2014-01-23_SOTA Call on A87_Final Slide Deck

Medicaid/CHIP & Human Services System
Jessica Kahn, Director,
Division of State
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
• 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
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!
• 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
• 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
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
State Systems Interoperability and Integration Grants
Interoperability Toolkits
Confidentiality Toolkit
ACF Interoperability Website / Communications
The Low-Hanging Fruit
State Systems Interoperability and Integration Grants
• New York:
• Maryland:
• Indiana:
• Illinois:
• Colorado:
• Oklahoma:
• California:
The Children’s Passport Design
NIEM and NHSIA Integration
Social Return on Investment Calculator
Vital Statistics Interface for Human Services
Program Integrity and Improved Services Delivery
Governance Model and Integration Roadmap
Enhanced Interfaces and Data Sharing
NIEM and NHSIA Integration
A Bridge of Enhanced Interfaces and Data Sharing
Includes ESB and SOA Integration
Governance Model and Data Sharing Concepts
A Proof-of-Concept Application
The Other Low-Hanging Fruit
Projects from the ACF Interoperability Initiative
• S2I2:
PARIS Database Interface Model and XML Schema
Titles IV-E and IV-D Interface Model and XML Schema
A Mature, Version 1 Model With 7 Design “Viewpoints”
Compatible with MITA 3.0
Seven Grant Projects With Deliverables Being Published
Final Reports From Each to be Published
• Interoperability
A Wealth of Knowledge From Schedules to Guidance
• Confidentiality
Data Sharing in 6 Human Services Programs – Discussed
Includes Appendix of 6 Matrices – Regulations/Statutes
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
([email protected]).
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….
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
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
 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
A-87 Exception Implementation
Time Frames
Level 1: Front Door: Can Be
Done Quickly
Document Imaging
Digitization of Case Records
Client Portals
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
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

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