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.
Frequently Asked Questions
What aspects of reuse do states need to be aware of when developing advance planning documents (APDs)?
APDs must demonstrate a reuse-friendly design that includes the sharing of systems, modules, code, and any other developed artifacts. States could include language describing their efforts to find and learn from or reuse components from similar systems, or efforts the state is making to ensure that other states more easily can reuse the proposed system once it is developed.
FAQ ID:93661
SHARE URLWhat is the Centers for Medicare & Medicaid Services (CMS) policy regarding ownership rights?
From an intellectual property standpoint, reuse is supported by the general grant conditions for Federal Financial Participation (FFP) under 45 CFR 95.617, which require states to "include a clause in all procurement instruments that provides that the State or local government will have all ownership rights in software or modifications thereof and associated documentation designed, developed, or installed with FFP under this subpart."
Further, according to 42 CFR 433.112(6), CMS has "a royalty free, non-exclusive, and irrevocable license to reproduce, publish, or otherwise use and authorize others to use, for Federal Government purposes, software, modifications to software, and documentation that is designed, developed, installed or enhanced with 90 percent FFP."
In practice, this means that vendors retain ownership rights to software and other products they have developed under their own initiative and funding, while states and CMS have ownership rights to and may share any software, customizations, configurations, or add-ons funded with FFP.
FAQ ID:93666
SHARE URLWhat is the Office of Management and Budget (OMB) Circular A -87 Exception?
OMB Circular A-87requires costs associated with building shared state-based Information Technology (IT) systems that support multiple health and human service programs be allocated across all benefitting programs in proportion to their use of the system. The OMB A-87 Exception revised this approach by allowing human service programs (e.g. SNAP, TANF, LIHEAP, etc.) and others to utilize a wide range of IT components, needed by Medicaid but also of use to these other programs, at no additional cost except for interfaces or other uniquely required services specific to those programs. The A-87 Exception applies only to design, development, and implementation. Maintenance and operations work should continue to be allocated in accordance with the A-87 Circular. OMB Circular A-87 – Cost Principles for State, Local, and Indian Tribal Governments, has been Relocated to 2 CFR, Part 225 .
FAQ ID:93611
SHARE URLWhen does the OMB A-87 Exception expire?
On July 20, 2015, the U.S. Department of Health and Human Services and the U.S. Department of Agriculture announced a three-year extension of the Exception to the OMB A-87 cost allocation requirements from December 31, 2015 to December 31, 2018. We are currently making plans for the OMB A-87 exception to end.
FAQ ID:93616
SHARE URLWhat is the impact of the OMB A-87 expiration for states utilizing the exception for system integration development?
States will need to incur costs for goods and services furnished no later than December 31, 2018 to make use of this Exception. Therefore, if work is completed by December 31, 2018, it can be funded under the OMB A-87 Exception and states should follow typical invoicing and claiming processes. However, if an amount has been obligated by December 31, 2018, but the good or service is not furnished by that date, then such expenditure must be cost allocated by program in proportion to their use of the system in accordance with OMB A-87.
FAQ ID:93621
SHARE URLHow should states account for OMB A-87 exception in their Advance Planning Documents (APD)
For FFY2019 annual APDs and budget tables, including the Medicaid Detailed Budget Table (MDBT), must be completed as follows:
- For Q1 FFY2019, states can allocate costs in accordance with the OMB A-87 Exception
- For Q2-Q$ FFY2019, and all APDs going forward, states should allocate costs as required under the OMB A-87 Circular
If a state has already submitted their annual APDs without providing separate budgets they will need to complete an APDU with a revised MDBT and cost allocation plan. The update should address how cost allocation will be done prior to, and after, December 31, 2018. Budget tables should be completed as described above.
The Data and Systems Group (DSG) that approves APDs does not approve cost allocation methodology. States working to develop their new methodologies should send operational cost allocation plans to Cost Allocation Services and the regional office fiscal staff for all benefiting programs.
FAQ ID:93626
SHARE URLAre states only required to conduct Upper Payment Limit (UPL) demonstrations for services with approved state plan supplemental payment methodologies?
No, an upper payment limit demonstration considers all Medicaid payments (base and supplemental). States must conduct UPL demonstrations for the applicable services described in State Medicaid Director Letter (SMDL) 13-003 regardless of whether a state makes supplemental payments under the Medicaid state plan for the services.
FAQ ID:92191
SHARE URLHow and when should the Medicaid hospital tax/provider assessment be included in the inpatient hospital template?
The cost of the tax should be reported in Variable 401 - MCD Provider Tax Cost. A state may separately report the Medicaid portion of the cost of a provider assessment/tax only when it is using a cost based methodology to calculate the UPL. A state may not include this cost when calculating a DRG or Payment based UPL demonstration.
FAQ ID:92366
SHARE URLThis table indicates what reports are available to CMS Users. These can be found under the "Reports" tab.
Report Name |
Description |
Available For |
Clock Status Report |
View the regulatory clock statuses |
CPOC, CMS Disapproval Coordinator, SRT Admin CMS Report Admin, |
State Agency Profile Report |
Overview of a State's Medicaid Plan including the prior 12 months' submission package history |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, CSA, SRT |
Submission Detail Report |
View details on packages by date |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Submission Statistics Detail Report |
View all Submission Packages currently in review |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD, SRRVW, SRT |
Submission Statistics Summary Report |
View summary of Submission Packages in a specific review status within a specified date range. |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Submission Summary Report |
Overview of submitted packages by date |
CPOC, CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, SME, PA, PD,SRRVW, SRT |
Staff Workload Report |
View the number of Submission Packages assigned to each CPOC and SRT member, as of the report run date. |
CMS Disapproval Coordinator, SRT Admin, CMS Report Admin, CSA |
FAQ ID:92871
SHARE URLWhat is the Review Tool Report?
The Review Tool Report is a feature CPOCs, SRTs, Senior Reviewers, Package Approvers, Package Disapprovers, and CMS Report Admins can utilize to see Package Reviewable Units, Reviewers, Reviewable Unit Assessment Values, and Notes.
Log in as CMS Point of Contact or Submission Review Team member. Under the "Records" tab, select "Submission Packages". Then select the link to the submission package. In the left panel, select "Review Tool Report". You may sort the reviews of all Review Team members by Package Reviewable Unit, Reviewer, Reviewable Unit Assessment Value, or Note/Assessments by utilizing the drop-down boxes. You also have the ability to export this report to Excel by selecting "Export to Excel."
FAQ ID:92876
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