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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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Our state included dental services along with physician (non-dental) services in our state's Upper Payment Limit (UPL) demonstration of the practitioner Average Commercial Rate (ACR) using the Medicare Equivalent of the ACR. Should we keep both services together in one demonstration or should we separate the services out for two different ACR demonstrations?

Dental services are not covered under Medicare, which means the state may not compare Medicaid rates for comparable dental services for the Medicare Equivalent of the ACR. The state may calculate a dental ACR in order to make supplemental payments to dental services providers and continue to calculate the Medicare Equivalent of the ACR for other services covered by Medicare. The state should submit two separate ACR demonstrations, one for dental services and one for physician (non-dental) services. This will involve completing two versions of the Office of Management and Budget-approved template. If the same provider provides both physician and dental services the state would differentiate the provider information between the two demonstrations by appending 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 physician ACR as 123456-A and in the dental ACR as 12345-B. If a Medicare Certification Number is not available then the state should append the Medicaid Provider Number.

FAQ ID:92441

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What materials does CMS require a state to submit as part of the Upper Payment Limit (UPL) Demonstration submission package?

The submission package consists of the completed templates and any supporting documentation needed to understand the UPL demonstration. This could include the completed Guidance document and supporting documentation (in Microsoft Excel with formulas included, not as a PDF) that is necessary to further explain a state's UPL demonstration, and a summary spreadsheet that aggregates the UPL gap for each of the ownership categories (state government owned, non-state government owned, and private).

FAQ ID:92236

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For 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

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What is the difference between "Medicaid Amount Reimbursed" vs. "Non-Medicaid Amount Reimbursed" in the State Drug Utilization Data (SDUD)?

A Non-Medicaid Reimbursed amount is any amount paid on a claim by parties other than Medicaid (e.g., other federal coverage, co-pay, private insurance). If a state receives Federal Financial Participation (FFP) for any part of a claim for a Covered Outpatient Drug (COD), that portion of the claim is included in the Medicaid Reimbursed amount. If a state does not receive FFP for any part of a rebate-eligible claim, then the amount of the claim is included in the Non-Medicaid Reimbursed amount.

FAQ ID:91981

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Why Does the "Medicaid Amount Reimbursed" and the "Non-Medicaid Amount Reimbursed" not equal the "Total Amount Reimbursed" in the State Drug Utilization Data (SDUD)?

The sum of the “Medicaid Amount Reimbursed” and the “Non-Medicaid Amount Reimbursed” fields should generally equal the Total Amount Reimbursed on a National Drug Code (NDC) by NDC basis; however, these new fields were implemented beginning with the fourth quarter of 2007 and are optional for the states to report prior to that time. Therefore, for quarters earlier than fourth quarter 2007, there may be some large discrepancies between the Total Amount Reimbursed and the sum of the Medicaid Amount Reimbursed and the Non-Medicaid Amount Reimbursed because the Non-Medicaid Amount Reimbursed is often not present for those earlier quarters. Should you notice apparent discrepancies in an individual state's utilization data, your questions should be directed to the State Technical Contact.

FAQ ID:91986

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Is the amount reimbursed by Medicaid net of rebates or pre-rebate in the State Drug Utilization Data (SDUD)?

Amounts reimbursed by Medicaid are pre-rebate, not net of rebates.

FAQ ID:92001

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Does the State Drug Utilization Data (SDUD) field "Units Reimbursed" represent the number of pills Medicaid paid for a drug that comes in a pill form?

"Units Reimbursed" are the number of units (based on Unit Type) of the drug (11-digit NDC level) reimbursed by the state or, for MCO drugs, the number of units dispensed during the Quarter/Year. For more specific information, you may contact either the Drug Manufacturer or State via the contact lists.

FAQ ID:92016

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When are states required to submit State Drug Utilization Data (SDUD) to the Centers for Medicare & Medicaid (CMS)?

States are required to submit their utilization data to CMS within 60 days of the end of the rebate period.

FAQ ID:92026

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How long does a state have to report State Drug Utilization Data (SDUD) that was not previously reported?

Per section 1927 of the Act, initial submissions of quarterly state utilization data are due to CMS within 60 days of the end of each rebate period. If a state fails to report utilization data in the quarter that it was dispensed, the state must submit initial utilization data for the most recently closed quarter as well as adjustments/corrections to any previously reported utilization data.

FAQ ID:92036

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Are all states required to participate in the Medicaid Drug Rebate Program (MDRP)? If not, is there a listing published by Medicaid indicating who is not participating?

Drug coverage under Medicaid is an optional benefit for the states. However, if a state opts to cover prescription drugs in their Medicaid program, they must participate in the MDRP.  As part of that participation in the MDRP, states are required to submit quarterly drug utilization data to CMS.  All states and the District of Columbia currently participate in the MDRP; therefore, they all submit quarterly drug utilization data to CMS.

FAQ ID:92061

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