«Center for Medicaid and CHIP Services September 20, 2012 Medicaid/CHIP Affordable Care Act Implementation Answers to Frequently Asked Questions ...»
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
7500 Security Boulevard, Mail Stop S2-26-12
Baltimore, MD 21244-1850
Center for Medicaid and CHIP Services September 20, 2012
Medicaid/CHIP Affordable Care Act Implementation
Answers to Frequently Asked Questions
Federal Data Services Hub
Q1. What verification services will be available from the Federal data services hub on
October 1, 2013 (“Day 1”)?
A: 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 Q2. 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?
A: No. We will not charge state-based exchanges (SBEs) or Medicaid/CHIP agencies for the Federal data hub services or underlying data.
Q3. 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?
A: 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.
Page 2 Q4. What will a State need to do to invoke the Federal data hub services?
A: 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 requests 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.
Q5. How do I learn which data elements and definitions will be available for each Federal data hub service?
A: Information about the known data elements, definitions for the Federal data hub services are contained in Business Services Description (BSD) documents. The best way to access the BSDs and to avoid version control problems, is to request access to the CMS Service Catalog. States may do so by contacting email@example.com and requesting the CMS Services Catalog User Intake Form. Please note that as the information published on the repository is quite technical in nature, state users should ideally have a technical background.
Q6. Will each Federal agency conduct its own audits of safeguards?
A: The Federal agencies involved in data verifications are currently involved in discussions of the overall approach to oversight and audits of safeguards. Certain agencies are expected to conduct their own independent audits.
Q7. Will the DHS data available through the Federal data services hub include the same data elements as is currently provided directly to states?
A: The Federal data services hub is utilizing the same Department of Homeland Security (DHS) SAVE verification service currently available to states. States will receive both the verification data received from SAVE as well as the Federal data services hub-derived indicators of lawful presence, qualified non-citizen status, and whether the five year bar has been met where applicable.
Page 3 Q8. Can states use the data verified through the Federal data services hub for other programs, aside from Medicaid/CHIP eligibility?
A: Each federal agency has the authority to define use of its data. Therefore CMS defers to IRS, DHS and SSA who are partnering with us to provide data via the Federal data services hub.
Please refer to the CMS Services Catalog to review the Business Service Description (BSD) for the verification of income service to identify the Federal tax information data elements and definitions that will be made available to states through the Federal data services hub.
Q9. Will there be any automatic updates coming through the Federal data services hub? Or will we always need to make a call to the Federal data services hub in order to get any information back? If a change is likely will the state need to send ongoing, frequent requests through the Federal data services hub?
A: Generally, information from the Federal data services hub will only be sent in direct response to a call from the requesting entity. However, in the case of verifications conducted by DHS, there can be up to three steps to a verification, the second and third of which will not be in real time. If the step 1 query fails, the Federal data services hub will automatically invoke step 2, and the response may take up to several days. If step 2 fails, the Federal data services hub will notify the requesting entity which will need to submit additional documentation from the applicant for step 3. The step 3 response can take weeks. During this time, the Federal data services hub will regularly poll DHS to see if the response has come back.
Q1: How can States access information about leveraging business processes and borrowing/sharing information from other States’ systems? What is the CALT?
A: The Collaborative Application Lifecycle Tool (CALT) is available for all states to collaborate among State Medicaid Communities to leverage existing business processes, turnkey solutions, document artifacts in the planning and designing an Exchange and Medicaid Eligibility & Enrollment solutions. As States upload Medicaid IT Gate Review artifacts to the CALT, states can view other States’ artifacts with respect to Medicaid and Exchange development.
The CALT has the ability to notify users of new information that is posted to the collaboration platform. For more information about the CALT, including how to access it, benefits of the
CALT environment, and training opportunities please refer to:
http://www.medicaid.gov/Medicaid-CHIP-Program-Information/By-Topics/Data-andSystems/Downloads/CALT_factsheet.pdf There is also a similar portal environment where information about health insurance Exchange development is being shared among states. That information is available at Https://CALT.HHS.gov.
Page 4 Q2: What is the effective date for enhanced Medicaid funding and for how long is it available?
A: Enhanced Medicaid funding for Eligibility & Enrollment activities is available prospectively from the approval of an Advanced Planning Document (APD). An ongoing Medicaid administrative match at the 50% rate is available for activities that take place prior to an approved Eligibility & Enrollment APD, as long as the activities fall within the purview of administering the Medicaid program (42 CFR 433.15).
Enhanced funding at the 90% rate is available for costs of goods and services incurred by December 31, 2015 for design, development and implementation (DDI) that comply with certain defined standards and conditions. Enhanced funding at the 75% rate is available for maintenance and operations (M&O) of systems that were built using enhanced funding during the DDI phase.
The December 2015 time limit on the availability of 90/10% matching funds does not apply to activities that qualify for the 75/25% matching rate. More information on this issue is available in our final rule, issued in April 2011 (available at http://www.gpo.gov/fdsys/pkg/FR-2011-04html/2011-9340.htm).
Q3: What are the seven conditions and standards that are required for purposes of receiving the enhanced funding?
A: In accordance with the regulations issued in April 2011, Eligibility & Enrollment projects funded with enhanced funding will have to be: (1) modular; (2) advance the Medicaid Information Technology Architecture (MITA) principle; (3) meet specified industry standards; (4) promote sharing, leverage and reuse of Medicaid technologies of systems within and among States; (5) support business results; (6) meet program reporting; and (7) ensure seamless coordination and integration with the Health Insurance Exchange and allow interoperability with health information exchanges, public health agencies, human services programs, and community organizations providing outreach and enrollment assistance services. Please refer to CMS Guidance on Seven Conditions and Standards available in the CALT (see information in Question 1 about how to access the CALT) and also on www.medicaid.gov at http://www.medicaid.gov/AffordableCareAct/Provisions/Information-Technology-Systems-andData.html.
Q4: What cost allocation requirements apply to E&E projects and how can States use the temporary exception to OMB-A-87?
A: 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 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 design, development and implementation (DDI) costs of shared eligibility services that will benefit other human service programs (SNAP, TANF, childcare and child Page 5 welfare). The exception does not apply to maintenance and operations (M&O) costs and therefore States must cost allocate to benefiting programs for these costs. For more information, please see two Tri-Agency Letters, available at http://www.medicaid.gov/AffordableCareAct/Provisions/Information-Technology-Systems-andData.html.
Q5: What information is available for States to reuse and where can it be accessed?
A: In the CALT, 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 State leads are available to discuss and assist States in finding the right artifacts in the CALT 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.
Q6: Do Eligibility & Enrollment projects need to have Independent Validation and Verification (IV&V)?
A: An assessment for IV&V analysis of a State’s 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.
Q7: How are Medicaid and the Exchanges coordinating their systems work at the Federal level?
A: The Center for Medicaid and CHIP Services (CMCS) and the Center for Consumer Information and Insurance Oversight (CCIIO) are working closely together to develop business processes supporting the concepts of a “Shared Eligibility Service.” This includes collaboration on guidance to States, design of the single, streamlined application, and technical assistance efforts more broadly. Additionally, CMCS and CCIIO are engaged in the review of Grant Applications, Advanced Planning Document submissions, and in assessing Establishment Reviews and the Medicaid IT Gate Reviews involving State artifacts.
Q8: How should States report expenditures in the CMS-64 for approved enhanced funding for Eligibility &Enrollment Advanced Planning Documents?
A: 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 Page 6 Q9: Will CMS certify new Eligibility & Enrollment systems post-implementation as it does with MMIS?