CMS Multi-State HITECH Conference

CMS Multi-State HITECH Conference

April 10, 2012

CMS Office Hours – RFPs, IAPDs, Contracts

Robert McCarthy

Robert opened the discussion by updating participants on Procurement and Contracts. He described the following:

Procurement/Contracts –

·  How CMS aligns the contract with the IAPD to review who, what and allocation of federal and state dollars.

·  The need for prior approval from CMS for contracts and RFPs.

·  CMS will check with current approved IAPD and SMHP. If the current IAPD doesn’t reflect contractor, then CMS will return IAPD with comments on what would need to be corrected or adjusted.

·  All federal HITECH and general accounting rules must be reflected in the contract.

-  Line 1 is the Basic line that covers HITECH administrative cost.

-  SMA has access to CMS to pre-review the contract. CMS must approve the contract or RFP or the State can’t pay with Federal funds. $100,000 is the limit for requiring CMS prior approval, but please check with CMS because other conditions may apply that would limit Federal funding.

-  SMA should make certain contractor understands language of contract. Both should realize they are in partnership with the Federal Government and therefore, CMS or anyone can come in and do oversight of the contract scope of work at any time.

-  SMA should have well-defined contracts including the timeline, funding match, IAPD and SMHP. Please call or contact your HITECH coordinator if you need any assistance.

Robert then reviewed the IAPD Template and provided general information for the template.

IAPD template –

·  The IAPD is a chapter or more precisely it is the financial chapter of the SMHP.

·  The IAPD should not regurgitate the SMHP so it should be shorter in length.

·  The IAPD template is an 11 page document. If the IAPD submitted is more than 30 pages long, then it is too long and it should just be a chapter and not a repetition of SMHP

·  IAPD is the past, present, future of financial history for the Incentive Program.

·  Procedurally, CMS has 60 days to review the IAPD. If CMS has the SMA’s IAPD in the template, then it will reduce the time for review. CMS has a team of reviewers so it is important to have consistency for transition between staff. The IAPD will carry the history of what is done and planned by the SMHP.

Robert then provided instruction on each section of the template. The IAPD contains a SMA information summary sheet as the first page to the document. This is followed by a table of contents for each individual section. The section instructions are as follows:

IAPD Sections:

Section 1 – The Executive Summary - a very brief summary of what was already stated in SMHP – can refer to pages in the SMHP to shorten summary.

·  Since there are changes every year, then a new IAPD is required. All IAPDs as of now must be in the new template.

·  In one line, state the IAPD approved date. Also in 1-2 lines state the past cost. Be brief. Emphasize key milestones.

·  Check all totals twice and round any numbers as CMS would like data in whole numbers. The general rule is greater than or equal to .05 to round up, any number less than .05 round down.

·  If the SMA has any questions they can ask the state’s RO HITECH Coordinator or Robert McCarthy.

Section II – Results of Activities Included in the Planning Advanced Planning Document (PAPD) and SMHP

·  The PAPD has what amount was approved, what was spent, the total, PAPD close out date, and when approved, and all should be stated briefly. There are only 1-2 states with an open PAPD still.

·  Next year refer to this year’s IAPD and put the PAPD information into the IAPD so don’t have to repeat the information again.

Section III – Needs and Objectives

·  Refer to the previous IAPD list page and state what is changing and the need for the next 2 years (ex: listed in SMHP, p. 26, section 5)

Section IV - Statement of Alternatives Consideration

·  Need one line where something is located in the original SMHP or previous IAPD. Now list what it is and where it is in a new SMHP and page number.

·  When CMS reviews new document, they compare it to all past documents.

·  CMS will need an organizational chart. If it is in the SMHP and it hasn’t changed, then give the page number where this is located in the SMHP. Don’t use names in the organizational chart as it will help to not have to redo the organizational chart if someone leaves or is added on. Therefore, it is best to use only positions in the organizational chart.

Section V - Personnel Resources Statement

·  For Contractors – list name of contract and when CMS approved contract. Nothing else needs to be added.

·  For State Personnel there is a table to enter personnel. Please use full table sections. If SMA has positions in SMHP, then refer to the page number in the SMHP and states don’t have to list these out again here in the Table.

·  The new grand total – CMS matches this to what is being requested. CMS uses this as it provides good information.

Section VI – Proposed Activity Schedule

·  If SMA is providing information through 2021, then they are providing too much information. At least cover 2 years. The SMA can give a Snag it screenshot of Microsoft Office Project schedule with the timeline. SMHP has some info, but not the details CMS wants for the next 2 years.

Section VII – Budget

The Budget covers past, present, and future cost. CMS has seen Excel spreadsheets with nice colors that describe all costs, but state isn’t asking for funding. CMS wants to know what they approved for funding. SMAs can modify the boxes to suit their needs. Example columns: previously approved funds or what $ is needed to run the program or future expected costs. In the next IAPD, just carry over money is listed in the ‘prior’ box. If CMS knows what state is projecting, then CMS can bank that for state’s requested 2 years.

Ex: Date from ______

Date to ______

·  Annual IAPD – state what will need for next 2 years so CMS can estimate next year’s funding.

-  Contracts, be sure to list all. CMS needs to approve all RFPs and contracts before executed - who and when CMS approved and funding

-  Tables – list administrative funding

-  No miscellaneous costs allowed; must define all funding requests

-  No contingency costs; not able to say that

-  2 year projection should match what is in the CMS 37

-  What is in the IAPD = CMS 37 – ‘close projection’

-  Budget by FFY quarters – start and end on these previously approved, present/current – match to CMS 37

Section VIII – Allocations

·  What if it is not 90/10 funding and is not HIE nor MMIS, or not or partial Medicaid. Funding may not be allocated or partially allocated.

·  There is a new section for 60/40 split of costs which is use from the OMB circular A-87.

·  There should be a summary of costs at the end of the section which should be the total of what the state is requesting.

Section IX – Assurance

·  If indicate no, a brief explanation is needed

·  If mark yes, at bottom the SMA can add the other assurances, MMIS, HIE, and security.

Appendices – The appendices are where the SMA can put costs for individual items.

Appendix A – MMIS – explain why and what money is needed. If approved in other IAPD, identify what money was approved, spent, current, and requested. Any MMIS funding goes here – 75% funding.

Appendix B – EP/EH – 2 years projection. Do a chart – 2 lines by FFY/Qtr. Was the reporting in CMS 37 – estimate – close match?

If state asked for too much, then CMS has to explain to OMB why pulling back money from state – raises many questions. Keep HITECH coordinators informed of changes in projections to funding so can reconcile early. Last year pulled back + $500 million of claim funding not spent.

Appendix C – Information about Grants – For HITECH, it should name who/cost/spent/remaining - table/chart

Appendix D – Information about HIE – The IAPD has separate questions for HIE. A separate IAPD for HIE will not to be approved within 30 days, so as to not slow other IAPD reviews down, do a separate IAPD for HIE (OMB A-87 – use structure circular). Who is involved, who is paying, what is Medicaid share and how you came to that share. If submitted an HIE APD, then say when, cost, etc. are needed.

Appendix E – contains information regarding information about systems and their alignment with the 7 standards and conditions. Explain how is the SMA system meeting these standards and conditions? Be brief - limit to 2 pages.

Comments/Questions/Answers

1.  States operate on SFY, but in award letter CMS does the approval by quarters. Confusion for SMAs

2.  Appendix A – confusion about the matching funds for MMIS – matching funds are for when MMIS funding needed for HITECH expenditure or process.

a.  Question from PA - Core funding for MAPIR and also have a core product. Will meet with CMS to discuss

3.  No need to redline IAPDs now – since now using the IAPD Template each year

4.  Following review, CMS will send a letter to the state with what clarification is needed

5.  State must keep the SMHP and IAPD current

6.  One state does mini grants for providers – for connectivity. HRSA and USDA do mini grants as well.

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