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.
Frequently Asked Questions
How does this durable medical equipment (DME) limit on federal financial participation (FFP) affect those states that are 90% managed care?
As we explained in the January 4, 2018 letter, only those items provided in the Medicaid program on a fee-for-service (FFS) basis are to be included in the aggregate expenditure calculation. DME reimbursed under a Medicaid managed care arrangement or a Medicaid competitive bidding contract are not subject to the FFP limitation. If a state is 90% managed care the state would only have to show compliance or a demonstration with the 10% of FFS utilization and expenditures for the relevant DME items.
FAQ ID:93531
SHARE URLDo the managed care organizations (MCOs), who are contracted to provide services to our Medicaid clients, have to comply with the durable medical equipment (DME) limit on federal financial participation (FFP)?
So long as the MCOs are not paid on a fee-for-service (FFS) basis, MCOs are not covered under this statute or subject to the limit on FFP. Only the relevant DME items provided in FFS are included in this limit.
FAQ ID:93536
SHARE URLAre states that provide durable medical equipment (DME) through a managed care arrangement required to submit the reconciliation data?
Only those items provided in the Medicaid program on a fee-for-service basis are to be included in the aggregate expenditure calculation. DME reimbursed under a Medicaid managed care arrangement or a Medicaid competitive bidding contract are not subject to the federal financial participation limitation.
FAQ ID:93541
SHARE URLCenters for Medicare & Medicaid Services is saying this durable medical equipment (DME) limit on federal financial participation is applicable only to fee for service (FFS). How about the Home and Community-Based Services (HCBS) waiver programs?
If the HCBS waiver includes FFS payments for DME, the state’s expenditures for DME would be subject to the limit.
FAQ ID:93546
SHARE URLUnder CMS 2370-F, may states continue to use discounted reimbursement rates for out-of-state or out-of-network eligible primary care providers, which may be less than the Medicare rate, for calendar years (CYs) 2013 and 2014?
CMS acknowledges the customary practice of reimbursing out-of-state or out-of-network providers at a base rate minus a defined percentage. The applicable Medicare rate effectively becomes the ‘floor’ for payments to eligible providers for eligible services rendered in CYs 2013 and 2014. Health plans may pay above that rate but not below.
Supplemental Links:
FAQ ID:92131
SHARE URLUnder CMS 2370-F, CMS has indicated that the CMS-64 will be modified for states to report the expenditures that will receive the 100 percent federal medical assistance percentage (FMAP) for the increased expenditures for primary care services. Will the CMS-21 also be modified to report these expenditures for the CHIP Medicaid Expansion population?
No. The only expenditures that count against the CHIP allotment and must be reported on the CMS-21 are those related to the Medicaid rate in effect on July 1, 2009. The difference between those rates and the 2013 and 2014 Medicare rates eligible for 100 percent FMAP are Medicaid expenditures and are reported on the CMS 64.9.
Supplemental Links:
FAQ ID:92116
SHARE URLDoes CMS require states to submit their 2019 Upper Payment Limit (UPL) demonstrations using the Office of Management and Budget (OMB) approved templates for Inpatient Hospital services (IPH), Outpatient Hospital services (OPH), and Nursing Facility services (NF) UPLs?
Yes, CMS requires states to use all of the OMB approved templates for their 2019 (07/01/2018 to 06/30/2019) UPL demonstrations submitted to meet the annual UPL reporting requirement and with State Plan Amendment (SPA) submissions. When submitting UPL demonstrations, use the following naming convention: UPL_<UPL Demo Date Range>_<Service Type Abbreviation>_R<Region Number>_<State Abbreviation>_<Workbook Number>.xls. Here is an example of the naming convention: UPL_20170701-20180630_IP_R01_CT_01.xls.
FAQ ID:92196
SHARE URLWhen a state pays at or less than the Medicare rate is it required to submit an Upper Payment Limit (UPL) demonstration using the template(s)?
No, if a state's payment methodology describes payment at no more than 100 percent of the Medicare rate for the period covered by the UPL then it does not need to submit a demonstration using the template(s). To show the state has met the annual UPL demonstration reporting requirement it should make CMS aware that it is paying no more than the Medicare rate.
FAQ ID:92201
SHARE URLIf a state's inpatient hospital, outpatient hospital, or nursing facility Upper Payment Limit (UPL) demonstration has been approved by CMS for demonstration year 2018, does the UPL template still need to be populated and submitted for 2018?
No, states that already have submitted their 2018 (07/01/2017 - 06/30/2018) inpatient hospital, outpatient hospital, or nursing facility services UPL demonstrations will not have to resubmit using the templates. In that instance, CMS will populate the templates using data already submitted by the state.
FAQ ID:92211
SHARE URLCan a state use an Upper Payment Limit (UPL) demonstration that was submitted within the fiscal year for purposes of demonstrating that a State Plan Amendment (SPA) change complies with the regulations in order to meet the State Medicaid Director Letter (SMDL) requirements?
Yes, a demonstration submitted within the fiscal year that is used to document that SPA methodology changes comply with the UPL requirements may be used to satisfy the SMDL requirements as long as no subsequent changes are made to the state's provider payment methodology prior to the state's annual submission and CMS has reviewed and accepted the demonstration.
FAQ ID:92216
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