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Does CMS MMIS certification support non-traditional claims processing models, such as using an Administrative Services Organization or "claims processing as a service" approach?

Yes. The certification checklist defines a set of business and technical requirements that a particular Medicaid function must meet. The checklists and criteria are agnostic as to whether the requirements are met by a system built within the Medicaid Agency, a Software-as-a-Service model, a cloud-hosted model, or an ASO model.

Does HHS plan to further extend deadlines for states to decide on their level of involvement in implementing Exchanges?

No. As mentioned in the two letters that Secretary Sebelius sent to governors in November 2012, states have been and will continue to be partners in implementing the health care law and we are committed to providing states with the flexibility, resources and time they need to deliver the benefits of the health care law to the American people.

Will HHS charge fees to a state that utilizes federal data in connection with its State-Based Exchange?

No. HHS is establishing a federally-managed data services hub to support information exchanges between states (Exchanges, Medicaid and CHIP agencies) and relevant federal agencies. In many cases, federal agencies other than HHS will be providing information through the hub. As stated in previous guidance, no charge will be imposed on states for use of the hub, nor for the required data accessed there.

How will HHS work with state policymakers to make sure that the Federally-Facilitated Exchange accounts

To the greatest extent possible, HHS intends to work with states to preserve the traditional responsibilities of state insurance departments when establishing a Federally-Facilitated Exchange for a particular state. Additionally, HHS will seek to harmonize Exchange policy with existing state programs and laws wherever possible.

What restrictions will there be on a state regulator's authority to enforce state laws when

States have significant experience and the lead role in insurance regulation, oversight, and enforcement. We will seek to capitalize on existing state policies, capabilities, and infrastructure that can also assist in implementing some of the components of a Federally-Facilitated Exchange. We also encourage states interested in improving this alignment to apply to conduct plan management through a State Partnership Exchange.