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 URLOur state uses multiple cost centers (routine and ancillary) in the calculation of our inpatient hospital Upper Payment Limit (UPL). Do the templates permit the use of multiple cost centers?
Yes, the templates allow the use of multiple cost centers. For example, if the state uses a cost methodology for ancillary services and a per-diem methodology for routine services, the state will complete one cost template and one per-diem template in order to account for these two cost centers. Every hospital would be featured in each of the two templates; however, to differentiate their provider information, the state would append the Medicare Certification Number (Medicare ID) (variable 112) with a letter, such as an -A or a -B. For example, if the Medicare ID was 123456, it would be depicted in the cost template as 123456-A and in the per diem template as 123456-B. If a Medicare Certification Number is not available then the state should append the Medicaid Provider Number. If there are multiple cost centers under either the cost or per-diem methodology, the state would separate out the cost centers within their respective templates. Each cost center should be associated with only one appended letter and these should be described in the notes tab. When using multiple cost centers, the state should insert a new tab in the templates that summarizes the UPL gap calculations for each of the ownership categories (state government owned, non-state government owned, and private), unless a summary worksheet is already included in the workbook.
FAQ ID:92261
SHARE URLIf we complete multiple inpatient templates for Diagnosis Related Groups (DRG) and per diem, should they be in the same file or separate files? Should there be a summary of all the inpatient Upper Payment Limits (UPLs) showing grand totals?
The state should complete one template each for the DRG and per diem UPL calculations and these should be placed in one file. The state should also include a summary worksheet in the same file that shows the UPL gap for each ownership category (state government owned, non-state government owned, and private). States should include all necessary supporting documentation.
FAQ ID:92276
SHARE URLCan the Outpatient Hospital (OPH) Services Upper Payment Limit (UPL) demonstration consider Clinical Diagnostic Laboratory (CDL) services?
Section 1903(i)(7) of the Social Security Act specifies a separate UPL for CDL services which limits payment to no more than the Medicare rate on a per test basis. To meet the statutory provision, the UPL for CDL services must be separately demonstrated from the OPH services UPL. States do not have the ability to "borrow room" from the CDL UPL and apply it to the OPH UPL.
FAQ ID:92401
SHARE URLThis table indicates what reports are available to CMS Users. These can be found under the "Reports" tab.
Report Name |
Description |
Available For |
Clock Status Report |
View the regulatory clock statuses |
CPOC, CMS Disapproval Coordinator, SRT Admin CMS Report Admin, |
State Agency Profile Report |
Overview of a State's Medicaid Plan including the prior 12 months' submission package history |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, CSA, SRT |
Submission Detail Report |
View details on packages by date |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Submission Statistics Detail Report |
View all Submission Packages currently in review |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD, SRRVW, SRT |
Submission Statistics Summary Report |
View summary of Submission Packages in a specific review status within a specified date range. |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Submission Summary Report |
Overview of submitted packages by date |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Staff Workload Report |
View the number of Submission Packages assigned to each CPOC and SRT member, as of the report run date. |
CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, CSA |
FAQ ID:92871
SHARE URLWhat is the Review Tool Report?
The Review Tool Report is a feature CPOCs, SRTs, Senior Reviewers, Package Approvers, Package Disapprovers, and CMS Report Admins can utilize to see Package Reviewable Units, Reviewers, Reviewable Unit Assessment Values, and Notes.
Log in as CMS Point of Contact or Submission Review Team member. Under the "Records" tab, select "Submission Packages". Then select the link to the submission package. In the left panel, select "Review Tool Report". You may sort the reviews of all Review Team members by Package Reviewable Unit, Reviewer, Reviewable Unit Assessment Value, or Note/Assessments by utilizing the drop-down boxes. You also have the ability to export this report to Excel by selecting "Export to Excel."
FAQ ID:92876
SHARE URLWhat is the purpose of each Analyst Note Type?
Analyst Notes are a form of brief internal communication for the CMS Review Team. These notes are a part of the official record; however, State users are not able to see these notes. Analyst Notes are part of the Review Tool for each Reviewable Unit and the SRT or CPOC may view the notes from other Review Team members (depending on the type of note) within the Review Tool, and add his/her own notes.
The CMS Point of Contact or Submission Review Team members may add Analysts Notes through the Review Tool. The types of notes available are referenced in a table below. You will start by logging in as the CMS Point of Contact or Submission Review Team member, then going to the "Records" tab. Under the "Records" tab select "Submission Packages" and then select the link to the package. In the left panel select "Analyst Notes". You will then have the ability to search notes entered by Review Team Members.
Analyst Note Type | Description | Visible By |
Note to self | Private note for self only | Self |
For POC (Formal Review) | Indicates information that should be included in disposition | CPOC |
For Review Team | For other Review Team members | CPOC and SRT |
For RAI | Indicates something that requires RAI | CPOC and SRT |
For Correspondence Log | Indicates information that should be communicated to the SPOC | CPOC and SRT |
Non SRT-User | Note on behalf of a CMS participant outside of the Review Team | CPOC and SRT |
General Note | A note that doesn't fall into another category | All |
Justification | Provides bases for a recommended disposition | POC Admin, CPOC and SRT |
Post-Recommendation | Included by other CMS users during the package disposition review | POC Admin, CPOC and SRT |
FAQ ID:92881
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