Supporting Statement for the Information Collection Requirements (ICRs)
For the State Child Health Plan Under Title XXI of the Social Security Act,
State Children’s Health Insurance Program and
Model Application Template and Instructions
A. Background
The Balanced Budget Act of 1997 created the Children’s Health Insurance Program under Title XXI of the Social Security Act. Title XXI enables States to initiate and expand health insurance coverage for uninsured children. In order to be eligible for payment under this legislation, each State submitted an initial Title XXI plan for approval by the Secretary that details how the State intends to use the funds. States may also amend their plans at any time by submitting an amendment for approval by the Secretary. Under the law, a State plan or amendment is considered approved in 90 days unless the Secretary notifies the State in writing that the plan is disapproved or that specified additional information is needed. The plan encompasses all of the child health assistance being provided using Title XXI funding. It is important to note that once a Title XXI plan is approved, the State is obligated to continue providing benefits as described in that plan until the plan is amended. All 56 States and Territories have submitted and received approval for State plans and numerous amendments to their plans. States will continue to amend their plans as necessary to reflect changes to their programs.
After 10 years of experience with the State Children’s Health Insurance Program, we feel it is important to clarify certain parts of the State plan template. Specifically, CMS wants to ensure clarity of the information on income levels related to Medicaid expansion programs; and have revised the instructions appropriately. Also, the instructions clarify information that should be included in the State plan template regarding eligibility and coverage of unborn children.
B. Justification
1. Need and Legal Basis
The legal authority for this collection is Title XXI of the Social Security Act.
2. Information Users
States must submit Title XXI plans and amendments for approval by the Secretary. The plan or amendment must be submitted to CMS. The plan and its subsequent amendments are used by CMS to determine if the State has met the requirements of Title XXI.
Information provided in the state plan, state plan amendments and from the other information CMS is collecting will be used by: advocacy groups, beneficiaries, applicants, other Governmental agencies, providers groups, research organizations, health care corporations, health care consultants and States. These groups will use the information collected to assess state plan performance, health outcomes and an evaluation of the amount of substitution of private coverage that occurs as a result of the subsidies and the effect of the subsidies on access to coverage.
3. Improved Information Technology
States and non-Federal governmental plans can use their data processing and electronic systems to generate notices to participants and beneficiaries regarding eligibility determinations, public notices and enrollee rights to file grievances and appeals.
States can use their electronic systems to send CMS information regarding their: state plan, state plan amendments, actuarial reports for benchmark-equivalent coverage, state expenditure and statistical reports, annual reports, state evaluations, the amount of substitution that occurs as a result of subsidies and the effect of subsidies on access to coverage, documentation (to be found in each applicants file -- facts that support the state's determination of the applicants eligibility for SCHIP), and the annual amount the state spends on family coverage and the number of children it has covered (this information is captured in the annual report).
4. Duplicate Information
Title XXI is a program created by the Balance Budget Act. There is no duplication of this information.
5. Small business
This collection of information does not involve small businesses or other small entities.
6. Less Frequent Collection
Title XXI of the Social Security Act requires each state to submit a child health plan and receive approval by the Secretary in order to be eligible for Federal funds. Once the plan is approved, it remains in effect until the state requests changes by submitting a plan amendment to CMS for approval. All states and Territories have approved state plans; however, states will submit amendments for approval when they want to make changes to their plans.
7. Special Circumstances
There are no special circumstances.
8. Federal Register/Outside Consultation
A 60-day Federal Register notice was published on March 14, 2008.
CMS has consulted with the National Governor’s Association, states and other private and public parties in the development of this plan, the model template and instructions, and in the estimate of the reporting and record keeping burden.
9. Payments or Gifts
There is no provision for any payment or gift to respondents associated with this reporting requirement.
10. Confidentiality
Because no personal identifying information is collected in the report, there is no issue of confidentiality with respect to the information submitted by the State. The information submitted by the State is available for public review.
11. Sensitive Questions
There are no questions of a sensitive nature in the information collection.
12. Estimate of Hour Burden and Cost to Respondents
Although States may submit the information in any manner to demonstrate that they have met the requirements set forth in Title XXI of the Social Security Act, CMS, in cooperation with the states, has developed the attached model application template and instructions to reduce the burden associated with these ICRs to a minimal level. The estimate of burden includes time for reviewing instructions, gathering information, and completing the model template. Because all states already have approved plans, states currently submit amendments when needed to make changes to their programs. They alter only those portions of the model application template that are affected by the change.
Section 457.60 -- Amendments
In summary, §457.60 requires a State to submit to CMS for approval an amendment to its approved State plan, whenever necessary, to reflect any changes in: 1) Federal law, regulations, policy interpretations, or court decisions, 2) State law, organization, policy or operation of the program, or 3) the source of the State share of funding.
The burden associated with this requirement is the time and effort for a State, using the State Plan Amendment template to prepare and submit to CMS for approval, any necessary amendments to its State plan. Based upon CMS's previous experiences with State plan amendments we estimate that on average, it will take a State 80 hours to complete and submit an amendment. We estimate that 40 amendments will be submitted on an annual basis for a total burden of 3,200 hours.
Record Keeping and Reporting Burden
40 amendments X 80 hours = 3,200 hours.
Total Annual Cost
The estimate of annualized costs to the State governments is $27,266 (28.01 percent of the total costs of $97,344). The State employee hourly wage figure is computed as 80 percent of the 2004 GS-12, step 1, annual salary, plus 20 percent retirement/insurance benefits. The average State cost is computed as follows:
$30.42 per hour X 3,200 hours per year = $97,344
$97,344 X 28.01 percent (average State share) = $27,266.
13. Total Costs as a Result of Data Collection
There are no start-up costs associated with this information collection.
14. Federal Costs
The estimated average annualized cost to the Federal government per state is 71.99 percent X $97,344 = $70,078.
The cost estimate is computed as follows:
Title XXI provides an enhanced Federal match that is 30 percent of the difference between 100 and the current Federal match. The average Federal match for Federal Fiscal Year 2004 is 59.99 percent of total costs. Therefore, the average enhanced match under Title XXI is 71.99 percent.
Federal costs = 71.99 percent X $97,344 = $70,078
15. Program/Burden Changes
There are no program or burden changes.
16. Publication and Tabulation Data
There are no plans to publish the information for statistical use.
17. Display of Expiration Data
CMS is not seeking approval not to display the expiration date for OMB approval of the information collection.
18. Exception to Certification Statement
There are no exceptions to the certification statement.
C. Collection of Information Employing Statistical Methods
CMS does not intend to collect information employing statistical methods.
| File Type | application/msword |
| Author | CMS |
| Last Modified By | CMS_DU |
| File Modified | 2008-05-16 |
| File Created | 2008-03-04 |