About the IAPD Companion Guide for State Medicaid Agencies (SMAs)

Transcription

1 (Disclaimer: This document is a draft pending final CMS approval) About the IAPD Companion Guide for State Medicaid Agencies (SMAs) Purpose: Components: This Guide is intended to be a resource to SMAs to provide additional clarification and successful examples (including tips, sample text and tables) regarding the development and submission of the HITECH IAPD and IAPD updates (IAPD Us). This Guide is composed of two parts: 1. IAPD Companion Guide Tip Sheet: The Tip Sheet provides helpful do s and don ts by IAPD section along with links to additional resources. 2. IAPD Companion Guide Addendum: The Addendum provides sample text and tables by IAPD section. SMAs can feel free to use and customize the text and tables included in the Addendum. Caveats: Additional Resources: The sample text and tables included in this Guide are illustrative of how some states have successfully presented the required information in their IAPD, which has resulted in a more expeditious review and approval. States are not required to strictly follow these examples to receive approval of their IAPD. Furthermore, guidance contained herein does not supersede federal laws and regulations. Additional guidance and clarification can be obtained from your Regional Office lead and/or Robert McCarthy (Robert.McCarthy@cms.hhs.gov ). Page 1

2 IAPD Companion Guide Tip Sheet SECTION I EXECUTIVE SUMMARY SECTION II RESULTS OF ACTIVITIES INCLUDED IN PAPD (if applicable), INCLUDING SMHP 1) Provide a brief but complete overview of your IAPD Update (IAPD U) request 2) Section should be 1 2 pages in length 3) Specifically include: A chart that provides the total requested amount for the current IAPD U with the cost broken down by funding stream for all implementation activities described in the IAPD U The total requested amount for MMIS activities (Appendix A) The total requested amount for health information exchange/hie activities (Appendix D) 1) Include a brief description of the status of activities under the PAPD, SMHP, and previous versions of the IAPD 2) Include a table showing the status of activities under the PAPD, SMHP and previous versions of the IAPD 3) Include a table/chart that outlines the history of funding requests, including the PAPD, IAPD and any subsequent IAPD updates 4) Include tables that break out funds approved, expended, and remaining for the PAPD and previous versions of the IAPD by using the table included in the template 5) If the PAPD activities have been completed, the narrative should state that the planning grant can be closed out; if the PAPD has already been closed out, include an explicit statement to that effect 1) Do not forget to review the SMHP to make sure that it aligns with the IAPD. 2) Do not forget to review the numbers to make sure they are consistent with the amounts in other sections 1) Do not forget to explain what may have caused delays in the start or completion of certain activities Page 2

3 SECTION III STATEMENT OF NEEDS AND OBJECTIVES SECTION IV STATEMENT OF ALTERNATIVE CONSIDERATIONS SECTION V PERSONNEL RESOURCE STATEMENT 1) Describe at a high level the needs of the project for which requested funding will be used (e.g. Administrative needs, Outreach needs, Technical Assistance needs) 2) Consider organizing the objectives of the projects as they relate to specific goals and vision for the overall HIT program (see example in the Addendum) 3) Describe how the state will measure progress toward goals and objectives (refer to the latest version of the SMHP as deemed appropriate) 1) If no substantive changes have been made to the program, include a statement that refers back to the Statement of Alternative Considerations contained in previous versions of the IAPD or in the SMHP 2) If substantive changes have been made, include a statement describing the alternatives that the state considered when making the change; remember to update the SMHP as necessary with any substantive changes to the approach for implementing EHR incentives 1) Include information on both state personnel and contractors in separate tables 2) For state staff, include a table that shows staff function, % of time spent on HIT activities, number of hours spent on HIT projects and costs including benefits, and a description of staff responsibilities 3) Total state staff costs with benefits should align to the state personnel line item on the budget in Section VII 1) Do not forget to add a clear statement of goals and/or objectives and how the state will measure and monitor progress toward them 1) Do not show state personnel costs that differ from what is included in the budget reflected in Section VII 2) Do not use TBD in place of an actual dollar figure for planned contractor procurements Page 3 Specifically regarding contracts that utilize HITECH funds, please note that (1) 42 CFR states that any contract utilizing HITECH funds must have CMS prior approval prior to execution. (2) All of these contracts must conform to Federal

4 4) For Contractors, include a table reflecting each contract including contractor cost category, contractor/vendor name, total contract cost description of contractor services, whether services relate to HITECH or HIE activities and the term of the contract; this table should also include projected contractor costs related to procurements which have been approved by CMS 5) For planned procurements, include projected contractor roles and costs regulations outlined in 42 CFR 495. (3) States will receive written approval from CMS for these contracts; the approval will be in the HITECH IAPD approval letter or in a separate contract approval letter. SECTION VI PROPOSED ACTIVITY SCHEDULE SECTION VII PROPOSED BUDGET 1) List out all program activities since receipt of PAPD funds, including activities that have occurred under previously approved PAPDs and IAPDs 2) For each activity, include start date, end date or projected end date, and status (completed, ongoing, not started, etc.) 1) Present the total cost of Medicaid HITECH activities across all activity categories: Medicaid EHR Incentive Program, Medicaid HIE, etc. (each activity category has its own line item) 2) Present a complete request for FFP that includes all applicable funding sources (e.g. Medicaid HITECH, MMIS Design Development and Implementation (DDI), MMIS Maintenance and Organization (M&O)) 3) Be explicit about the requested Federal match amount and the State amount 4) Be explicit about the various applicable levels of federal funding being requested (ex: 90%, 75%, 50%) 5) Budget for a full two years 1) Do not include expenses which will not be incurred prior to 12/31/2021; expenses incurred after that date will only be eligible for 50% FFP as allowed by Federal regulations 2) Do not forget to line up requested funds with activities and timelines outlined in the Proposed Activity Schedule (Section VI) 3) Do not forget to review the SMHP to make sure that it lines up with the IAPD Page 4

5 6) Break down projected program costs by federal fiscal quarters 7) Personnel costs must include salaries and benefits 8) Contracts and projected contracts must be itemized, with estimated costs per contract included in the budget detail 9) Miscellaneous expenses include materials and supplies, communications related expenses, printing costs and facilities expenses; these costs can be broken out into distinct cost categories in the budget detail per the state s Chart of Accounts 10) Provide an explanation of these projected expenditures SECTION VIII COST ALLOCATION PLAN FOR IMPLEMENTATION ACTIVITIES 1) As specified in OMB Circular A 87, a cost allocation plan must be included that identifies all participants and their associated cost allocation to depict non Medicaid activities and non Medicaid FTEs participating in this project, if any 2) HITECH cost allocation formulas should be based on the direct benefit to the Medicaid EHR Incentive Program, taking into account State projections of eligible Medicaid provider participation in the incentive program (leveraging actual data/experience as deemed appropriate) 3) Cost allocation must account for other available Federal funding sources, the division of resources and activities across relevant payers, and the relative benefit to the State Medicaid program, among other factors 4) Be sure that cost allocations involve the 1) Do not assume that the absence of other payers is sufficient cause for Medicaid to be the primary payer 2) Do not be ambiguous about other potential federal funding sources; for example, if no CHIP funds are being requested, include a statement to that effect in this section Page 5

6 timely and ensured financial participation of all parties. Medicaid funds should be neither the sole contributor at the onset nor the primary source of funding. States should demonstrate that other payers who stand to benefit are contributing their share, ideally from the beginning of the program/activity/service for which funding is being requested 5) Restate costs subject to cost allocation, and the items/expenditure types for which FFP from various fund sources is being requested (e.g. MMIS) 6) Restate FFP being requested, and from which federal fund sources, in this section 7) Restate all costs for which funding is requested via this particular IAPD SECTION IX ASSURANCES, SECURITY, AND INTERFACE REQUIREMENTS 1) Ensure that your state complies with all applicable Code of Federal Regulations (CFR) and State Medicaid Manual (SMM) citations 2) Strongly consider using the example provided in the Addendum for this section 3) Any no responses must be explained; CMS will contact you to discuss reasons for noncompliance prior to approving your request 1) Do not forget to explain any no responses. CFR and SMM Citations: Page 6-42 CFR Part SMM Section CFR Part CFR Part CFR Part CFR Part CFR Part CFR Part (b)(5) (9) - 45 CFR Part CFR Part CFR Part CFR Part CFR Part CFR Part 164 Securities and Privacy

7 APPENDIX A MMIS 1) IF APPLICABLE, provide a breakout of MMIS expenditures related to HITECH activities that are eligible for MMIS FFP 2) Include a narrative or bulleted description of these activities and expenditures 3) See State Medicaid Director Letter for examples and other guidance regarding appropriate MMIS expenditures 1) Don t include expenditures related to EHR Incentive Program systems which are distinct systems and not MMIS components ; e.g. systems developed by CGI (Incentive360) and Maximus (PIPP) MAPIR Automated CMS 64 reporting of Medicaid EHR incentive program expenditures APPENDIX B PROVIDER INCENTIVE PAYMENTS 1) Include provider incentive payments already made, broken out by federal fiscal quarter, ideally going back to the start of the EHR Incentive Program 2) Provide estimates of future incentive payments for at least one year preferably for the time period for which IAPD funding is being requested 3) Provide estimates of the number of providers by type (professionals and hospitals) who will receive payments during the period for which payment estimates are provided 1) Don t forget to reconcile provider incentive payments to figures reported on CMS 64 s 2) Don t forget to include a statement that makes it clear that the incentive payment history and projections are based on data as of date xxx APPENDIX C GRANTS 1) Make sure that the State accounts for all grant funding that is used to support any activities mentioned in the IAPD U request 2) Review the State Medicaid Director Letter for examples of grants that might need to be included as well as other guidance 3) Consider using the table in the addendum to make sure key information regarding each grant is provided 4) Make sure that any new grants are included and any expired grants are removed 1) Do not get bogged down in detailed descriptions of the grant activities; high level descriptions are appropriate (see addendum for example) 2) Don t forget to make sure any funding amounts are consistent with the IAPD U request Page 7

8 APPENDIX D HIE APPENDIX E STANDARDS AND CONDITIONS 1) Ensure that this section provides information contained in the checklist in the addendum 2) Complete this section in narrative format 3) Reference previous IAPDs for background information if a comprehensive overview of the State s HIE has been previously provided 4) Provide the most current update regarding progress toward benchmarks, milestones and schedule 5) Make sure the cost allocation methodology, data sources, and funding requests are broken out by MMIS or HITECH as appropriate 1) Follow the format provided in the Addendum section should contain a high level checklist as well as narrative description for each of the main subject areas in bold 1) Don t forget to double check the budget in this section with budgets/requests in other sections 1) Don t forget to ensure that the narrative meets your state s circumstances (rather than strictly follow the narrative in the addendum) id Information Technology MIT/Downloads/Enhanced Funding Requirement Seven Conditions and Standards.pdf Page 8