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.
Frequently Asked Questions
What is the Office of Management and Budget (OMB) Circular A -87 Exception?
OMB Circular A-87requires costs associated with building shared state-based Information Technology (IT) systems that support multiple health and human service programs be allocated across all benefitting programs in proportion to their use of the system. The OMB A-87 Exception revised this approach by allowing human service programs (e.g. SNAP, TANF, LIHEAP, etc.) and others to utilize a wide range of IT components, needed by Medicaid but also of use to these other programs, at no additional cost except for interfaces or other uniquely required services specific to those programs. The A-87 Exception applies only to design, development, and implementation. Maintenance and operations work should continue to be allocated in accordance with the A-87 Circular. OMB Circular A-87 – Cost Principles for State, Local, and Indian Tribal Governments, has been Relocated to 2 CFR, Part 225 .
FAQ ID:93611
SHARE URLWhen does the OMB A-87 Exception expire?
On July 20, 2015, the U.S. Department of Health and Human Services and the U.S. Department of Agriculture announced a three-year extension of the Exception to the OMB A-87 cost allocation requirements from December 31, 2015 to December 31, 2018. We are currently making plans for the OMB A-87 exception to end.
FAQ ID:93616
SHARE URLWhat is the impact of the OMB A-87 expiration for states utilizing the exception for system integration development?
States will need to incur costs for goods and services furnished no later than December 31, 2018 to make use of this Exception. Therefore, if work is completed by December 31, 2018, it can be funded under the OMB A-87 Exception and states should follow typical invoicing and claiming processes. However, if an amount has been obligated by December 31, 2018, but the good or service is not furnished by that date, then such expenditure must be cost allocated by program in proportion to their use of the system in accordance with OMB A-87.
FAQ ID:93621
SHARE URLHow should states account for OMB A-87 exception in their Advance Planning Documents (APD)
For FFY2019 annual APDs and budget tables, including the Medicaid Detailed Budget Table (MDBT), must be completed as follows:
- For Q1 FFY2019, states can allocate costs in accordance with the OMB A-87 Exception
- For Q2-Q$ FFY2019, and all APDs going forward, states should allocate costs as required under the OMB A-87 Circular
If a state has already submitted their annual APDs without providing separate budgets they will need to complete an APDU with a revised MDBT and cost allocation plan. The update should address how cost allocation will be done prior to, and after, December 31, 2018. Budget tables should be completed as described above.
The Data and Systems Group (DSG) that approves APDs does not approve cost allocation methodology. States working to develop their new methodologies should send operational cost allocation plans to Cost Allocation Services and the regional office fiscal staff for all benefiting programs.
FAQ ID:93626
SHARE URLNow that Upper Payment Limit (UPL) demonstrations are submitted to a central e-mailbox, will the CMS Regional Office still have a role in reviewing UPL demonstrations or will the review be performed by the Central Office?
The Regional Office will continue to review state UPL demonstrations and states will continue to work with the CMS Regional Offices as a first point of contact concerning their UPL demonstrations.
FAQ ID:92256
SHARE URLFor our Nursing Facility (NF) Upper Payment Limit (UPL) calculation we separate Medicaid allowable costs into three categories: salaries and benefits, operating costs, and property costs. Based on previous guidance from CMS, we do not apply an inflation factor to the property costs. In looking at the template, it appears the inflation factor is applied to all costs. Is this correct?
Where inflation is not applied to property costs, please separate out this cost from the Medicare UPL by reporting these amounts in variable 402 - Adjustment to the Medicare UPL.
FAQ ID:92361
SHARE URLHow and when should the Medicaid hospital tax/provider assessment be included in the inpatient hospital template?
The cost of the tax should be reported in Variable 401 - MCD Provider Tax Cost. A state may separately report the Medicaid portion of the cost of a provider assessment/tax only when it is using a cost based methodology to calculate the UPL. A state may not include this cost when calculating a DRG or Payment based UPL demonstration.
FAQ ID:92366
SHARE URLHow do I view approved State Plan Content with current, previous, or future effective dates?
Under the "Records" tab, select "Medicaid State Plan". Next, search for a state using the search feature in the left panel. Select the blue link for your State Plan. On the next screen you will be able to see past, current and future Health Homes Programs.
FAQ ID:92856
SHARE URLWhat main functions can my role perform?
Primary Role | Definition |
CMS Package Disapprover (PD) |
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Office of Strategic Operations & Regulatory Affairs (OSORA) |
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CMS Senior Management (SrMGR) |
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CMS Package Approver (PA) |
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CMS Point of Contact Administrator (POC Admin) |
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Subject Matter Expert (SME) |
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Submission Review Team (SRT) |
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CMS Point of Contact (CPOC) |
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Report Administrator (RA) |
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Subscriber (SUB) |
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FAQ ID:92861
SHARE URLWhat does it mean if the State allows CMS to view?
The State has the option to allow CMS to view the information in a submission package prior to submission informally by using the "Allow CMS to View" functionality. The CMS Point of Contact, Submission Review Team, and Subject Matter Expert have the ability to view these submission packages once the state has initiated the function. Please Note: This option will permit the CMS review team to see the screens in this submission package as they appear currently. It does not cause the package to be submitted as Draft or Official, and does not start a CMS review clock. Validation of the screens is not required. States must notify their CMS contact that viewing is available; MACPro does not notify CMS staff. States can deselect this option at any time
To access the submission package, go to the "Records" tab and then select "Submission Packages". Next select the link to the submission package and then in the left panel, select "Reviewable Units". You may then select the blue links to each Reviewable Unit to view the data entered by the state.
FAQ ID:92866
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