Medicaid/CHIP & Human Services System Integration Jessica Kahn, Director, Division of State Systems SOTA Call January 23, 2014
The A 87 Waiver Announced on 8/10/2011 Prioritizes States eligibility systems modernization requirements critical to implementation of the Affordable Care Act while encouraging states to take a phased approach and build systems that can be leveraged for human services
The Tri Agency Letter Guidance on the timing, priorities and parameters of when the A 87 waiver applies and when it does not. Examples of services that could be costallocated within an integrated system
Uptake? 46 of the 50 States and DC are either integrated now or planning to integrate with human services to some degree 18 states currently offer a multi benefit application (e.g. Medicaid/CHIP and SNAP) It s not clear, however, how many states are planning to take advantage of the A87 waiver for the development of additional shared services
Waiver Requests Some states have sent a formal letter to CMS Others have indicated their intent to invoke the waiver in APDs (but have plans changed?) Others have indicated that they will provide the information in the expedited APD checklist around human services for their FFY14 DDI IAPDupdates If it s unclear to us if a state definitively plans to take advantage of the waiver, we will follow up with you head s up!
M&O The waiver is for DDI costs for shared services. State Medicaid/CHIP agencies may receive 75% FFP for maintenance and operations costs and for eligibility workers fulfilling certain functions. All M&O costs must be cost allocated with any program that benefits from use of the system/shared services/eligibility workforce (including human services)
The 12/31/15 Deadline All goods and services funded with the 90/10 have to be incurred by 12/31/15. Example: State A finalizes UAT testing and final tweaks by 12/31 but their vendor doesn t send them the bill until 1/15/16. Is that okay? Yes. Costs were incurred before the deadline. States have 30 days after the end of the federal fiscal quarter to report expenditures Example: State B is making final tweaks and finishes on 5/20/16. Can they get reimbursed at the 90/10 match rate for the costs incurred between 1/1 5/20/16? No. There were costs incurred after the deadline that can now only be eligible for the 50/50 match
2014 2015 Priorities Finalization of eligibility systems modernization for the ACA (deferred scope, additional functionality and refinements) DDI for shared services with human services Inclusion of non MAGI into new eligibility systems
The Human Services Side (A/K/A: The ACF Interoperability Initiative) Sequestration Took A Toll But We re Not Done Seven Projects from 2011 through 2013 PMO NIEM NHSIA State Systems Interoperability and Integration Grants Interoperability Toolkits Confidentiality Toolkit ACF Interoperability Website / Communications
The Low Hanging Fruit State Systems Interoperability and Integration Grants S 2 I 2 New York: The Children s Passport Design NIEM and NHSIA Integration Maryland: Social Return on Investment Calculator Indiana: Vital Statistics Interface for Human Services Program Integrity and Improved Services Delivery Illinois: Governance Model and Integration Roadmap Colorado: Enhanced Interfaces and Data Sharing NIEM and NHSIA Integration Oklahoma: A Bridge of Enhanced Interfaces and Data Sharing Includes ESB and SOA Integration California: Governance Model and Data Sharing Concepts A Proof of Concept Application
The Other Low Hanging Fruit Projects from the ACF Interoperability Initiative NIEM: PARIS Database Interface Model and XML Schema Titles IV E and IV D Interface Model and XML Schema NHSIA: A Mature, Version 1 Model With 7 Design Viewpoints Compatible with MITA 3.0 S 2 I 2 : Seven Grant Projects With Deliverables Being Published Final Reports From Each to be Published Interoperability Toolkit: Confidentiality Toolkit: ACF Interoperability Website: A Wealth of Knowledge From Schedules to Guidance Data Sharing in 6 Human Services Programs Discussed Includes Appendix of 6 Matrices Regulations/Statutes www.acf.hhs.gov/initiatives priorities/interoperability
Policy Ripe For The Picking Program Instruction ACF OA PI 13 01 ACF OA PI 13 01 describes the waiver process for the use of federal funding for Commercial Off the Shelf (COTS) software products in human services programs. Key Cost Allocation Q&As HHS released a new Q&A s document on the OMB Circular A 87 cost allocation waivers and use of 90 percent FFP in support of enhancing state E&E Systems and integrating state HHS systems. Tri Agency Letter on Details of Cost Allocation Waiver This letter includes detailed instructions on the exception to the cost allocation requirements in OMB Circular A 87 described in the tri agency letter (below). It provides guidance on how States may use the exception, including 19 safeharbor functions, modules, and components. Tri Agency Letter Announcing Cost Allocation Waiver This letter announced an exception to the cost allocation requirements in OMB Circular A 87 to allow Federally funded human services programs to benefit from investments by Medicaid in State eligibility systems, including across human services programs. For additional information, contact the ACF interoperability team at (interoperability@acf.hhs.gov).
Top 10 Reasons Why States Should Take Advantage of the A 87 Cost Allocation Exception
Happy Eligibility Workers!
Happy Tech Support!
Happy Mainframe
Happy Budget Office!
Happy Feds
Happy Clients
Now about those happy feds.
Paperwork!!
While Avoiding Disallowed Costs (Which sometimes means required paperwork) Submit your APDU to FNS for approval Submit your contract and/or amendment(s) Pay attention to cost allocation SNAP costs must still be charged to SNAP SNAP administrative costs are under scrutiny
What Can You Do Now? Prepare those documents for FNS approval Become familiar with new system architecture Identify SNAP needs and requirements for development or integration Consider opportunities for new business processes throughout human services Manage the change
APHSA s A 87 Exception Toolkit I. What is the OMB A 87 Cost Allocation Exception? Business Services and Components that Qualify Limitations II. Potential Savings How Does the Exception Work? Savings: Before and After Examples III. What Can Be Completed in the Time that Remains? Within 12 Months Within 12 18 Months Longer than 18 Months IV. Strategies http://www.aphsa.org/content/ APHSA/en/pathways/NWI.html
A 87 Exception Implementation Time Frames Level 1: Front Door: Can Be Done Quickly Document Imaging Digitization of Case Records Client Portals Notices Customer Services Workflow Mgmt Tools User Interfaces Interfaces to Community Assisters and Outreach Organizations Level 3: System s Heart and Soul: Requires Most Amount of Time Level 2: Foundational System Components: Takes a Little Longer Automated Account Creation and Case Management Business Rules Engine Enterprise Service Bus Interfaces to State/Federal Verification Services Data Warehouse Master Client Index Identity Management