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Medicaid Enterprise System Implementation Forecast

Understanding State Systems Impact of Recently Released Policy or Technical Guidance

Statute, regulations, and guidance governing requirements of the Medicaid, CHIP, and/or BHP program(s) are constantly evolving. In response, State Medicaid Agencies (SMAs) need to review and make necessary adjustments to their policy, operations, and Medicaid Enterprise Systems (MES) to ensure compliance with new or updated Medicaid policy. As states review and assess new releases from CMS, identifying and understanding the impact these changes will have on state systems is critical to their ability to conduct proactive project planning and ensure program compliance.

To assist states with their planning, CMS developed the timeline and associated data table below. These reflect new policy or technology requirements that may require changes to state MES. Because each SMA is unique, and these actions may impact each state and territory differently, this timeline is meant as a guide to help states identify where there are likely system implications, type of impact, estimated level of effort, and compliance dates. It is not intended to conflict with or supersede any of the requirements in statute, regulation, or guidance, which should be regarded as the source of authority for these requirements.

For additional information, please contact statefeedback@cms.hhs.gov.

View of current and upcoming implementation of policy and technical requirements

The image below provides a summary of the new policy or technology requirements that we have analyzed for state MES impacts, by year. A detailed view for each provision with a potential MES impact is included in the data table, along with a link to the source document. Additionally, a comprehensive visual of the potential impacts for several of the rules released in 2024 (managed care, access, and E&E) can be accessed under “additional resources”.

For more information about Access visit https://www.medicaid.gov/medicaid/access-care/index.html, for managed care visit https://www.medicaid.gov/medicaid/managed-care/guidance/medicaid-and-chip-managed-care-final-rules/index.html, and for eligibility and enrollment (E&E) visit https://www.cms.gov/newsroom/fact-sheets/streamlining-medicaid-childrens-health-insurance-program-and-basic-health-program-application.

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Image 1: High level summary of policy and technical guidance impacts on MES by year and category

For additional information on the data fields, visit data.Medicaid.gov. The data dictionary tab provides more information on the data field categories used.

Medicaid Enterprise System Datatable

Link to source document Implementation Year Policy/Update Type Policy/Update Title Potential MES Impact Statute or Regulation Citation Compliance Month Compliance Day Type of Potential System Impact Category of Potential Impact Impact to Medicaid CHIP and/or BHP T-Shirt Size
Link to source document Implementation Year Policy/Update Type Policy/Update Title Potential MES Impact Statute or Regulation Citation Compliance Month Compliance Day Type of Potential System Impact Category of Potential Impact Impact to Medicaid CHIP and/or BHP T-Shirt Size

Notes: 

For additional information on the data fields, visit data.Medicaid.gov. The data dictionary tab provides more information on the data field categories used.

Footnotes for image 1:

  1. "Medicaid Program; Streamlining the Medicaid, Children's Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes" (89 FR 22780)
  2. "Streamlining Medicaid; Medicare Savings Program Eligibility Determination and Enrollment" (88 FR 65230)
  3. "Ensuring Access to Medicaid Services” (89 FR 40542)
  4. "Medicaid and Children's Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality” (89 FR 41002)
  5. "Patient Protection and Affordable Care Act; Advancing Interoperability and Improving Prior Authorization Processes for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans on the Federally- Facilitated Exchanges, Merit-Based Incentive Payment System (MIPS) Eligible Clinicians, and Eligible Hospitals and Critical Access Hospitals in the Medicare Promoting Interoperability Program" (89 FR 8758 )
  6. Section 5123 of the Consolidated Appropriations Act, 2023 (CAA, 2023; P.L. 117-328
  7. Federal Data Services Hub Verify Law Presence Service
  8. Federal Data Services Hub Account Transfer Service