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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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What cost allocation requirements apply to E&E projects and how can States use the temporary exception to OMB-A-87?

The requirements of Circular OMB-A-87 apply to the allocation of costs for design, development, and implementation (DDI) and maintenance and operations (M&O) of eligibility and enrollment (E&E) systems including the respective benefiting health insurance affordability programs: Medicaid, CHIP (for states that have separate Title XXI programs or for portions of separate CHIP programs in states that operate a combination CHIP/Medicaid program) and to CCIIO Grant Funding if the project will include functionality for Health Insurance Exchanges.

States can request the temporary exception to Circular OMB-A-87 requirements to use Medicaid enhanced funding for DDI costs of shared eligibility services that will benefit other human service programs (SNAP, TANF, childcare, and child welfare). The exception does not apply to M&O costs, and therefore states must cost allocate to benefiting programs for these costs. For more information, please see the State Medicaid Director Letter, dated July 20, 2015, at https://www.medicaid.gov/federal-policy-guidance/downloads/smd072015.pdf (PDF, 80.07 KB).

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FAQ ID:93341

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What information is available for States to reuse and where can it be accessed?

In zONE, states can find business process models, templates for concepts of operations, and other planning and development artifacts, business and technical requirements, Requests for Proposals (RFPs), Statements of Work (SOWs), system design documents, etc. CMS Eligibility & Enrollment (E&E) state leads are available to discuss and assist states in finding the right artifacts in the zONE collaboration spaces. Your SOTA team and your E&E state lead are available to answer specific questions about what might be available soon that is not already in the CALT.

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FAQ ID:93346

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Do Eligibility & Enrollment projects need to have Independent Validation and Verification (IV&V)?

An assessment for IV&V analysis of a state's E&E system development effort will be required for APD projects that meet any of the criteria contained in federal regulations at 45 CFR 95.626(a). If CMS determines that the IV&V analysis is required for a state's system development effort, the provisions contained in federal regulations at 45 CFR 95.626(b) and (c) apply. Additional guidance is available in the Medicaid E&E Toolkit, available at https://www.medicaid.gov/medicaid/data-and-systems/meet/index.html.

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FAQ ID:93351

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How should States report expenditures in the CMS-64 for approved enhanced funding for Eligibility & Enrollment Advanced Planning Documents?

Medicaid Budget Expenditure System/Children's Budget Expenditure System (MBES/CBES) has been modified to add new Medicaid Eligibility Determination System lines to the 64.10 Form series beginning with Quarter Ending March 31, 2011:

  • 28A - DDI of Medicaid E&E systems/cost of in house activities - 90% FFP
  • 28B - DDI of Medicaid E&E systems cost of private sector contractors - 90% FFP
  • 28C - Operation of an approved Medicaid E&E system/cost of in-house activities - 75 % FFP
  • 28D - Operation of an approved Medicaid E&E system/cost private sector contractors- 75% FFP

FAQ ID:93361

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Will section 1115 demonstrations continue beyond December 31, 2013?

The section 1115 waiver authority continues and whether a particular waiver continues will vary by State. CMS has been working with States individually to determine the appropriate waivers and expenditure authorities that will be extended beyond December 31, 2013. For example, States that have utilized demonstrations to expand eligibility to the childless adult population will no longer need the expenditure authority because this population will become a mandatory State plan population under the Affordable Care Act's Medicaid eligibility expansion. On the other hand, States that have utilized demonstrations to undertake delivery system reforms may still require waivers and/or expenditure authorities to execute those reforms beyond December 31, 2013.

CMS will work with States to develop and submit the transition plans that are required by the Special Terms and Conditions of each demonstration. These transition plans will serve as a vehicle for discussion of the various options that States will have in 2014 and beyond, including for populations with incomes above 133 percent of the Federal poverty level (FPL). CMS will engage with States during State Operations and Technical Assistance (SOTA) calls to work through State-specific transition issues.

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FAQ ID:93016

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Can the State Operations and Technical Assistance Team (SOTA) calls replace the requirement for submitting an 1115 transition plan?

The SOTA calls cannot replace the submission of a transition plan, as the plan is a required deliverable under the State's Special Terms and Conditions. However, we expect to use the SOTA calls as a platform for transition planning discussions. We are also available for additional calls with States as needed. We can accept as the State's required early deliverable, a summary of the issues that the State needs to address in the transition plan, given the specific features of its waiver and plans for 2014. We will work with States in subsequent months to fully develop the transition plan to ensure it is in place in time for 2014.

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FAQ ID:93026

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If a State's demonstration is expiring in 2012, can the State request an extension?

Yes. CMS will continue to consider section 1115 demonstration extension requests. However, the State's proposal must include a plan to address changes in its demonstration that would need to take place to ensure readiness for 2014. Please also note that extension requests are subject to the recently issued transparency final rule (http://www.gpo.gov/fdsys/pkg/FR- 2012-02-27/html/2012-4354.htm )and corresponding State Health Officials letter (http://www.medicaid.gov/Federal-Policy-Guidance/Downloads/SHO-12-001.pdf (PDF, 136.08 KB) (PDF 0 bytes)), which outlines the new public notice comment and process requirements.

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FAQ ID:93031

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How will Essential Health Benefits (EHB) be defined for Medicaid benchmark or benchmark-equivalent plans?

Since 2006, State Medicaid programs have had the option to provide certain groups of Medicaid enrollees with an alternative benefit package known as "benchmark" or "benchmark-equivalent" coverage, based on one of three commercial insurance products or a fourth, "Secretary-approved" coverage option. Beginning on January 1, 2014, all Medicaid benchmark and benchmark-equivalent plans must include at least the ten statutory categories of Essential Health Benefits. Under the Affordable Care Act, the medical assistance provided to the expansion population of adults who become newly eligible for Medicaid as of January 1, 2014, must be provided consistent with section 1937 benchmark authority.

For Medicaid alternative benefit plans, three of the benchmark plans described in section 1937 (the State's largest non-Medicaid HMO, the State's employee health plan, and the FEHBP BCBS plan) may be designated by the Secretary as EHB benchmark reference plans, as described in the EHB Bulletin (link below). A State Medicaid Agency could select any of these section 1937 benchmark plans as its EHB benchmark reference plan for Medicaid. There would be no default EHB benchmark reference plan for purposes of Medicaid; each State Medicaid Agency would be required to identify an EHB benchmark reference plan for purposes of Medicaid as part of its 2014-related Medicaid State Plan changes.

If the EHB benchmark reference plan selected for Medicaid were to lack coverage within one or more of the ten statutorily-required categories of benefits, the section 1937 alternative benefit plan would need to be supplemented to ensure that it provides coverage in each of the ten statutory benefit categories. This would be in addition to any other requirements for Section 1937 plan, including Mental Health Parity and Addition Equity Act compliance.

For more information about the Essential Health Benefits, please see CCIIO's bulletin from December 2011 (available at http://cciio.cms.gov/resources/files/Files2/12162011/essential_health_benefits_bulletin.pdf ) and the CMCS informational bulletin from February 2012 (available at http://www.medicaid.gov/Federal-Policy-Guidance/downloads/CIB-02-17-12.pdf (PDF, 71.68 KB).

FAQ ID:93036

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Could a State select a different Essential Health Benefits (EHB) benchmark reference plan for its Medicaid section 1937 alternative benefit plans than the EHB reference plan it selects for the individual and small group market?

Yes. A State is not required to select the same EHB benchmark reference plan for Medicaid section 1937 plans that it selects for the individual and small group market, and it could have more than one EHB benchmark reference plan for Medicaid (for example, if the State were to develop more than one benefit plan under section 1937).

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FAQ ID:93041

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Could a State select its regular Medicaid benefit plan as its section 1937 alternate benefit plan for the new adult eligibility group?

Yes. A State could propose its traditional Medicaid benefit package as a section 1937 alternate benefit plan under the Secretary-approved option available under section 1937 of the Social Security Act. The State would have to ensure that the ten statutory categories of EHB are covered, either through that benefit plan or as a supplement to that plan.

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FAQ ID:93046

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