Frequently Asked Questions

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

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

No. CMS does not participate the state's in E&E or in MMIS system development life cycle (SDLC) level reviews.

FAQ ID:95056

Yes. The rules pertaining to procuring IV&V contracts (State Medicaid Director Letter 16-010) apply to both E&E and MMIS.

FAQ ID:95061

In most cases once they are created, the documents will simply be updated to account for the additional modules being planned or developed. A new document is not necessarily created for each module. If a state calls a document by a different name, the state should inform CMS of the name difference.

FAQ ID:95076

Granting CMS direct access to the state's evidence repository is the preferred method for making evidence available to CMS. If that is not possible, the state may make other secure arrangements with CMS, such as using encrypted File Transfer Protocol (FTP). It is critical to follow all Health Insurance Portability and Accountability Act (HIPAA) regulations when submitting evidence that contains personal health information (PHI) and personally identifiable information (PII).

FAQ ID:95081

No. Only the checklists pertaining to the modules undergoing review need to be included, and that only for the report created in preparation for a milestone review. However, the IV&V progress report should include risks and recommendations for the entire project--not just those about to undergo a milestone review.

FAQ ID:95086

When streamlining the core checklists (IA, TA and S&C checklists), we found that some criteria fit better in other checklists, so they were moved. To keep traceability simple for the states, we chose to keep the original identifiers for any criteria that were moved. The same holds true for criteria moved to the programmatic tab of the IV&V progress report template.

FAQ ID:95091

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

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