Presentation on theme: "State Systems Panel Joe Bodmer Terry Watt Dave Jennings Chuck Lehman Karen Painter Jaquess."— Presentation transcript:
State Systems Panel Joe Bodmer Terry Watt Dave Jennings Chuck Lehman Karen Painter Jaquess
“ We are building our ACA system to comply with MITA, so we don’t have to worry about the NHSIA standards.” MITA was designed for Medicaid. Now you are building something bigger. The NHSIA standards are complementary to MITA, not competing or redundant. NHSIA offers different “viewpoints” into specific aspects of a system architecture - data, business, capabilities, infrastructure, systems, and project, which may help identify and fill gaps that MITA doesn’t address for Human Services.
“ Taking full advantage of the A-87 waiver means it’s ok to add case management for DOL and similar programs, typically considered outside of health or human services.” You can’t apply the A-87 waiver to non-health or non-human services programs Nonetheless, States should still consider including those programs in an enterprise architecture, because there are business efficiencies and customer service benefits to be gained even if Title XIX can’t cover the shared costs for those programs.
“ It’s ok to charge routine costs, like new PC’s for the child welfare staff, or updating a component in my siloed Human Service application, to title XIX under these funding authorities.” You can’t use the A-87 waiver authority for your siloed information system. It is only applicable to SHARED costs in an enterprise or integrated system. Even if you were building shared services accessed through an enterprise system benefiting title XIX, the cost of components, modules or hardware specifically needed only for other programs, such as PC’s used to access the shared services, would be a direct charge to those programs.
“ If the State Medicaid folks won’t talk to us, we can just send an APD directly to CMS to request 90/10 funding or an A-87 exception for our Human Service application needs.” The 90/10 funding is only available for Medicaid’s share of system costs. Thanks to the A-87 exception, system components, services or modules that Medicaid builds/buys can be used by other health and human services programs, at no cost. But neither of these funding authorities allows CMS to provide funding to programs other than Medicaid for system costs. Other programs still need to pay the incremental costs of adding or changing any functions or components to serve their needs.
“ We don’t need to worry if the State Medicaid folks don’t have time/won’t play nice – the Feds will make them do it. The 7 Standards and Conditions require them to include us.” application needs.” To get 90/10, the 7 Standards and Conditions require Medicaid state agencies to create system solutions that “allow interoperability”. They don’t require a State to achieve interoperability on a specific timeline. State human service agencies still have to bring their needs, their business case and their willingness to re-think business processes to the table. “The Feds” have opened the door – you have to walk through it. Together.
“ CMS is coordinating everything now – just send your documents to them and they’ll take care of ACF and FNS.” YOU still need to send your documents to each agency who will be expected to kick in, at any phase. Sending your documents only to CMS may cause delays. CMS is often the majority funder in ACA-related projects, but approval from each Federal funder is still required. An approval from CMS doesn’t guarantee approval or funding from the other Feds.
“ If I’m not asking for any funding in this phase from FNS or ACF, I don’t need to get their approval for my APD or procurement. I’ll just send them an APDU when the time comes.” Send all agencies your IAPD, even if you aren’t requesting funding from some until later. As you near the appropriate phase(s), submit APDUs that provide more detail. When you sign a contract that includes work on SNAP or ACF programs, you are essentially committing those program’s funds. You’ll need to get those agencies’ approval of the procurement up front.
“ We have to wait for policy decisions on the insurance exchanges before we can develop the interfaces” All States, no matter what form of Exchanges they may decide upon still must be capable of accessing the Federal Data Hub for citizenship, income and other available Federal Verification information. Waiting too long to make the Exchange decision will likely mean that the State would need to connect to the Federally Facilitated Exchange in order to receive and send client account information.
“We have to wait for policy changes from SNAP before we can determine how SNAP will fit into the system/architecture.” Some of the SNAP rules are in the statute. Some would require action by congress. Some changes would cost a lot of money, which is tough to sell in tight budget times. System solutions today can be smart enough to provide a unified PROCESS without requiring unified policies, rules and definitions. Keep working on policy questions. Keep proposing pilots and demonstration projects. But don’t get so hung up on the policy issues that you fail to see and grab onto the potential of technology solutions to help you work through and around those policy differences.
“ Medicaid will be DONE on 1/1/14 and the other human services partners will have to pay for everything after that.” The State Medicaid office must meet the requirements of the ACA by 1/1/14, but that does not mean their entire Medicaid case management system must be completed. In fact, the ACA addresses only the Income Based Medicaid populations. Most States will need to address the more complex Aged, Blind and Disabled (ABD) eligibility groups after the January 2014 deadline. Funding under the enhanced 90/10 FFP rate and the use of the A-87 exception goes on until December 31, “Add-ons” like data warehousing with data analytics, customer service portals, and master client indexes that enhance Medicaid functionality, AND benefit other programs, can be completed during that extra 2 years.
“Privacy/Confidentiality rules prevent us from having a robust, meaningful data exchange or a truly interoperable system.” Institutional/cultural barriers are often as much to blame as actual rules State statutes and regs sometimes go far beyond anything Federal law suggested To at least get a more realistic view of the issue, check out ACF’s Interoperability Initiatives Project “Confidentiality Toolkit” available this fall.
“If my program isn’t “at the table” now, it’s too late.” It’s NOT too late! Be informed and involved, to best position yourself for a later phase. Make your business case. Demonstrate your willingness to reconsider long-held business process and program-specific assumptions. It’s only too late if you ignore the potential for phase 2 or phase 3 and aren’t ready to play.
“The project is too busy to talk to my program right now - I can wait until 1/2/14 to get involved.” If you wait until January 2014 to START thinking, and engaging, 2 years won’t be enough. Be ready to approach that date not with questions, but with answers and plans. Do your needs assessment and your business process analysis. Know what you need change and what you are willing to change. Get your people on the governance, policy and technology teams. Do the cost analysis for the program-specific components, work on the draft IAPD-U for your phase, and get your Federal approval before work begins on your stuff.
“Medicaid can pay for EVERYTHING!” The Tri-Agency letters have outlined very clearly the kinds of things that Medicaid can pay for, that other programs can benefit from - Things like Rules Engines, Case Management Tools, Master Data Management and Data Warehouses. Anything that another program needs to add or change, that is unique to that program, cannot be charged to Medicaid, and must be paid for directly by the benefitting program.
“The Gate Reviews are just a formality. The feds have to support getting these projects done on time. Once my project is approved/ contract signed, they aren’t going to withhold funding or do anything to slow me down, no matter how my project is going.” There are several key functions that must be in place on day one in order to meet the ACA objectives. The purpose of the gate reviews is to monitor the capability of the State to meet those objectives and to ensure there are adequate contingencies in the event of a schedule slippage. If the Feds spot a problem in a gate review, the point isn’t to slow you down, it’s to help you get past it to meet the goal!
“The Feds will extend the deadline – they know most states won’t be able to make it.” The federal agencies do not have the authority to extend the deadline. Better just get on with it!
“Technical details of the federal data hub are well understood” These details are still being worked out. CMS plans to issue a clarification on the federal data services hub in September. Vender Perspective
“Inserting eligibility policies into a modern business rules engine is easy. Maintaining rules in a BRE is a breeze. All users can do it.” This process is non-trivial and requires detailed knowledge of syntax. It is important to establish and enforce governance on who and how to enter and maintain business rules. Vender Perspective