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
Will states need to modify already approved contracts to add the final capitation rates to the contract to comply with section 438.3(c), which requires that the payment term be included in the contract?
Yes. We remind states that the requirement that the final capitation rate be specified in the contract is not a new requirement, see section 438.6(c)(2)(ii) of the 2002 final rule. The amount of payment for performance-in this context, the final capitation rate-is a primary component of any contract and must be included for purposes of verifying claims for Federal Financial Participation (FFP) on the CMS-64. In the Final Rule at page 27595, in the context of risk adjustment, CMS suggested that the payment terms under the contract could be identified in an appendix, or additional supporting documentation, to the contract for ease of updating the information when risk adjustment is applied. The state must submit a formal contract amendment when the final capitation rates differ from the payment terms in an approved contract.
Supplemental Links:
- This FAQ was released as part of a larger set. View the full set. (PDF, 185.26 KB)
FAQ ID:93171
SHARE URLWhere can I find general information on the change in matching rates for External Quality Review (EQR)?
CMS released an Informational Bulletin (CIB) discussing the change in federal financial participation (FFP) for EQR that was effective May 6, 2016. The CIB includes revised claiming instructions for the CMS-64 and a sample form. It is available at Medicaid.gov on the EQR webpage, under Technical Assistance Documents, and available at https://www.medicaid.gov/federal-policy-guidance/downloads/cib061016.pdf (PDF, 279.08 KB).
Supplemental Links:
- This FAQ was released as part of a larger set. View the full set. (PDF, 185.26 KB)
FAQ ID:93471
SHARE URLCan CMS please clarify if only audited financial statements that are done on a formal Generally Accepted Accounting Principles (GAAP) basis can be used to meet the requirements in section 438.3(m)? Audits can also be done following statutory accounting principles or government auditing standards and it is not clear if states and managed care plans have flexibility in which standard to apply.
The regulation at section 438.3(m) has a general reference to "generally accepted accounting principles" and "generally accepted auditing principles." This means that states have the flexibility to specify the applicable generally accepted accounting and auditing principles for the audited financial reports in the managed care plan contracts. The federal regulation does not endorse a particular standard.
Supplemental Links:
- This FAQ was released as part of a larger set. View the full set. (PDF, 185.26 KB)
FAQ ID:93466
SHARE URLMy state is planning for our upcoming EQRO contracting. When does CMS plan to publish a protocol for the new activity relating to the validation of network adequacy?
CMS expects to first issue revised protocols for the current mandatory and optional EQR-related activities in the Fall of 2017. We expect to issue the protocol for the new mandatory EQR activity relating to the validation of network adequacy later in 2017 or early 2018. States will have up to one year from the publication of the protocol to implement the new mandatory EQR activity.
Supplemental Links:
- This FAQ was released as part of a larger set. View the full set. (PDF, 185.26 KB)
FAQ ID:94656
SHARE URLIf I have additional questions about EQR and claiming for EQR, who can I ask?
For questions related to state expenditure reporting and claiming instructions for EQR activities, please contact your CMS regional office financial representative. For specific external quality review questions, including what activities qualify for enhanced match, please contact the Division of Quality and Health Outcomes at ManagedCareQualityTA@cms.hhs.gov.
Supplemental Links:
- This FAQ was released as part of a larger set. View the full set. (PDF, 185.26 KB)
FAQ ID:94666
SHARE URLBased on CMS guidance, states may take up to 18 months to bring an IV&V contractor on board to perform certification tasks or align current IV&V contract to comply with CMS guidance pertaining to scope of services and financial independence. What must the state do if the IV&V contractor's start up is delayed?
IV&V contractor activities must still be performed such as checklist evaluation, artifact review and preparation of IV&V Progress Reports. The state should provide a plan and timeline for how these activities will be supported and performed until the proper IV&V contract can be either procured or aligned with updated CMS guidance on IV&V.
FAQ ID:94866
SHARE URLWhat is the applicability of Minimum Acceptable Risk Standards for Exchanges (MARS-E) 2.0 to states' Medicaid Management Information Systems (MMIS)?
MARS-E 2.0 compliance is not required by CMS for states' MMIS, but CMS recommends that states follow applicable national privacy and security standards and practices for their MMIS. MARS-E 2.0 compliance is required for states' Medicaid/CHIP Eligibility and Enrollment (E&E) systems in order to maintain their Authority to Connect with CMS. Link for more information about MARS-E 2.0: https://www.medicaid.gov/federal-policy-guidance/downloads/cib-09-23-2015.pdf (PDF, 105.5 KB).
FAQ ID:94871
SHARE URLCan state Medicaid agencies access federal financial participation (FFP) to support system changes necessary to meet HIPAA, NIST cybersecurity, or MARS-E 2.0 standards?
For E&E and MMIS, enhanced FFP funding is available at 90 percent via the usual Advanced Planning Document process.
FAQ ID:94876
SHARE URLIs IV&V required during operations and maintenance (O&M) for MMIS?
As contained in the MECT standard RFP/contract language required by CMS, CMS does not cover activities that the state may require of the IV&V contractor during ongoing O&M. However, as Medicaid is moving away from monolithic single applications, it is expected that states will continuously update and replace modules in their enterprise. Therefore, IV&V should always have a role to ensure successful integration and testing.
FAQ ID:94881
SHARE URLWhat would preclude a company from being eligible to bid on the MMIS or E&E IV&V contract(s)?
If an organization is performing another role (such as systems integrator, PMO, quality assurance, etc.) on the MMIS or E&E project, it may not perform the IV&V function on the same project. A state may contract the same vendor to perform the IV&V role for both its E&E and MMIS projects.
FAQ ID:94886
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