute to the HIE must contribute their agreed-upon share.

Please note that the allocation of costs to the Medicaid EHR Incentive Program may vary for different components of the public health infrastructure. For example, the Medicaid EHR Incentive Program may benefit proportionally more from interfaces to an immunization registry than to a cancer registry.

The public health landscape greatly varies among states, and CMS encourages interested states to reach out to their CMS regional HITECH contacts to discuss any proposed HIE funding requests prior to submitting an Implementation Advance Planning Document Update (IAPD-U).

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• This FAQ was released as part of a larger set. View the full set. (PDF, 288.05 KB)

FAQ ID:92546

Yes. Under Stage 2 meaningful use, providers must provide patients the ability to view online, download, and transmit the patients' health information. CMS understands that for many providers, utilizing a PHR through a HIE will be the best way to achieve this objective. As such, CMS allows states to request funding for PHRs under the Medicaid EHR Incentive Program's guidelines for requesting HIE funding. The parameters for this funding are outlined in State Medicaid Director (SMD) Letter #10-016 and SMD Letter #11-004, which emphasizes the fair share and cost allocation principles. For a provider to use the PHR service via the HIE, the PHR technology would need to be certified as an EHR Module to meet the meaningful use objective's certification criterion. When reviewing a state's request for PHR funding, CMS will consider how the proposed PHR solution affects the state's entire HIE landscape and whether there are any other PHRs options in the state. CMS expects any proposed PHR solution to support providers and stakeholders throughout the state, and not just those who are eligible for the Medicaid EHR Incentive Program. This strategy will best promote sustainability by bringing in other payers and by avoiding the creation of silos.

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• This FAQ was released as part of a larger set. View the full set. (PDF, 288.05 KB)

FAQ ID:92551

As State Medicaid Director (SMD) Letter #10-016 makes clear, states cannot use HITECH administrative funds on activities that could otherwise be funded with MMIS matching funds. That includes activities related to developing and implementing functionality to allow patients to download their data that is housed in the MMIS, because states could potentially use MMIS funds to create this functionality for claims or clinical data that is housed within the MMIS. It is CMS policy that MMIS funding is available for clinical decision support functionality that ties directly to the MMIS to reduce cost and improve outcomes. See 42 CFR 433 Subpart C, and State Medicaid Manual Part 11. Please note that MMIS funding would not be allowable for infrastructure outside the MMIS environment.

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FAQ ID:92556

Yes, states can utilize 90/10 HITECH administrative funding to update existing HIE infrastructure to align with new Federal HIE guidelines and requirements to exchange data with Federal agencies. For funding to be available for this purpose, the HIE infrastructure must be used to support Medicaid eligible providers in achieving meaningful use; for instance by supporting the achievement of the requirement to submit a summary of care record electronically for more than 10 percent of eligible transitions.

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FAQ ID:92561

Yes, states can utilize 90/10 HITECH administrative funding for the Medicaid EHR Incentive Program to upgrade existing Direct infrastructure, which supports eligible providers in achieving relevant meaningful use objectives, to align with ONC guidelines. For instance, states could use the funds to move from a single certificate for a Health Information Service Provider (HISP) to certificates being issued to each health care related organization in a HISP or a more granular component of an organization (e.g., by department or by individual).

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• This FAQ was released as part of a larger set. View the full set. (PDF, 288.05 KB)

FAQ ID:92566

The Affordable Care Act established an income disregard equal to five percentage points of the FPL disregard "for the purposes of determining income eligibility" for individuals whose eligibility is based on MAGI. In our final rule issued July 15, 2013, we provide that the disregard is applied to the income calculation of individuals only to the extent that the disregard matters for the purposes of determining eligibility for Medicaid or CHIP under MAGI-based rules-that is, those for whom the application of the disregard means the difference between being eligible for Medicaid or CHIP and being ineligible.

The disregard matters for purposes of determining Medicaid or CHIP eligibility only in cases where individuals have MAGI-based income that is above the highest applicable income standard under the program (Medicaid or CHIP), but would be within that income standard if the disregard were applied. This is the case only when the MAGI-based income is no higher than five percent of the FPL higher than that income standard. The disregard would not be applied for a determination of the particular eligibility group in which the individual qualifies, but only for overall eligibility for Medicaid or CHIP. We understand that this policy changes how disregards have been applied in the past, but believe this policy should be administratively simple to apply, for example, by applying the disregard at the point before a decision of ineligibility based on income would otherwise be made. This also ensures that the disregard does not reduce the "newly eligible" population for whom the increased federal matching rate is available.

For example, in a state that extends coverage to the new adult group, if a parent applied and has MAGI-based income within five percentage points of the FPL above the net income standard for the mandatory parent/caretaker relative group, the disregard would not apply because the disregard would not be needed for eligibility. The parent could be made eligible in the adult group instead. In that same state, if a parent applied with MAGI income within five percentage points of the FPL above the net income standard for the adult group (133% FPL), the five percent disregard would be applied to ensure that the parent could obtain eligibility in Medicaid and the parent would be made eligible in the adult group.

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FAQ ID:92591

Preventive services include immunizations, screenings for common chronic and infectious diseases and cancers, clinical and behavioral interventions to manage chronic disease and reduce associated risks, and counseling to support healthy living and self-management of chronic conditions, such as those associated with obesity. A list of preventive health care services recommended as Grade A or B by the U.S. Preventive Services Task Force can be found at: https://www.uspreventiveservicestaskforce.org/Page/Name/uspstf-a-and-b-recommendations/.

Through Medicaid's children's benefit - Early and Periodic Screening, Diagnostic and Treatment (EPSDT) - children under age 21 enrolled in Medicaid are assured coverage for preventive and comprehensive health services. States cover adult preventive services within Medicaid through both mandatory and optional benefit categories. Some preventive services (such as those related to family planning) may be defined in a state's mandatory set of benefits while others may be included in the optional benefit category. As a result, Medicaid programs differ from state to state on the coverage of preventive services for adults.

Obesity-related services are those services that help prevent and manage unhealthy weight. Medicaid and CHIP programs can cover a range of services to prevent and reduce obesity including Body Mass Index (BMI) screening, education and counseling on nutrition and physical activity, prescription drugs that promote weight loss, and, as appropriate, bariatric surgery.

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FAQ ID:92666

Affordable Care Act Section 4004(i)(2) calls for "state public awareness campaigns to educate Medicaid enrollees regarding availability and coverage of preventive and obesity related services with the goal of reducing incidences of obesity." The statute tasks states with designing the public awareness campaign because states have a better understanding of what outreach efforts will best meet the needs of their state Medicaid and CHIP population. Activities that provide information to beneficiaries about the preventive and obesity-related services covered in the state's Medicaid and CHIP programs will satisfy the requirement. Federal funding would be available for such activities as administrative costs of the Medicaid and CHIP programs.

Some resources that states may want to consider as they move forward with their activities include:

• Healthy Weight, Healthy People, Healthy Communities page on the Health Resources and Services Administration's website
• Centers for Disease Control and Prevention's Nutrition, Physical Activity and Obesity 
• "F as in Fat: How Obesity Threatens America's Future 2012," issued by the Trust for America's Health and the Robert Wood Johnson Foundation

States can receive the 50 percent Medicaid administrative matching rate for public awareness campaign activities, and will receive their existing Federal Medical Assistance Percentage (FMAP) rate for preventive services.

The Affordable Care Act includes additional funding for states that cover Grade A and B recommended services of the US Preventive Services Task Force (USPSTF) and all Advisory Committee on Immunization Practices (ACIP) recommended adult vaccines and their administration without cost sharing. CMS has released separate guidance on that provision which can be found at https://www.medicaid.gov/sites/default/files/Federal-Policy-Guidance/downloads/SMD-13-002.pdf (PDF, 138.73 KB).

In addition, CMS can provide technical assistance to states with reporting and interventions that they have in place to improve performance on the prevention core measures.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set. (PDF, 86.67 KB)

FAQ ID:92671