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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.

Showing 1 to 10 of 18 results

What is the Office of Management and Budget (OMB) Circular A -87 Exception?

OMB Circular A-87requires costs associated with building shared state-based Information Technology (IT) systems that support multiple health and human service programs be allocated across all benefitting programs in proportion to their use of the system. The OMB A-87 Exception revised this approach by allowing human service programs (e.g. SNAP, TANF, LIHEAP, etc.) and others to utilize a wide range of IT components, needed by Medicaid but also of use to these other programs, at no additional cost except for interfaces or other uniquely required services specific to those programs. The A-87 Exception applies only to design, development, and implementation. Maintenance and operations work should continue to be allocated in accordance with the A-87 Circular. OMB Circular A-87  â€“ Cost Principles for State, Local, and Indian Tribal Governments, has been Relocated to 2 CFR, Part 225 .

FAQ ID:93611

When does the OMB A-87 Exception expire?

On July 20, 2015, the U.S. Department of Health and Human Services and the U.S. Department of Agriculture announced a three-year extension of the Exception to the OMB A-87 cost allocation requirements from December 31, 2015 to December 31, 2018. We are currently making plans for the OMB A-87 exception to end.

FAQ ID:93616

What is the impact of the OMB A-87 expiration for states utilizing the exception for system integration development?

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

How should states account for OMB A-87 exception in their Advance Planning Documents (APD)

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

How do I withdraw a submission package?

A State may withdraw a submission package once it has been submitted to CMS. Withdrawing a submission package takes it out of contention and the submission package cannot be edited or resubmitted. Log in as State Point of Contact, and select the "Records" tab. Then select "Submission Packages" for your State. Next, select the link to the submission package you wish to withdraw. In the left panel, select "Related Actions". Next, select "Withdraw Submission Package". Then select the green button labeled "Withdraw Submission Package". A box will pop up, select "Yes". Once the submission package is withdrawn, you will be redirected to the Records screen. A yellow notification will appear briefly at the top of the page indicating "Action Completed Successfully".

FAQ ID:92891

How do I allow CMS to view my submission package prior to submitting?

After the State Editor has forwarded the submission package to the State Point of Contact for Reviewing, the State Point of contact should log into MACPro. Then go to the "Records" tab and select "Submission Packages" for your state. Select the submission package you wish for CMS to view. In the left panel, select "Related Actions". Next, select "Allow CMS to View Screen". On the Allow CMS to View Screen page, select "Yes" under Visibility Setting, and then select the green "Update Visibility" button in the bottom right corner.

Note: Selecting this option will permit the CMS review team to see the screens in this submission package as they are now. It does not cause the package to be submitted as Draft or Official, and does not start a CMS review clock. Validation of the screens is not required. Notify your CMS contact that viewing is available and who you wish to see it; MACPro does not notify CMS staff. You can deselect this option at any time.

FAQ ID:92896

What functions can my role perform?

Refer to the table below.

Role Actions
State Editor (SE)
  • Responsible for creating SPA submission packages
State Point of Contact (SPOC)
  • Responsible for reviewing and submitting the SPA submission package to CMS
  • Responds to Requests for Additional Information (RAIs) from CMS
  • Documents and reviews Correspondence Log
State Director (State Director)
  • Reviews and certifies SPA submission packages
State System Administrator (SSA)
  • Creates/maintains State Profile

FAQ ID:92901

How do I assign a SPA ID?

The SPA ID is assigned by the State Editor and entered in a field in Official Submission packages. The SPA ID (SS-YY-NNNN-xxxx) is assigned by the State in Official Submission Packages and consists of the State abbreviation (SS), they year (YY), a four character sequence number (NNNN), and an optional four character alpha and numeric (xxxx).

FAQ ID:92906

How do I access previous submission packages for my state?

Select the "Records" tab in the upper tool bar. Select "Submission Packages" for your state and then search for the package you would like to view.

FAQ ID:92911

What is the difference between a Draft Submission Package and Official Submission Package?

Official Submission Package

CMS suggests initially submitting simple program amendments or new programs that are similar to existing programs as official submission packages.

Draft Submission Package

CMS suggests submitting complex programs or new Health Home models and new targeted amendments as draft submission packages.

Official submissions start the 90 day policy clock upon submission to CMS for review and disposition.

Drafts submitted to CMS do not start the 90 Day Policy Clock.

CMS may review and view package. States may allow CMS to view the submission package informally prior to official submission.
CMS may approve, disapprove, request additional information (RAI), or submit a clarification for the official submission package. CMS may review, but cannot approve, disapprove, implement an RAI, or request clarification for the draft submission package.
The State may allow CMS to view the submission package informally prior to official submission. When CMS returns the package to the State they may provide feedback in the correspondence log or offline.
If the state chooses not to edit the returned draft package, it may be closed and converted to an official package for submission to CMS starting the 90 Day Policy Clock.
If the state chooses to edit the returned submission package, the state must re-submit the draft to CMS as a draft submission package for re-review prior to closing the draft submission and converting to an official submission package.
Closed draft submissions cannot be edited.
Official submissions that were converted from drafts cannot be edited with the exception of the SPA ID and proposed effective date prior to submissions to CMS.

FAQ ID:92916

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