Medicaid/CHIP & Human Services System Integration

1. Medicaid/CHIP & Human Services System Integration Jessica Kahn, Director, Division of State Systems SOTA Call January 23, 2014

2. 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

3. 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 cost-allocated within an integrated system

4. 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

5. 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 IAPD-updates • 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!

6. 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)

7. 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

8. 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

9. 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

10. The Low-Hanging Fruit State Systems Interoperability and Integration GrantsS2I2 • 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

11. 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 • S2I2: Seven Grant Projects With Deliverables Being Published Final Reports From Each to be Published • InteroperabilityToolkit: A Wealth of Knowledge From Schedules to Guidance • ConfidentialityToolkit: Data Sharing in 6 Human Services Programs – Discussed Includes Appendix of 6 Matrices – Regulations/Statutes • ACFInteroperabilityWebsite:www.acf.hhs.gov/initiatives-priorities/interoperability

12. Policy Ripe For The Picking • Program Instruction ACF-OA-PI-13-01ACF-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&AsHHS 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 WaiverThis 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 “safe-harbor” functions, modules, and components. • Tri-Agency Letter Announcing Cost Allocation WaiverThis 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).

13. 6 / Top 10 Reasons Why States Should Take Advantage of the A-87 Cost Allocation Exception

14. Happy Eligibility Workers!

15. Happy Tech Support!

16. Happy Mainframe

17. Happy Budget Office!

18. Happy Feds

19. Happy Clients

20. Now about those happy feds….

21. Paperwork!!

23. 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

24. 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

25. APHSA’s A-87 Exception Toolkit • What is the OMB A-87 Cost-Allocation Exception? • Business Services and Components that Qualify • Limitations • 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

26. A-87 Exception Implementation Time Frames • 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 • 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 • Data Warehouse • Master Client Index • Identity Management