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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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CMS has advised states that the 90/10 matching funds for modernization of Medicaid eligibility and enrollment (E&E) systems is not related to a state's decision about whether to proceed with the Medicaid expansion for the new adult group. Is 90/10 funding contingent on a state complying with other aspects of the Affordable Care Act related to eligibility? Must a state that uses 90/10 funding build into its design and development support for the new "adult group," even if it does not plan now to proceed with the expansion?

The 90/10 funding is not contingent on a state's decision to proceed with its Medicaid expansion. As the preamble to the final regulation makes clear, the enhanced funding was not solely for eligibility determination systems that support the Medicaid expansion. (76 Fed Reg 21950-21975 (April 19, 2011) and 42 CFR Part 433.
CMS was clear in the final rule that enhanced funding could be available for eligibility determination systems that determine eligibility for traditional eligibility groups. However, such systems must meet all requirements, standards and conditions included in the final rule, including the Standards and Conditions for Medicaid IT that ensure modernized and efficient eligibility systems that produce accurate and timely eligibility determinations and that can interface seamlessly with the Exchange operating in that state. In all states, including those that do not proceed with the expansion, state eligibility systems must be able to electronically pass accounts between the Exchange (whether state-based or federally-facilitated) in order to facilitate seamless coordination. In addition, the systems must be able to support a single streamlined application for coverage among insurance affordability programs, support Modified Adjusted Gross Income (MAGI)-based eligibility determinations; and must support new renewal processes and connections for data-driven, electronic verifications as described in the Medicaid eligibility final rule issued March 23, 2012 (available at http://www.gpo.gov/fdsys/pkg/FR-2012-03- 23/pdf/2012-6560.pdf ).
States are not required to "build in" programming for the new adult group. However, a state that conforms to the Standards and Conditions for Medicaid IT (particularly modular design and separation of business rules from core programming) will be able to quickly and efficiently support enrollment for the expansion population. In addition, enhanced funding is available for states that wish to explicitly "build in" placeholder programming for the new adult group now to provide for future flexibility.

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FAQ ID:93216

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What technical guidance and deliverables can CMS offer to states that are modernizing their eligibility and enrollment (E&E) systems?

CMS has developed the Medicaid Eligibility and Enrollment Toolkit (MEET) to provide guidance for states that are conducting E&E systems projects. The MEET is available at https://www.medicaid.gov/medicaid/data-and-systems/meet/index.html.

Also, various artifacts developed by states are posted in a shared environment for reuse by others. These artifacts can be used to help jump-start projects. More information on reuse, including access to the reuse repository, is available at https://www.medicaid.gov/medicaid/data-and-systems/reuse/index.html.

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FAQ ID:93226

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When does CMS need to know states' intention to proceed with the Medicaid expansion for purposes of the FFE build? What if a State adopts the expansion too late to have the change accommodated by the FFE (at least for some period of time); how would the coordination provisions of the law be accommodated?

There is no deadline by which states need to decide on the Medicaid expansion. We understand that there are many considerations involved in this decision, and CMS stands ready to work with states on their individual timetables. Regardless of the expansion, every state that uses the Federally Facilitated Exchange will need to support coordination between the Medicaid and CHIP programs and the FFE and otherwise comply with the new MAGI rules as well as the application, renewal and verification procedures described in the Medicaid eligibility final rule issued March 23, 2012 (available at http://www.gpo.gov/fdsys/pkg/FR-2012-03-23/pdf/2012- 6560.pdf). We will be working with each state to ensure that the appropriate business rules are accommodated and tested, and the necessary electronic account handoffs are in place, before the FFE is operational and the new Medicaid rules are in effect. We are continuing to provide more guidance and information on these issues as part of the FFE manual and MOU process as well as through our SOTA calls. We are also establishing a state- to- FFE change process to help manage changes in policies that a state may make over time; a state that decides later to proceed with expansion will be accommodated within that process.

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FAQ ID:93236

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How will the Supreme Court Decision affect CMS's ability to ensure other aspects of the law such as those affecting interactions with the Federally-facilitated Exchange? For example, if a state does not want to exchange electronic accounts with the FFE, what will be required and what, if any, penalties could be imposed?

As previously stated in a letter from the Secretary to the nation's governors, the Supreme Court held that a state may not lose federal funding for its existing Medicaid program if the state chooses not to participate in the expansion of Medicaid eligibility for low-income adults. The Court's decision did not affect other provisions of the law. State Medicaid and CHIP programs will need to coordinate with the Federally-facilitated Exchange, regardless of a state's decision to proceed with expansion. States will need to be part of the seamless system for people to apply for all coverage programs; and will need to coordinate eligibility with the new insurance affordability programs. These provisions have relevance regardless of whether a state chooses to participate in the expansion for low-income adults.

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FAQ ID:93246

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What will be the role of the FFE in reviewing applications from individuals with incomes below 133% of the FPL in states that do not implement the Medicaid expansion?

The FFE's role is the same whether or not a state implements the Medicaid expansion for low-income adults. The FFE will still make MAGI-based determinations or assessments of eligibility for Medicaid and CHIP and will assess eligibility for premium tax credits and cost sharing. The FFE will apply the state's eligibility levels for Medicaid/CHIP when it makes the Medicaid determination or assessment. In addition, as established in the Exchange and Medicaid/CHIP eligibility final rules, the FFE will electronically transfer accounts for individuals who are either determined or assessed as eligible for Medicaid and CHIP (it is a state option whether to have the FFE determine or assess eligibility) for further evaluation/action.

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FAQ ID:93256

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How would a state's decision not to expand their Medicaid program's eligibility affect their ability to get information from the federal HUB under a state-based exchange model?

The federal hub will provide data verification services to any state-based exchange and to the Medicaid and CHIP program without regard to whether a state has adopted the low-income adult expansion. Consistent with the regulations issued on March 23, 2012, state Medicaid and CHIP programs must rely on the HUB for certain information; this provision applies without regard to whether a state has adopted the Medicaid expansion for low-income adults.

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FAQ ID:93261

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What verification services will be available from the Federal data services hub on October 1, 2013 ("Day 1")?

The Federal data services hub will provide the following services on Day 1. CMS is also pursuing data sources for additional verifications through the Federal data services hub and will keep states updated as they are confirmed:

  • Social Security Number (SSN) verification via the Social Security Administration (SSA)
  • Citizenship verification via SSA or the Department of Homeland Security (DHS) when relevant
  • Incarceration verification via SSA
  • Title II benefit income information via SSA (monthly and annual amounts)
  • Quarters of coverage information via SSA
  • MAGI income information from the Internal Revenue Service (IRS)
  • Max APTC from IRS
  • Immigration status verification via DHS, as well as a translation to indicators for lawful presence, qualified non-citizen, and five year bar status.
  • Public minimum essential coverage (MEC) verification from Federal agencies

FAQ ID:93266

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Will CMS charge state-based exchanges (SBEs) or Medicaid/CHIP agencies for any of the Federal data hub services or underlying data? If so, which ones and how much?

No. We will not charge state-based exchanges (SBEs) or Medicaid/CHIP agencies for the Federal data hub services or underlying data.

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FAQ ID:93271

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Are all of the Federal data hub services separate ("atomic"), such as SSN validation, and citizenship, or will they be wrapped into a single, "composite" service?

Some services will be composite, and others atomic. For instance, it will be possible to invoke individual SSA services in a single composite service, although not all services in the composite will always need to be invoked. If the Exchange is seeking Title II income information for a member of a household who is not the applicant, then the citizenship and incarceration services would not be invoked. In contract, public MEC verification services will be separate, atomic services.

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FAQ ID:93276

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What will a State need to do to invoke the Federal data hub services?

All transactional requests to the Federal data services hub shall be performed via web services. These services shall be invoked by State IT systems via application programming interfaces (API) or Web APIs that are accessed via secure Hypertext Transfer Protocol (HTTP) and shall be executed on the system hosting the requested services. The CMS web services shall accept request from trusted sources, perform the function based on the request, and return a response to the State system. CMS shall publish these web services in the CMS Service Catalog, which shall contain all services available to the states and the definitions of the standards that must be met to request the service and standard data format for the data provided when making the request and the data that shall be returned.

CMS is still determining the best mechanism for how batch and bulk data transactions will be designed and implemented. At this stage, CMS believes that there shall be a need to establish both web services and possibly alternate interfaces to meet batch and bulk data transaction requirements.

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FAQ ID:93281

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