No Wrong Door System and Medicaid Administrative Claiming Reimbursement Guidance

The No Wrong Door (NWD) System represents a collaborative effort of the U.S. Administration for Community Living (ACL), the Centers for Medicare & Medicaid Services (CMS), and the Veterans Health Administration (VHA), to support state efforts to streamline access to LTSS options for all populations and all payers. The state Medicaid agency is a critical partner and player within the NWD System conducting activities such as outreach, referral, assessment, functional and financial eligibility and even final determination which are all activities that are part of a state’s NWD System. Federal matching funds under Medicaid are available for costs incurred by the state for administrative activities that directly support efforts to identify and enroll potential eligibles into Medicaid and that directly support the provision of medical services covered under the state Medicaid plan, when those activities are performed either directly by the state Medicaid agency or through contract or interagency agreement by another entity. The purpose of the NWD System Medicaid Administrative Guidance is to inform states about the appropriate methods for claiming federal matching funds, known as Federal Financial Participation (FFP), for Medicaid administrative activities performed through NWD Systems, and to ensure non-duplication for any such claims. To the extent that NWD System employees perform administrative activities under a contract or interagency agreement with the state Medicaid agency that are in support of the state Medicaid plan, and meet the necessary requirements to identify the expenditures incurred for those activities, federal reimbursement may be available for a share of those expenditures. 

In 2012, an estimated $220 billion was spent in the United States on LTSS. This figure includes federal state, local and private funding1. Often individuals who use publicly funded services are left with high-cost options when they desire a low-cost option. The NWD system helps states use resources more efficiently and effectively. By transforming state publicly administered and/or publicly funded LTSS payers and providers into a single system, states can gain efficiencies by reducing duplication and informing processes. They can collect information that guides system improvements and informs policy makers. The NWD system will help states better understand the needs and preferences of individuals using LTSS while simultaneously helping individuals get the LTSS they are seeking. Ultimately, states can better serve people and be better stewards of federal and state funds by implementing the NWD system. A NWD System builds on the strength of existing entities such as Aging and Disability Resource Centers, Area Agencies on Aging and Centers for Independent Living, by providing a single, more coordinated system of information and access for all persons seeking long-term services and supports. This minimizes confusion, enhancing individual choice, and supporting informed decision-making. The NWD System functions include:

  • Public Outreach and Coordination with Key Referral Sources;
  • Person-Centered Counseling;
  • Streamlined Eligibility to Public Programs; and,
  • State Governance and Administration. 

State and local leaders can learn more about building capacity for No Wrong Door Systems by using the No Wrong Door System Key Elements.

1 O’Shaughnessy, Carol. George Washington University. (2014). National Health Policy Forum. The Basics: National Spending for Long-Term Services and Supports (LTSS), 2012. Washington, DC.