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
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
SHARE URLWhat 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
SHARE URLHow 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
SHARE URLWhat is the difference between "Medicaid Amount Reimbursed" vs. "Non-Medicaid Amount Reimbursed" in the State Drug Utilization Data (SDUD)?
A Non-Medicaid Reimbursed amount is any amount paid on a claim by parties other than Medicaid (e.g., other federal coverage, co-pay, private insurance). If a state receives Federal Financial Participation (FFP) for any part of a claim for a Covered Outpatient Drug (COD), that portion of the claim is included in the Medicaid Reimbursed amount. If a state does not receive FFP for any part of a rebate-eligible claim, then the amount of the claim is included in the Non-Medicaid Reimbursed amount.
FAQ ID:91981
SHARE URLWhy Does the "Medicaid Amount Reimbursed" and the "Non-Medicaid Amount Reimbursed" not equal the "Total Amount Reimbursed" in the State Drug Utilization Data (SDUD)?
The sum of the “Medicaid Amount Reimbursed” and the “Non-Medicaid Amount Reimbursed” fields should generally equal the Total Amount Reimbursed on a National Drug Code (NDC) by NDC basis; however, these new fields were implemented beginning with the fourth quarter of 2007 and are optional for the states to report prior to that time. Therefore, for quarters earlier than fourth quarter 2007, there may be some large discrepancies between the Total Amount Reimbursed and the sum of the Medicaid Amount Reimbursed and the Non-Medicaid Amount Reimbursed because the Non-Medicaid Amount Reimbursed is often not present for those earlier quarters. Should you notice apparent discrepancies in an individual state's utilization data, your questions should be directed to the State Technical Contact.
FAQ ID:91986
SHARE URLIs the amount reimbursed by Medicaid net of rebates or pre-rebate in the State Drug Utilization Data (SDUD)?
Does the State Drug Utilization Data (SDUD) field "Units Reimbursed" represent the number of pills Medicaid paid for a drug that comes in a pill form?
"Units Reimbursed" are the number of units (based on Unit Type) of the drug (11-digit NDC level) reimbursed by the state or, for MCO drugs, the number of units dispensed during the Quarter/Year. For more specific information, you may contact either the Drug Manufacturer or State via the contact lists.
FAQ ID:92016
SHARE URLWhen are states required to submit State Drug Utilization Data (SDUD) to the Centers for Medicare & Medicaid (CMS)?
States are required to submit their utilization data to CMS within 60 days of the end of the rebate period.
FAQ ID:92026
SHARE URLHow long does a state have to report State Drug Utilization Data (SDUD) that was not previously reported?
Per section 1927 of the Act, initial submissions of quarterly state utilization data are due to CMS within 60 days of the end of each rebate period. If a state fails to report utilization data in the quarter that it was dispensed, the state must submit initial utilization data for the most recently closed quarter as well as adjustments/corrections to any previously reported utilization data.
FAQ ID:92036
SHARE URLAre all states required to participate in the Medicaid Drug Rebate Program (MDRP)? If not, is there a listing published by Medicaid indicating who is not participating?
Drug coverage under Medicaid is an optional benefit for the states. However, if a state opts to cover prescription drugs in their Medicaid program, they must participate in the MDRP. As part of that participation in the MDRP, states are required to submit quarterly drug utilization data to CMS. All states and the District of Columbia currently participate in the MDRP; therefore, they all submit quarterly drug utilization data to CMS.
FAQ ID:92061
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