CMS-10615 Emergency Justification (signed by CMS Administrator)

CMS awarded a federal evaluation of the Indiana HIP 2.0 demonstration in late 2015. The
federal evaluation of the HIP 2.0 demonstration, of which the federal survey is a major
component, serves to complement rather than duplicate the State’s previous survey and
evaluation. The federal survey will accomplish this by providing comparable but independent
information on HIP 2.0 enrollees and disenrollees on their understanding, experience and
satisfaction with aspects of HIP 2.0 that are priority for CMS. The federal evaluation will be
conducted on a larger sample of beneficiaries and will allow greater precision in comparisons of
key measures, and for two (2) different time points, than was possible with the State’s evaluation
as CMS understands it.
In December 2015 CMS concluded work with the State on the State’s evaluation design and
surveys. At that point, CMS made adjustments to the federal evaluation and developed a set of
survey instruments that would minimize duplication between the State and federal evaluations
and provide a robust approach to evaluating the Indiana HIP 2.0 demonstration. The new
surveys were not available in time to avoid this emergency clearance request. Therefore, and in
accordance with the implementing regulations of the PRA at 5 CFR 1320.13(a)(2)(ii), we are
submitting this ICR for emergency processing.
Conduct of the debriefing is crucial to ensure that the survey instruments can be tested, revised,
and finalized in enough time to allow: Indiana and public comment, submission and OMB
approval of the main study package, survey data collection and analysis, and CMS deliberation
regarding the waiver prior to its December 1, 2016 expiration date. Obtaining emergency
clearance would enable CMS to meet its objective in time so that no harm is done to Medicaid
beneficiaries. As explained below, the regular PRA process could not be followed due to the
need to meet important “hard” deadlines imposed by the waiver expiration timeline.
Public Harm
Delays in the instrument testing would be incurred if the regular OMB clearance procedures
were used, including the need for 60- and 30-day comment periods; this would result in an
overall process of up to 6 or more months. A delay of this magnitude would jeopardize the
timely completion of the evaluation of the NEMT and other important waivers. Most
importantly, it would potentially cause significant harm by depriving Medicaid beneficiaries-especially those affected by the NEMT waiver--of appropriate medical services and needed care.
Therefore, we are requesting emergency processing under the implementing regulations of the
PRA at 5 CFR 1320.13(a)(2)(i). We expect to continue to engage with the State of Indiana in the
survey development and design process to the extent possible.
Background
Currently 26 states are pursuing traditional Medicaid expansion as written under the Patient
Protection and Affordable Care Act (ACA) of 2010. Six (6) states are expanding Medicaid by
using an alternative to traditional Medicaid expansion (i.e., Section 1115 demonstration
approvals). CMS anticipates that additional states may seek a Section 1115 demonstration for the
new adult group under the ACA. CMS expects that additional federal evaluations likely will be
required for more states, and that the Indiana evaluation can serve as a model.
CMS approved the HIP 2.0 demonstration in January 2015. The demonstration expands
Medicaid coverage under the ACA for individuals in Indiana. The objectives of the
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demonstration include: (1) promoting increased access to health care services; (2) encouraging
health behaviors and appropriate care, including early intervention, prevention, and wellness; (3)
increasing the quality of care and efficiency of the health care delivery system; and (4)
promoting private market coverage and family coverage options through HIP Link to reduce
network and provider fragmentation within families. The demonstration is authorized for three
(3) years from February 1, 2015 through January 31, 2018 (as described above, the waiver of
NEMT is authorized only through December 1, 2016).
In 2014, CMS awarded cross-state federal evaluations covering four 1115 demonstration types of
high priority policy significance. This was the first federal evaluation in over ten years.
Subsequently, in late 2015, CMS awarded a federal evaluation of the Indiana HIP 2.0
demonstration.
Details of Federal Survey Instrument Testing
This emergency approval request is for testing/debriefing of three (3) paper-based draft versions
of a customer satisfaction survey of beneficiaries enrolled and disenrolled in the HIP 2.0
Medicaid demonstration. The testing and debriefing will provide CMS with critical feedback
from the perspective of people in Indiana who are familiar with HIP in order to refine the
instruments prior to fielding the questions during the main study. Our testing approach with
Indiana beneficiaries is intended to guarantee data collection instruments that are of high quality
and relevant to the target beneficiary population.
The target group for testing the draft survey instruments includes a small group of voluntary
participants from Indiana who report that they are currently or formerly enrolled in HIP, or are
familiar with HIP. Our goal is to recruit up to 36 individuals to test three (3) survey instruments
(up to 12 testers per instrument). Recruitment will be monitored to ensure that participants
include both enrollees and disenrollees.
Participants will be contacted by phone through local market research firms (Briljent and
Brightpoint) to schedule a debriefing interview for the testing. The in-person debriefings will
take place in Briljent’s local offices in Indianapolis and Fort Wayne, Indiana. On the day of the
scheduled interview, participants will receive a draft survey instrument and asked to complete it
on site. After the participants complete the draft survey, participants will be debriefed on their
understanding of and experience with completing a draft survey instrument. Debriefings will be
transcribed and summarized, indicating themes and any needed survey revisions. All information
collected will be kept private, and reported in the aggregate only.
The testing will require participants to travel to and from a central location, the Briljent office.
Participants will be offered a $25 “thank you” in the form of a gift card in appreciation of their
time and to cover travel expenses (e.g., gas mileage, public transportation, parking, etc.). This
token of appreciation will also help minimize barriers to participation such as costs of child care
or loss of income from time off from work.
Proposed Timeline of Selected Survey Activities
Testing and Development
Date

Activity
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This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only
and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized
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03/18/2016
03/21/2016 to
03/25/2016
03/21/2016 to
04/08/2016

Requested date of OMB emergency approval
Begin survey testing:
Publish Federal Register notice informing public of the emergency
request and allowing the submission of comments.
Conduct testing/debriefing training; recruit testing participants; conduct
testing/debriefing

Implementation
Date
04/08/2016 to
04/15/2016
04/15/2016
04/15/2016

04/18/2016
04/21 or 04/22/2016
05/21 or 05/22/2016
06/01/2016

06/15/2016
06/15/2016 to
09/15/2016
11/10/2016
12/01/2016
01/31/2018

Activity
Revise survey instruments based on testing results, public comment,
State feedback
Submit final package to OSORA, including emergency clearance
justification (implementation)
Submit final package to OSORA, including emergency clearance
justification (implementation)
Submit emergency package to OMB
Formal OMB approval of emergency processing request
Publish Federal Register notice (30 day comment period)
Public comments due
Response to public comments due to OSORA along with any revised
documents
Formal emergency package submission to OMB
Obtain OMB approval
Survey data collection
Findings on NEMT and survey report due to CMS
NEMT waiver expires
HIP 2.0 demonstration ends

We request OMB’s support in approving the HIP 2.0 Federal Customer Satisfaction Survey
Instrument Testing request under the Emergency PRA procedures to allow us to meet the CMS
deadline for the renewal of the NEMT waiver for the State of Indiana.
If you have any questions, please contact: Teresa DeCaro, Deputy Director, CMCS State
Demonstration Group, at 202-384-6309, or [email protected].

INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only
and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized
disclosure may result in prosecution to the full extent of the law.