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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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If a state is reusing an MMIS system or module already certified in another state do they need to go through certification review and decision?

CMS encourages states to reuse modular solutions as much as possible. If a state can reuse a modular solution from another state with minimal changes or customization, CMS will work with the state to streamline the certification process as much as possible to leverage knowledge of the reused solution. However, CMS will still require a certification decision for each state implementation of reused solutions to ensure compliance with federal regulations.

FAQ ID:94896

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Which of the checklist paths (MITA, Module, Custom) described in the MECT are best for a state implementing a services-type solution?

All the criteria in the checklists (MITA, MMIS or Custom) are the same. The difference between checklists is the criteria organization within the checklists. If the services solution is innovative, unique, or an unconventional approach, then the custom checklist approach might be appropriate. The RO will work with the state and vendors to decide which checklist set is best suited for the state's certification. Both service and traditional-type solutions need to meet all certification criteria to ensure compliance with federal regulations.

FAQ ID:94901

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If the state conducts a staged rollout for implementing new MMIS Medicaid modules, will CMS pay for the overlapping costs?

Yes, CMS will support the costs for this kind of MMIS transition. We encourage states to ensure that both the current vendor's and new solutions provider's contracts account for this transition period and address a prorating of cost during this time. States should minimize the costs of transition by performing due diligence on the anticipated spending. The legacy system provider should be compensated for its role in ensuring a smooth transition, with a ramp-down of other operational costs. The new solutions provider should have deliverables in its contract that speak to the soft launch or phased launch approach, with an uptick in operational costs as the transition progresses.

FAQ ID:94906

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What security and privacy documents are state Medicaid agencies required to have for their MMIS?

State Medicaid agencies are required to have MMIS System Security Plan and Privacy Impact Assessment documents. State Medicaid agencies must perform regular routine security and privacy risk assessments to ensure the protection and safeguard of beneficiary data that is consistent with Health Insurance Portability and Accountability Act (HIPAA) privacy and security rules. Please refer to the MECT for more details: https://www.medicaid.gov/medicaid/data-and-systems/mect/index.html

FAQ ID:94911

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Can the Systems Integrator (SI) be awarded contracts for development of modular components within the MMIS project?

Yes. While CMS envisions a discrete role for the System Integrator (SI) in each state, with specific focus on ensuring the integrity and interoperability of the Medicaid IT architecture and coherence of the various modules incorporated into the Medicaid system complex, it is permissible for an SI to provide modules as part of the overall solution. The target outcome for the SI in support of the state should be to foster best-in-breed solutions for Medicaid business requirements, with the SI responsible for the successful integration of the chosen solutions and infrastructure into a seamless functional system. The SI must ensure that all modules have open APIs and remain loosely coupled. More information on the SI role can be found in Section 1.7 of the Medicaid Enterprise Certification Life Cycle, part 01 of the MECT. States are encouraged to use an acquisition approach that limits the potential for conflict of interest an SI may have in choosing the modular solutions to be incorporated into the system. As described above, the goal is to avoid lock-in to a single vendor or an otherwise closed set of solutions.

FAQ ID:94916

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Can a state decide to be its own MMIS systems integrator?

CMS encourages the use of an SI outside the state agency, but states can consider themselves in that role if they can support that effort and if that decision is made with consultation and agreement from CMS. For more information about the role of the SI, see Section 1.7 in part 01 of MECT Medicaid Enterprise Certification Life Cycle. https://www.medicaid.gov/medicaid/data-and-systems/mect/index.html

FAQ ID:94921

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Does CMS MMIS certification support non-traditional claims processing models, such as using an Administrative Services Organization or "claims processing as a service" approach?

Yes. The certification checklist defines a set of business and technical requirements that a particular Medicaid function must meet. The checklists and criteria are agnostic as to whether the requirements are met by a system built within the Medicaid Agency, a Software-as-a-Service model, a cloud-hosted model, or an ASO model.

FAQ ID:94461

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Is MITA considered during milestone reviews?

Yes, our milestone review process is fully aligned with MITA. During each milestone review, CMS will verify that the state has considered MITA maturity during system definition, and whether the state is actively moving toward higher MITA maturity as defined in the state's latest MITA State Self-Assessment. Please see 42 CFR 433.112 (b)(11).

FAQ ID:94476

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I am a vendor not currently in the Medicaid space, but interested in learning more about opportunities for MMIS and/or E&E modular solutions. Whom can I contact for more information?

CMS is looking for new innovators in the Medicaid IT space. Please direct inquiries to: mmis_mes_certification@cms.hhs.gov.

FAQ ID:94416

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I am an existing MMIS vendor under contract with a state. Who do I contact with questions about the new certification process?

Please work with your state representatives, so that they can contact CMS regional offices for quick assistance with your questions. In addition, please review other FAQs related to this topic.

FAQ ID:94431

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