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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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When should MMIS and /or E&E milestone reviews be conducted?

Alignment with the state's system development life cycle happens during the Project Initiation phase, specifically during Activity 1: Consult with CMS. The state should incorporate CMS milestone reviews into the state's project schedule. The flexibility is in scheduling, not whether milestone reviews are performed. Decisions made between the state and CMS are documented in the Project Partnership Understanding document and can be updated as needed throughout the life cycle.

FAQ ID:95051

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For E&E and MMIS, how often do the IV&V progress reports have to be submitted to CMS?

At a minimum, quarterly. Depending on the risk of project activity, the state and CMS may agree that more frequent reporting is appropriate. Any frequency greater than quarterly should be captured in the Project Partnership Understanding document.

FAQ ID:95071

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What is the benefit for a state to have milestone reviews with CMS?

Milestone reviews have proven to reduce risk by having earlier discussions where CMS can identify opportunities for efficiencies, facilitate collaboration with other states, and share other ideas that can save time, money, and effort. Identifying issues and opportunities earlier in the process will allow for a much greater impact than was experienced under the old process.

FAQ ID:93976

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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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Does CMS participate in the state's life cycle gate reviews?

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

FAQ ID:95056

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Does the IV&V 18-month compliance period apply to E&E systems?

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

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Do the documents in the artifacts table need to be created for every module?

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

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CALT is no longer available. Where should state artifacts and evidence be posted?

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

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