CMS-10398 - Supporting Statement for Generic Umbrella 12-27-17 Final [rev 02-23-2018 by OSORA PRA]

CMS-10398 - Supporting Statement for Generic Umbrella 12-27-17 Final [rev 02-23-2018 by OSORA PRA].docx

Generic Clearance for Medicaid and CHIP State Plan, Waiver, and Program Submissions (CMS-10398)

OMB: 0938-1148

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SUPPORTING STATEMENT

Generic Clearance for Medicaid and CHIP State Plan,

Waiver, and Program Submissions

CMS-10398, OMB 0938-1148


BACKGROUND


The Centers for Medicare & Medicaid work in partnership with States to implement Medicaid and the Children’s Health Insurance Program (CHIP). Together these programs provide health coverage to millions of Americans. Medicaid and CHIP are based in Federal statute, associated regulations and policy guidance, and the approved State plan documents that serve as a contract between CMS and States about how Medicaid and CHIP will be operated in that State. When modifications or enhancements to the program are prescribed by Congress through legislation, each State’s programs must be amended to comply. For example, in March 2010, Congress passed (and the President signed into law) the Affordable Care Act, which enacted comprehensive reform of the Medicaid program. CMS works collaboratively with States in the ongoing management of programs and policies, and CMS continues to develop implementing guidance and templates for States to use to elect new options available as a result of the Affordable Care Act or to comply with new statutory provisions. CMS also continues to work with States through other methods to further the goals of health reform, including program waivers and demonstrations, and other technical assistance initiatives.


A. JUSTIFICATION


1. Need and Legal Basis


Section 1901 of the Social Security Act (42 U.S.C. 1936) requires that States must establish a State plan for medical assistance that is approved by the Secretary to carry out the purpose of Title XIX. CHIP has a corresponding statutory requirement for a State plan outlined in Section 2101to carry out the purpose of Title XXI. 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.


The Act also provides the Secretary some discretion in waiving program requirements when it does not have a negative financial impact (cost effectiveness, cost neutrality, and budget neutrality) and promotes the objectives of the program. For instance, Section 1915(b) allows for the waiver of Medicaid provisions to allow for the implementation of managed care programs. Additionally, Section 1115 of the Act provides the Secretary flexibility to waive program requirements in Section 1902 and provide Federal funding for costs that are otherwise unmatchable. Written applications from States are required for these programs that outline what the State proposes to do and the financial impact it will have.


2. Information Users


State Medicaid and CHIP agencies are responsible for developing submissions to CMS, including State plan amendments and requests for waivers and program demonstrations. States use templates when they are available and submit the forms to CMS to review for consistency with statutory and regulatory requirements (or in the case of waivers and demonstrations whether the proposal is likely to promote the objectives of the Medicaid program). If the requirements are met, CMS approves the State’s submission 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.


The development of streamlined submission forms enhances the collaboration and partnership between States and CMS by documenting CMS policy for States to use as they are developing program changes. Streamlined forms improve efficiency of administration by creating a common and user-friendly understanding of the information needed by CMS to quickly process requests for State plan amendments, waivers, and demonstration, as well as ongoing reporting.


3. Improved Information Technology


The forms for the States to use are available in electronic format. We expect every submittal to be forwarded to CMS using the electronic format. The forms create streamlined and structured data, decreasing the time required by States to develop their submissions to CMS.


4. Duplication


There is no duplication of similar information.


5. Small Business


There is no burden on small businesses.


6. Less Frequent Collection


Under Medicaid and CHIP State plans, there is no need to resubmit information once it is approved, unless the State elects to change its program. For waiver and demonstration programs, renewals of the programs are required on cycles that vary across statutory authority from 2 – 5 years. However, within the approved waiver cycle, States are not asked to resubmit information once it is approved unless the State elects to change its program.


7. Special Circumstances


The implementation of these templates is often time sensitive and must be coordinated with the release of guidance documents such as regulations and policy letters. Additionally, some of the templates that would be approved under this collection must be available to States to implement the changes timely.


8. Federal Register Notice/Prior Consultation


The 60-day notice published in the Federal Register on February 21, 2017 (82 FR 11224). No comments were received.


9. Payment/Gift to Respondents


There is no payment or gift to respondents.


10. Confidentiality


Program submissions to CMS from States are public information, and there is no personal identifying information collected in the documents. No assurance of confidentiality is provided to respondents.


11. Sensitive Questions


There are no questions of a sensitive nature.


12. Burden Estimates


The newly proposed annual burden estimate (see Total, below) considers the currently approved collections that we seek to continue, discontinued collections that are no longer needed, projected collections that are expected to be added during the upcoming 3-year approval period, and unanticipated collections that may be added during the upcoming approval period.


In summary, our requested burden ceiling (154,104 hr) is unchanged.


Currently Approved GenICs


Currently, OMB has approved 120,398 hours of burden for the GenICs that are set out in the most recent Notice of Action (see attached NOA, dated May 23, 2017).


Discontinued GenICs


We propose to discontinue the requirements and burden (38,416 hours) associated with a number of currently approved GenICs identified in section 15 of this Supporting Statement.


Projected GenICs (as of Dec 27, 2017)


For the upcoming 3-year (2017/2018 – 2020/2021) approval period, we estimate the time involved for completing a template is 20 hours for shorter/less complex templates and 40 hours for templates that are more comprehensive/complex. Under the above scenario, each State could spend 1,080 hours to produce 38 responses including 16 complex templates requiring 40 hours and 22 shorter templates requiring 20 hours (1,080 hours = [16 templates * 40 hours] + [22 templates * 20 hours]). If all 56 respondents spent 1,080 hours over the 3-year period, the total 3-year burden would be 60,480 hours (1,080 hours * 56 States).


See section 15 of this Supporting Statement for our list of projected GenICs.


Unanticipated GenICs


We propose to add 11,642 hours of burden for unanticipated informant collection requests. This figure will align this iteration’s burden ceiling request with our currently approved ceiling, both are 154,104 total hours.


Proposed Burden


120,398 hr (Currently Approved GenICs)

-38,416 hr (Discontinued GenICs)

+60,480 hr (Projected GenICs)

+11,642 hr (Unanticipated GenICs)

154,104 TOTAL HOURS


Cost estimates are dependent on our requirements and the respondent’s BLS Occupation Title and wage. Since this information will not be known until upcoming GenICs are developed, our cost estimates will be set out when each GenIC package is submitted to OMB for approval.


13. Capital Costs


There are no capital costs associated with this information collection.


14. Costs to Federal Government


There is no cost to the Federal government.


15. Program/Burden Changes


Currently Approved GenICs


For the GenICs that we propose to keep active, we are not making any program changes.


An inventory of currently approved GenICs can be found in the most recent Notice of Action (see attached NOA, dated May 23, 2017).


Discontinued GenICs


From the inventory of currently approved GenICs (see attached NOA, dated May 23, 2017) we propose to discontinue the following as they are no longer needed:


No.

Title

Hours

3

RAC Program Phase II

1,120

4

RAC Program At A Glance

1,120

6

Medicaid Buy In

700

8

PIE Transaction

1,120

12

Primary Care Bump

2,448

14

MAGI Conversion Plan

1,120

19

Eligibility and Enrollment Performance Indicators - Started in CAHPG and moved

10,000

20

PERM

1,120

**

PERM Pilot Reporting Template Round 1 (Revised 9/14)

 

23

Medicaid Primary Care Payment Increase – State Data Collection Tool

2,080

25

Tobacco Cessation Quitline Expenditures

112

36

Same Sex Marriage Policy

56

38

Section 1115 Demonstration Long Term Services and Supports

448

39

Medicaid and CHIP Learning Collaboratives Assessment

27

40

BIPP Template

27

41

1095 B Reporting State Readiness Poll

56

42

Covered Outpatient Drug Rule (CMS-2345-F)

16,800

44

Oral Health Initiative Survey Tool

14

49

LC Consumer Eligibility

48

TOTAL

38,416


Projected GenICs


For the upcoming 3-year (2017/2018 – 2020/2021) approval period, we estimate the time involved for completing a template is 20 hours for shorter/less complex templates and 40 hours for templates that are more comprehensive/complex. Under the above scenario, each State could spend 1,080 hours to produce 38 responses including 16 complex templates requiring 40 hours and 22 shorter templates requiring 20 hours (1,080 hours = [16 templates * 40 hours] + [22 templates * 20 hours]). If all 56 respondents spent 1,080 hours over the 3-year period, the total 3-year burden would be 60,480 hours (1,080 hours * 56 States).


Title

Target Rollout Date

Projected Time Per Response (hr)

Projected Time (hr)

ACA Sec 2001: Benchmark

TBD

40

2,240

ACA Sec 2003: Premium Assistance for ESI

TBD

20

1,120

ACA Sec 2202: Presumptive Eligibility by Hospitals

TBD

20

1,120

ACA Sec 2301: Coverage of Freestanding Birth Centers

TBD

20

1,120

ACA Sec 2302: Concurrent Hospice Care

TBD

20

1,120

ACA Sec 2303: Coverage of Family Planning Services

TBD

20

1,120

ACA Sec 2404: Spousal Impoverishment

TBD

20

1,120

ACA Sec 4106: Preventive Services for Adults

TBD

20

1,120

ACA Section 1312: Residency

TBD

40

2,240

ACA Section 1331: Basic Health Plan

TBD

40

2,240

ACA Section 1411: Appeals Process

TBD

40

2,240

ACA Section 1413 /2201 HUB verification sources

TBD

20

1,120

ACA Section 1413: Alternative Streamlined Application Template (CMS)

TBD

20

1,120

ACA Section 1413: Verifications (Financial and non Financial)

TBD

20

1,120

ACA Section 2002: Coordination with Exchange ( Medicaid and CHIP)

TBD

20

1,120

ACA Section 2004: Former Foster Care

TBD

20

1,120

ACA Section 2303: Family Planning - Eligibility

TBD

40

2,240

Designation of Single State Agency

TBD

20

1,120

Election of Tax Credit Disregards

TBD

40

2,240

EQRO Protocols

TBD

20

1,120

Implementation of Asset Verification System

TBD

40

2,240

Implementation of MEQC data for PERM data

TBD

40

2,240

Implementation of Premium Assistance in Medicaid

TBD

40

2,240

Implementation of the Alignment of LIS and MSP Asset Tests

TBD

40

2,240

Implementation of the Public Assistance Reporting Information System (PARIS)

TBD

40

2,240

Medicaid and CHIP Statistical Enrollment Data System (SEDS)

TBD

40

2,240

Medicaid Eligibility Cards for Homeless Individuals

TBD

40

2,240

Medical Child Support Cooperation

TBD

40

2,240

Option to Cover Certain Children and Pregnant Women lawfully residing in the US

TBD

40

2,240

Performance Measures

TBD

40

2,240

Secretarial Certification of health plans in the Exchange

TBD

20

1,120

Secretarial Issue Streamlined Application (CCIIO-CMS)

TBD

20

1,120

Systematic Alien Verification for Entitlements

TBD

20

1,120

Tobacco cessation coverage

TBD

20

1,120

Transitional MA for Low Income Families

TBD

20

1,120

Tribal Consultation

TBD

20

1,120

Tuberculosis coverage

TBD

20

1,120

Medicaid Premiums

TBD

20

1,120

TOTAL

60,480


Unanticipated GenICs


We propose to add 11,642 hours of burden for unanticipated informant collection requests. This figure will align this iteration’s burden ceiling request with our currently approved ceiling, both are 154,104 total hours.


Proposed Burden


120,398 hr (Currently Approved GenICs)

-38,416 hr (Discontinued GenICs)

+60,480 hr (Projected GenICs)

+11,642 hr (Unanticipated GenICs)

154,104 TOTAL HOURS


16. Publication and Tabulation Dates


There are no plans to publish the information for statistical use.


17. Expiration Date


CMS is asking for an exemption from displaying the expiration date on our generic instruments. The exemption would reduce work on replacing the expiration date every 3 years with the renewal of the Generic Umbrella package. We currently have 52 approved Gen-ICs. Most of these may have multiple templates associated with them.


Moreover, in certain cases displaying the expiration date causes unnecessary burden and confusion, especially in instances where the expiration date is near the approval date. In one real example, a GenIC bundle was approved on October 29, 2014, while the expiration date is a few days later, on October 31, 2014. It would be confusing to respondents to forward templates on Oct 29th with an expiration date of Oct 31st of the same year. It would also be burdensome to produce and revise the expiration dates in such a short period of time.


18. Certification Statement


There are no exceptions.


B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS


The use of statistical methods does not apply for purposes of this collection.


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