Frequently Asked Questions

The law directs HHS to develop a methodology to reduce Disproportionate Share Hospital (DSH) funding over time in a way that is linked to reductions in the number of uninsured or how states target their funds. We have heard from states and health care providers about their concerns related to this change and are exploring all options. The Department will propose this methodology for public comment early next year.

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• This FAQ was released as part of a larger set. View the full set.

In 2014, some low-income children will be covered by Medicaid or CHIP while their parents obtain coverage on the Exchange with advance payments of the premium tax credit. Premium assistance, an option under current law, provides an opportunity for state Medicaid and CHIP programs to offer coverage to such families through the same coverage source, even if supported by different payers. Under Medicaid and CHIP statutory options, states can use federal and state Medicaid and CHIP funds to deliver Medicaid and CHIP coverage through the purchase of private health insurance. Most commonly, states have used premium assistance to help Medicaid/CHIP eligible families pay for available employer-based coverage that the state determines is cost effective. There are cost sharing assistance and benefit wrap-around coverage requirements, to the extent that the insurance purchased with Medicaid and/or CHIP funds does not meet Medicaid or CHIP standards. In both Medicaid and CHIP, premium assistance is authorized for group health coverage and, under some authorities, for health plans in the individual market, which, in 2014 would include qualified health plans available through the Exchange. Please note that advance payments of the premium tax credit and cost-sharing reductions are not available for an individual who is eligible for Medicaid or CHIP. The statutory authorities that permit use of title XIX or title XXI funds to be used for premium assistance for health plans in the individual market, including qualified health plans in the Exchange, are sections 1905(a) and 2105(c)(3) of the Social Security Act.

For example, beginning in 2014, when a child is eligible for Medicaid/CHIP and the parent is enrolled in a qualified health plan through the Exchange, a state Medicaid or CHIP program could use existing premium assistance authority to purchase coverage for a Medicaid or CHIP-eligible child through that qualified health plan. The premium tax credit would not be available to help cover the cost of coverage for these children. As noted above, with respect to the children, the state would adhere to federal standards for premium assistance, including providing wrap-around benefits, cost sharing assistance, and demonstrating cost-effectiveness, as appropriate. A State-Based Exchange may be able to support such an option, and in states where a Federally-Facilitated Exchange is operating, a State Medicaid or CHIP agency may be able to take this approach by making arrangements with qualified health plans to pay premiums for individuals. We will be working with states interested in this option to consider how the state Medicaid and CHIP agency can coordinate with the Exchange to establish and simplify premium assistance arrangements.

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• This FAQ was released as part of a larger set. View the full set.

The Affordable Care Act envisions and directs that there be a coordinated system for making eligibility determinations between Medicaid, CHIP and the Exchange to avoid gaps in coverage as individuals' income fluctuates. Smooth eligibility transitions will not necessarily prevent people from having to select a new plan and/or provider when they lose eligibility for one insurance affordability program and gain eligibility for another. The extent to which such changes in plans and providers occur will depend on whether and to what degree plans participate in both the Exchange and in Medicaid and CHIP, and the networks in such plans.

Premium assistance can help address this issue, while encouraging robust plan participation in Medicaid, CHIP, and the Exchange. As discussed above, this option permits state Medicaid or CHIP programs to use premium assistance to enroll a Medicaid or CHIP eligible individual or family in a qualified health plan through the Exchange. States may be most interested in this option for families close to the top of the Medicaid income limit. Under this arrangement, if a family's income changes such that some or all members of the family become ineligible for Medicaid or CHIP and eligible for a premium tax credit to help cover the cost of a qualified health plan through the Exchange, it would be less likely that members moving into Exchange coverage would need to change plans or providers.

Similarly, premium assistance could help increase the likelihood that individuals moving from Exchange coverage into Medicaid or CHIP may remain in the same qualified health plan in which they had been enrolled through the Exchange.

As discussed above, premium assistance options in Medicaid and CHIP are subject to federal standards related to wrap around benefits, cost sharing and cost effectiveness. There may also be an opportunity for states to promote continuity of coverage through "bridge plans" as described earlier.

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• This FAQ was released as part of a larger set. View the full set.

The requirements of Circular OMB-A-87 apply to the allocation of costs for design, development, and implementation (DDI) and maintenance and operations (M&O) of eligibility and enrollment (E&E) systems including the respective benefiting health insurance affordability programs: Medicaid, CHIP (for states that have separate Title XXI programs or for portions of separate CHIP programs in states that operate a combination CHIP/Medicaid program) and to CCIIO Grant Funding if the project will include functionality for Health Insurance Exchanges.

States can request the temporary exception to Circular OMB-A-87 requirements to use Medicaid enhanced funding for DDI costs of shared eligibility services that will benefit other human service programs (SNAP, TANF, childcare, and child welfare). The exception does not apply to M&O costs, and therefore states must cost allocate to benefiting programs for these costs. For more information, please see the State Medicaid Director Letter, dated July 20, 2015, at https://www.medicaid.gov/federal-policy-guidance/downloads/smd072015.pdf.

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• This FAQ was released as part of a larger set. View the full set.

In zONE, states can find business process models, templates for concepts of operations, and other planning and development artifacts, business and technical requirements, Requests for Proposals (RFPs), Statements of Work (SOWs), system design documents, etc. CMS Eligibility & Enrollment (E&E) state leads are available to discuss and assist states in finding the right artifacts in the zONE collaboration spaces. Your SOTA team and your E&E state lead are available to answer specific questions about what might be available soon that is not already in the CALT.

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• This FAQ was released as part of a larger set. View the full set.

An assessment for IV&V analysis of a state's E&E system development effort will be required for APD projects that meet any of the criteria contained in federal regulations at 45 CFR 95.626(a). If CMS determines that the IV&V analysis is required for a state's system development effort, the provisions contained in federal regulations at 45 CFR 95.626(b) and (c) apply. Additional guidance is available in the Medicaid E&E Toolkit, available at https://www.medicaid.gov/medicaid/data-and-systems/meet/index.html.

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• This FAQ was released as part of a larger set. View the full set.

Medicaid Budget Expenditure System/Children's Budget Expenditure System (MBES/CBES) has been modified to add new Medicaid Eligibility Determination System lines to the 64.10 Form series beginning with Quarter Ending March 31, 2011:

• 28A - DDI of Medicaid E&E systems/cost of in house activities - 90% FFP
• 28B - DDI of Medicaid E&E systems cost of private sector contractors - 90% FFP
• 28C - Operation of an approved Medicaid E&E system/cost of in-house activities - 75 % FFP
• 28D - Operation of an approved Medicaid E&E system/cost private sector contractors- 75% FFP

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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• This FAQ was released as part of a larger set. View the full set.

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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• This FAQ was released as part of a larger set. View the full set.

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.

Supplemental Links:

• This FAQ was released as part of a larger set. View the full set.