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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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To allow providers to meet the "view/download patient data" meaningful use objective, may a state request funding for personal health records (PHRs) under the current guidance for requesting health information exchange (HIE) funding?

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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FAQ ID:92551

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Under the CMS guidance for funding health information exchange (HIE) activities, could a state use HITECH funds to develop and implement functionality to allow patients to download their claims and/or clinical data that is housed in the Medicaid Management Information System (MMIS), similar to the "Blue Button" program in the Department of Veterans Affairs?

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

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Does a state have the option to utilize 90/10 HITECH administrative funding to update existing health information exchange (HIE) infrastructure to align with new federal HIE guidelines and requirements to exchange with Federal agencies?

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

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Can a state use 90/10 HITECH administrative funding for the Medicaid EHR Incentive Program to upgrade existing Direct infrastructure to align with the Office of the National Coordinator for Health Information Technology's (ONC) Direct: Implementation Guidelines to Assure Security and Interoperability and/or requirements for exchanging with Federal agencies?

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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FAQ ID:92566

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With respect to MAGI conversion, how will the 5% disregard be applied?

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

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What methods can states use to execute conversion to modified adjusted gross income (MAGI) as required by the Affordable Care Act?

Effective January 1, 2014, MAGI eligibility rules will be used to determine eligibility for nonelderly, nondisabled eligibility groups. The transition to MAGI also involves converting current net income eligibility standards to MAGI standards. MAGI rules apply regardless of whether a state adopts the new adult eligibility group. The December 28, 2012 Modified Adjusted Gross Income (MAGI) conversion guidance (PDF, 177.59 KB) sets out options for a state to use a standardized MAGI conversion methodology (using Survey of Income and Program Participation (SIPP) data or with state data) or to propose an alternative methodology for converting to MAGI.

There are two potential ways of using the standardized MAGI conversion methodology:

  • States may choose to have CMS calculate the converted income levels for eligibility groups requiring conversion using state-adjusted data from the Census Bureau's SIPP; or
  • States may choose to use their own data as the source for applying the standardized conversion methodology.

For each eligibility group income level that needs to be converted, under the standardized MAGI conversion methodology, individuals whose net income is within 25 percentage points of the FPL below the current income standards will be selected (for example, if the current standard is 80 percent of the FPL, the analysis will include people with incomes between 55 and 80 percent FPL). The next step is to calculate disregards as a percent of FPL for each selected individual. The resulting average disregard amount as a percent of FPL is added to the current net income standard to get the converted standard.

For example, if the average disregard is 8 percent FPL, the converted standard would be 88 percent FPL. This basic process is the same regardless of whether SIPP data or state data is used.

Alternatively, states have the option to propose their own method, subject to approval by CMS. States are asked to provide a statement of intent by February 15, 2013 and must submit their MAGI conversion plans by April 30.

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FAQ ID:93931

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What issues should states consider in choosing which MAGI conversion method and data source to use?

Factors that states might want to consider in choosing an income conversion method and data source include whether the state currently maintains or can easily access the data that are needed to do the conversions, as well as the quality and completeness of the state's data. In addition, states will want to consider whether they have the analytical resources needed to do the conversions with their own data, how long it would take them to run the conversions and how much it would cost to pay a contractor to do the analysis. Finally, states should also consider preferences about using state-adjusted SIPP or state data.

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FAQ ID:93936

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If a state wants to use the Standardized MAGI Conversion Methodology with its own date, what data elements will it need to use?

Detailed information on how to use state data to apply the standardized conversion methodology is forthcoming, but in general states will need 1) information on net income of each person and the size of the Medicaid eligibility unit to establish which enrollees fall within the 25 percentage point band below the current net income standard; and 2) data on the total amount of disregards for each individual within the 25 percentage point band - if this is not stored as a data element in the state's system, this can be calculated by adding up individual disregards, or as the difference between gross income and net income.

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FAQ ID:93941

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What type of technical assistance is available to states on MAGI Conversion?

Technical assistance for states thinking through their MAGI conversion options is available through the State Health Access Data Assistance Center (SHADAC) at the University of Minnesota. SHADAC is available to help states understand the income conversion methods, the data sources that can be used (SIPP or state data), and factors for states to consider in choosing a methodology. CMS will do conversions for all states using the standardized conversion methodology with SIPP data. States that choose to use state data or that propose a different methodology will need to do the conversions themselves, and SHADAC is available to provide consultation with states as they work through the process. This help is available at no cost to states. States can contact SHADAC for help with income conversion at (612) 486-2439 or by emailing their questions to fmaphelp@shadac.org.

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FAQ ID:93946

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Can you explain more about how the survey data from the Survey of Income and Program Participation (SIPP) will be reweighted to reflect state demographics for purposes of MAGI Conversion?

To produce reliable state-level results, income conversions using SIPP data will be based on the entire national sample that has been re-weighted to account for state demographic characteristics. The purpose of the reweighting is to ensure that the analysis is done using a population whose characteristics are similar to each state's actual population. The variables used in reweighting include age, parent status, gender, race/ethnicity, total household income as a percent of FPL, types of unearned income (whether the household has any unearned income and whether it includes child support), and whether or not an individual has child care expenses. The re-weighting will be done separately for each state and will ensure that the distribution of these characteristics (and combinations of these characteristics) matches state totals from the Census Bureau's Current Population Survey. In some states, a few of these categories will need to be combined due to small sample size. CMS will be releasing a brief on SIPP and the re-weighting adjustments.

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FAQ ID:93951

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