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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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Our state included dental services along with physician (non-dental) services in our state's Upper Payment Limit (UPL) demonstration of the practitioner Average Commercial Rate (ACR) using the Medicare Equivalent of the ACR. Should we keep both services together in one demonstration or should we separate the services out for two different ACR demonstrations?

Dental services are not covered under Medicare, which means the state may not compare Medicaid rates for comparable dental services for the Medicare Equivalent of the ACR. The state may calculate a dental ACR in order to make supplemental payments to dental services providers and continue to calculate the Medicare Equivalent of the ACR for other services covered by Medicare. The state should submit two separate ACR demonstrations, one for dental services and one for physician (non-dental) services. This will involve completing two versions of the Office of Management and Budget-approved template. If the same provider provides both physician and dental services the state would differentiate the provider information between the two demonstrations by appending the Medicare Certification Number (Medicare ID) (variable 112) with a letter, such as an -A or a -B. For example, if the Medicare ID was 123456, it would be depicted in the physician ACR as 123456-A and in the dental ACR as 12345-B. If a Medicare Certification Number is not available then the state should append the Medicaid Provider Number.

FAQ ID:92441

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Can 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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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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Should IV&V progress reports include all the checklist sets every time they submit a progress report?

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

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Why are there Standards and Conditions (S&C) and Access and Delivery (A&D) criteria in the Information Architecture checklist?

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

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Are Eligibility and Enrollment (E&E) systems now going to be certified the way MMIS systems are certified?

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

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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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