Annual ERR Memo

05/16/2016

Oversight Group

Effective Rate Review Data Collection Survey

Background

The Rate Review Division is charged with determining whether states comply with the provisions of 45 CFR §154.301(d) and should be considered to be an “Effective Rate Review” state. Over the years this has been done in a variety of ways through both written and verbal communication. Initially, a survey was developed to determine compliance. That survey was put through the PRA process in conjunction with the Rate Review Grants and was approved for use in September 2014. The use of the survey was suspended for 2016 and in its place phone conversations took place between Rate Review Division staff and each state. While this did build relationships between CMS staff and the various states, it only provided verbal assurances of compliance.  It was determined that in order to provide a sufficient audit trail for both the state and CMS the formal written survey should again be employed.

Discussion

The survey has been revised and shortened to focus on the true requirements of an Effective Rate Review program and reduce the workload of those states who must complete the survey each year.

 

The purpose of the survey is four-fold, to determine a state’s compliance with the Effective Rate Review rules, analyze the results to either renew a state’s effective status or institute a remediation plan, to provide an audit trail within CMS that we are looking into this on a regular basis, and to gain insight into areas where additional guidance may be needed.

CMS will make a summary of the survey findings public.

Next Steps

Once reviewed by OGC, the survey will undergo the full PRA process. The goal is to have the final survey ready for use by the states by October of 2016 with responses due back in November of 2016. Those responses will then be analyzed by the Rate Review Division and if there are any states that do not meet the requirements of an Effective Rate Review Program, we will work jointly with the states on an action plan to meet the requirements within a reasonable timeframe.

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