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Frequently Asked Questions

Frequently Asked Questions are used to provide additional information and/or statutory guidance not found in State Medicaid Director Letters, State Health Official Letters, or CMCS Informational Bulletins. The different sets of FAQs as originally released can be accessed below.

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Will these new MAGI rules apply to all people applying for Medicaid?

The new rules apply to most people who are eligible for Medicaid and Chip, but not the elderly or people who qualify based on a disability.

For coverage effective January 2014, MAGI will be the basis for determining both Medicaid and CHIP eligibility for children, pregnant women, parents and the adults enrolled under the new adult eligibility group created by the ACA (in states that adopt that eligibility group.) Individuals age 65 and older and those who qualify for Medicaid based on disability are not affected by the new rules.

FAQ ID:92466

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If a state is not expanding Medicaid in 2014, does it still use MAGI rules?

Yes. A state's decision whether or not to extend Medicaid coverage for low-income adults in 2014 is not related to the use of MAGI. MAGI rules simplify the eligibility rules and promote coordination between Medicaid and CHIP and coverage available through the Marketplace; coordination will be important for consumers in all states regardless of a state's decision on Medicaid eligibility for low-income adults.

FAQ ID:92471

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Why are the new MAGI income standards higher than the old ones (even when there is no eligibility expansion)?

The eligibility standards (where there's been no expansion) are not any higher than the old standards; they are expressed in a different way (gross versus net).

In the past, Medicaid and CHIP eligibility used a combination of an income eligibility standard--often expressed as a percentage of the Federal Poverty Level (FPL)--and a series of deductions (known as "disregards" that were like footnotes or 'below the line' adjustments to income and were determined by each state. The new way of calculating eligibility based on MAGI translates that two-part process into a one step process using an income standard that incorporates the 'below the line' deductions. This makes the new standard appear higher than the old one (e.g. from 185% of the FPL to 193% of the FPL for pregnant women). In effect, however, the new income standard represents what the state's old two-step process would have resulted in, just expressed in a different way.

FAQ ID:92476

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Do the MAGI changes mean more people will be eligible for Medicaid (even when there is no eligibility expansion)?

No, overall the new methodology does not change the number of people eligible for Medicaid. The MAGI-based standard will result in approximately the same number of people being eligible under the new standard as would have been eligible under the old standard. However, there may be some differences in which people will qualify--or not qualify--depending on how they might have fared under the old system (with deductions and disregards).

FAQ ID:92481

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Can you give an example of how the old rule worked, prior to MAGI?

Before MAGI, if a state's income limit was 100% of the FPL--the state would first look at the person's gross income, then subtract out (for example) 30% of their earned income and an amount they spend on childcare as work-related expense deductions and then compare that net income to 100% of the FPL. This means that under the pre-MAGI rules, in a state with an income eligibility limit of 100% of the FPL, a person with income over 100% of the FPL can qualify for Medicaid (because of the deductions and disregards).

FAQ ID:92486

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How will the new MAGI rules work?

The state will look at the individual's modified adjusted gross income, deduct 5%, which the law provides as a standard disregard, and compare that income to the new standard.

FAQ ID:92491

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How were the new MAGI-based income standards set?

Based on guidance issued in December 2012 (PDF, 177.59 KB), CMS worked with states to set their new standards. Most states used a model that determines the average value of the disregards a state had in place and then added that amount to the old standard to create the new eligibility levels. In the example above, in a state with a net income standard of 100% of the FPL, if the average value of the disregards equaled 6 percentage points of the FPL, that value would be added to the old standard for a new eligibility standard of 106% of the FPL.

FAQ ID:92496

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Under the CMS guidance for funding health information exchange (HIE) activities, what kinds of activities are eligible for 90 percent Federal matching funds (90/10) through HITECH administrative funding?

Within the parameters set by State Medicaid Director (SMD) Letter #11-004 and SMD Letter #10-016, states may request 90/10 HITECH administrative funding for a wide range of HIE activities that support meaningful use.

States may request this funding for two broad categories of their administrative activities related to HIEs: (1) on-boarding, and (2) design, development, and implementation (DDI) of infrastructure. In this context, on-boarding refers to the state's or HIE's activities related to connecting a provider to an HIE so that the provider is able to successfully exchange data and use the HIE's services; this funding cannot cover costs incurred by the provider or the vendor. For more information, please see the later FAQ that specifically discusses on-boarding. With respect to infrastructure DDI, CMS is able to provide matching funds for a variety of state activities that will enable providers who are eligible for the Medicaid EHR Incentive Program to meet meaningful use. If the requirements of SMD Letters #10-016 and #11-004 are met, CMS will provide funding for state administrative activities related to core HIE services (for example, designing and developing a provider directory, privacy and security applications, and/or data warehouses), public health infrastructure, and electronic Clinical Quality Measurement (eCQM) infrastructure.

CMS recognizes that there are multiple types of HIE models emerging among the states, and will review each proposal individually. SMD Letter #11-004 outlines some of the characteristics that CMS encourages, but a state may provide justification for why an alternate model is more appropriate given the unique circumstances in that state. CMS encourages interested states to reach out to their CMS regional HITECH contacts to discuss any proposed HIE funding requests prior to submitting an Implementation Advance Planning Document Update (IAPD-U) for HIE funding. Please note that cost allocation and fair share principles are critical requirements outlined in SMD Letter #11-004, and so the state must ensure that its funding request complies with the principles outlined in the SMD letter.

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FAQ ID:92526

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Under the CMS guidance for funding health information exchange (HIE) activities, is 90/10 HITECH administrative funding available for staffing costs?

Yes, but only in specific circumstances. States may request time-limited HITECH funding for staffing costs related to on-boarding eligible Medicaid providers to the HIE or to building initial infrastructure. The staff may sit in the state Medicaid agency or the HIE itself, depending on the state's situation. Any staffing costs for on-boarding or infrastructure must be time-limited to ensure that the costs do not become operational in nature. When requesting HITECH funds to cover staffing costs, states should present a justification that describes how many eligible providers are anticipated to on-board to the HIE and the amount of staffing time necessary to on-board those providers or build infrastructure.

Please note that HITECH administrative funding will also be available for personnel that sit within the Medicaid agency itself and support only Medicaid providers. However, the fair share and cost allocation principles outlined in the State Medicaid Director (SMD) Letter #11-004 still apply. If those personnel work on other State Medicaid program activities that do not benefit the Medicaid EHR Incentive Program, then HITECH funds must be cost allocated between the Medicaid EHR Incentive Program and the Medicaid agency personnel's other activities.

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FAQ ID:92531

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What process should states follow to request funding for health information exchange (HIE) infrastructure under the Medicaid EHR Incentive Program?

State Medicaid Director (SMD) Letter #11-004 and SMD Letter #10-016 indicate that states may request 90/10 HITECH administrative funding for HIE infrastructure under the Medicaid EHR Incentive Program. To request this funding, states must submit an Implementation Advance Planning Document Update (IAPD-U) using the approved template, which can be found at http://www.cms.gov/Regulationsand-Guidance/Legislation/EHRIncentivePrograms/Downloads/Medicaid_HIT_IAPD_Template.pdf. In particular, the IAPD-U template Appendix D outlines all the information required for an HIE funding request. The HIE funding request may be submitted in a separate IAPD-U, or it may be included in an IAPD-U that requests other funding for the state's Medicaid EHR Incentive Program.

CMS asks that states reach out early to their regional CMS HITECH contacts if they are considering submitting an IAPD-U for HIE funding. Given the complexity of an HIE request, along with the parameters set out in SMD Letter #11-004, CMS prefers to have one or more preliminary discussions to go over the state's current IAPD landscape, the state's technical model, and the state's approach to meeting the fair share and cost allocation principles.

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FAQ ID:92536

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