Supporting Statement
Medicaid State Plan Base Plan Pages
CMS-179, OMB 0938-0193
BACKGROUND
The Centers for Medicare & Medicaid Services (CMS) works in partnership with States to implement Medicaid, which provides health coverage to millions of Americans. Medicaid is rooted in Federal statute (Title XIX of the Social Security Act), associated regulations and policy guidance, and the approved State plan documents that serve as a contract between CMS and States about how Medicaid will be operated in that State (or Territory.) CMS works collaboratively with States (including States and Territories) in the ongoing management of programs and policies.
1. Need and Legal Basis
Section 1901 of the Social Security Act (42 U.S.C. 1936) requires States to establish a State plan for medical assistance that is approved by the Secretary to carry out the purpose of Title XIX. The State plan is a comprehensive document (approximately 700 pages) comprised of semi-structured templates developed by CMS and completed by State Medicaid agencies. The State plan functions as a contract between the State and Federal government, describing how the State will implement its program in accordance with Federal laws and regulations in order to secure Federal funding.
When a State wants to change its Medicaid program, the State Medicaid agency is responsible for developing an amendment submission for CMS approval, also called a State plan amendment or SPA. The State completes the templates relevant to the program change it seeks and submits the SPA to CMS for approval. The SPA submission includes a CMS-179 transmittal form and the relevant SPA templates the State wishes to update or revise. A State may amend one or more of the plan pages at a time. The templates are semi-structured forms that correspond to the statutory and regulatory Medicaid requirements. The data structure CMS provides in the forms allows States to develop SPAs more efficiently by including only relevant information. The plan pages are organized by subject matters which include Medicaid eligibility, services, payment for services, and general and personnel administration.
When CMS receives the SPA, it has 90 calendar days to approve or disapprove the SPA, or formally request additional information. If CMS does not act within 90 calendar days, the SPA is deemed approved. If CMS formally requests additional information, the review clock stops until the State submits a formal response. When the State formally responds, a second 90-day review clock begins, and CMS must either approve or disapprove the SPA within 90 calendar days. For a State to receive Medicaid Title XIX funding, there must be an approved Title XIX State plan.
2. Information Users
State Medicaid agencies complete the plan pages. CMS reviews the information to determine if the State has met all of the requirements of the provisions the States choose to implement. If the requirements are met, CMS will approve the amendments to the State’s Medicaid plan giving the State the authority to implement the flexibilities. For a State to receive Medicaid Title XIX funding, there must be an approved Title XIX State plan.
3. Improved Information Technology
The current collection is electronic in the sense that SPAs are normally submitted to CMS via e-mail, generally including either Microsoft Word templates or a scanned version of the paper amendment. CMS is currently developing a structured data system called MAC Pro that will become the electronic submission and processing system for this collection and related information.
4. Duplication
There is no duplication of similar information.
5. Small Business
There is no burden on small businesses.
6. Less Frequent Collection
Once any amendment is approved, there is no need to submit additional amendments unless the State initiates a change. This State plan amendment process is rooted in the statutory language found in Title XIX and has been used since the inception of Medicaid in 1965.
7. Special Circumstances
There are no special circumstances that will affect the collection of this information.
8. Federal Register Notice/Prior Consultation
The 60-day Federal Register notice published on April 20, 2015 (80 FR 21720). No comments were received.
9. Payment/Gift to Respondents
There is no payment or gift to respondents.
10. Confidentiality
The Medicaid State plan is public information. No assurance of confidentiality has been provided to respondents.
11. Sensitive Questions
There are no questions of a sensitive nature associated with this form.
12. Burden Estimate
Wages
To derive average costs, we used data from the U.S. Bureau of Labor Statistics’ May 2014 National Occupational Employment and Wage Estimates for all salary estimates (http://www.bls.gov/oes/current/oes_nat.htm). In this regard, the following table presents the mean hourly wage, the cost of fringe benefits (calculated at 100 percent of salary), and the adjusted hourly wage. The wage is a comparable position to State employees likely responsible for completing and returning the templates.
Occupation Title |
Occupation Code |
Mean Hourly Wage |
Fringe Benefit (at 100%) |
Adjusted Hourly Wage |
Business Operations Specialist |
13-1000 |
$32.40 |
$32.40 |
$64.80 |
As indicated, we are adjusting our employee hourly wage estimates by a factor of 100 percent. This is necessarily a rough adjustment, both because fringe benefits and overhead costs vary significantly from employer to employer, and because methods of estimating these costs vary widely from study to study. Nonetheless, there is no practical alternative and we believe that doubling the hourly wage to estimate total cost is a reasonably accurate estimation method.
Burden
There will be a total of 56 States and territories as possible respondents for this request, all of whom made the required entry when the election of Medicaid in its State was made. There is no particular methodology or reason why any particular number of States and territories would choose to amend the aforementioned provisions of its Medicaid State plan. The collection is required only if a State determines that a change to its Medicaid program warrants a change in the original response.
If however, each of the 56 respondents would submit an average of 20 responses per year, for a total of 60 responses over the 3-year period, this would result in an estimated burden of 1,120 (56*20) total responses (annual). The estimate of time involved for completing a template is 20 hours or 22,400 total hr (annual).
Under the above scenario, the cost is $25,920 per respondent ($64.80/hr x 20 responses/yr x 20 hr/response) or $1,451,520 (aggregate) ($25,920 x 56).
13. Capital Costs
There are no capital costs associated with this information collection.
14. Costs to Federal Government
To derive average costs, we used data from OPM’s 2015 Salary Table for the locality pay area of Washington-Baltimore-Northern Virginia (http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2015/DCB_h.pdf). Our estimate assumes a base hourly wage of $46.42 for a GS-13 step 3. To include the the cost of fringe benefits (calculated at 100 percent of salary), our adjusted hourly wage estimate is $92.84/hr.
The cost is estimated to be $311,942.40 ($92.84/hr x 1,120 possible yearly amendments x 3 hours per amendment on average).
15. Program/Burden Changes
This package includes nonsubstantial terminology changes to Section 4 of the State plan related to payment. The templates corresponding with the following sections have been updated (see Exhibit DP, Exhibit F and G, and Exhibit Y):
4.19(c)
4.19-D
4.19.B
The changes are set out in the attached Crosswalk.
The cost to respondents have been adjusted by considering the current BLS wage estimates and our estimate for fringe benefits.
The cost to the federal gov’t has been adjusted based on current OPM figures and our estimate for fringe benefits.
16. Publication and Tabulation Dates
Medicaid State plans are public documents generally available on the Internet. However, there are no plans to publish the information specifically for statistical use.
17. Expiration Date
CMS does not oppose the display of the expiration date.
18. Certification Statement
There are no exceptions.
The use of statistical methods does not apply for purposes of this form.
| File Type | application/msword |
| Author | CMS |
| Last Modified By | Mitch Bryman |
| File Modified | 2015-06-29 |
| File Created | 2015-06-29 |