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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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Are Eligibility and Enrollment (E&E) systems now going to be certified the way MMIS systems are certified?

No, E&E systems are not subject to certification. Though the Medicaid Eligibility and Enrollment Toolkit (MEET) was based on the MMIS toolkit, the MEET was created as a way to align how CMS reviews Medicaid enterprise systems and is a means for CMS to provide technical assistance to the states.

FAQ ID:95096

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Based on CMS guidance, states may take up to 18 months to bring an IV&V contractor on board to perform certification tasks or align current IV&V contract to comply with CMS guidance pertaining to scope of services and financial independence. What must the state do if the IV&V contractor's start up is delayed?

IV&V contractor activities must still be performed such as checklist evaluation, artifact review and preparation of IV&V Progress Reports. The state should provide a plan and timeline for how these activities will be supported and performed until the proper IV&V contract can be either procured or aligned with updated CMS guidance on IV&V.

FAQ ID:94866

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What is the applicability of Minimum Acceptable Risk Standards for Exchanges (MARS-E) 2.0 to states' Medicaid Management Information Systems (MMIS)?

MARS-E 2.0 compliance is not required by CMS for states' MMIS, but CMS recommends that states follow applicable national privacy and security standards and practices for their MMIS. MARS-E 2.0 compliance is required for states' Medicaid/CHIP Eligibility and Enrollment (E&E) systems in order to maintain their Authority to Connect with CMS. Link for more information about MARS-E 2.0: https://www.medicaid.gov/federal-policy-guidance/downloads/cib-09-23-2015.pdf (PDF, 105.5 KB).

FAQ ID:94871

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Can state Medicaid agencies access federal financial participation (FFP) to support system changes necessary to meet HIPAA, NIST cybersecurity, or MARS-E 2.0 standards?

For E&E and MMIS, enhanced FFP funding is available at 90 percent via the usual Advanced Planning Document process.

FAQ ID:94876

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Many State demonstrations require that a transition plan to 2014 be submitted by a specified date, in many cases by July 1, 2012. Will CMS provide guidance and technical assistance before then? What specifically is required to be included in the transition plan?

CMS plans to provide technical assistance on transition plans to States through the State Operations and Technical Assistance Team (SOTA) calls and through other calls with the State. We will also be providing additional guidance about the information that should be included in the transition plans. We will consider the transition plans that need to be submitted by the due date as living documents that are open to revision, and will continue to work with States to ensure a seamless transition in 2014 for beneficiaries and States.

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FAQ ID:93021

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How should states account for the cost of the Health Insurance Providers Fee in their actuarially sound capitation rates?

States and their actuaries have flexibility in incorporating the Health Insurance Providers Fee into the state's managed care capitation rates. This fee is not unlike other taxes and fees that actuaries regularly reflect in developing capitation rates as part of the nonbenefit portion of the rate. CMS believes that the Health Insurance Providers Fee is therefore a reasonable business cost to health plans that is appropriate for consideration as part of the non-benefit component of the rate, just as are other taxes and fees.

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FAQ ID:91126

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What methodologies are acceptable to account for the Health Insurance Providers Fee in capitation rates? Can states make retroactive adjustments to the capitation rates once the actual assessments on the health plans are known?

States have the flexibility to account for the Health Insurance Providers Fee on a prospective or retroactive basis. In the event that a prospective calculation results in a capitation rate that is too high or too low, the capitation rate may be adjusted after the actual tax assessment is known. States may also account for the fee prospectively by withholding such amounts until the health plan's actual fee is known. The capitation payment, net the amount of the withhold, must remain actuarially sound and the state can only claim Federal Financial Participation (FFP) on the actual expenditures paid from the withhold to reimburse the health plans for the fee.

States may account for the Health Insurance Providers Fee as an aggregated retroactive adjustment to the rates for the contract year once a health plan's liability is known. CMS anticipates that states would move to a prospective calculation as states and health plans obtain more experience with the fee.

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FAQ ID:91141

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Can the Health Insurance Providers Fee be paid to health plans as a separate payment after the plans' fee liability is known?

No. There is no Federal Financial Participation (FFP) available for Health Insurance Providers Fee payments made outside of actuarially sound capitation rates, per the requirements of section 1903(m)(2)(A(iii) of the Social Security Act and implementing regulations at 42 CFR 438.6(c)(2). Therefore, any payment for the fee-whether on a prospective or retrospective basis-must be incorporated in the health plan capitation rates and reflected in the payment term under the contract.

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FAQ ID:91151

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Are there any limitations around the use of the data year (e.g., 2013) or the fee year (e.g., 2014) as the base for any adjustment to the capitation rates to account for the Health Insurance Providers Fee?

There are reasonable ways to account for the Health Insurance Providers Fee as an adjustment to the states' capitation rates under either approach. In either approach, the amount of the fee should be incorporated as an adjustment to the capitation rates and the resulting payments should be consistent with the actual or estimated amount of the fee.

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FAQ ID:91161

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If the 2014 capitation rates are being adjusted to reimburse health plans for the Health Insurance Providers Fee due in 2014, should the adjustment be applied to every population?

No. Since the fee due in 2014 is based on the health plan's 2013 book of business, the adjustment should only apply to the capitation rates for populations that the state covered under the managed care contract in 2013. For example, states that chose to expand Medicaid eligibility starting January 1, 2014, should not adjust the capitation rates for the new adult eligibility group to account for the fee due in 2014, because they were not covered by the managed care plans in 2013. In future years, the Health Insurance Providers Fee will continue to be based on the book of business for the immediately preceding year, so this concept will apply in calculating the fee if any new populations are added to a state's managed care program.

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FAQ ID:91181

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