Generic Supporting Statement

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Generic Collection of Information
MAGI-Based Eligibility Verification Plan
CMS-10398 #11, OMB 0938-1148

    A. Background

The Centers for Medicare & Medicaid Services (CMS) 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. CMS works collaboratively with States in the ongoing management of programs and policies.

Existing regulatory authority in 42 CFR 435.945(j) requires States to develop and update as modified and submit to CMS upon request a verification plan documenting their eligibility verification policies and procedures to implement the provisions in §435.940 through 960 to verify factors of eligibility for enrollment in Medicaid and CHIP.

In association with our June 3, 2026 (91 FR 33348) interim final rule with comment period (CMS-2454-IFC; RIN 0938-AV98) entitled, “Medicaid Program; Community Engagement Requirement for Certain Individuals,” section 71119(a) of the Working Families Tax Cut (WFTC) legislation (P.L. 119-21) added section 1902(xx) of the Act to establish a community engagement requirement for certain adults applying for or enrolled in Medicaid, effective January 1, 2027. For these certain adults, States are required to verify that an applicant or beneficiary demonstrates community engagement or is deemed to demonstrate community engagement due to meeting the criteria for a mandatory exception or an optional short-term hardship exception, or that an individual is a “specified excluded individual” to whom the community engagement requirements do not apply consistent with § 435.557.  

Additionally, section 1902(xx)(5) of the Act requires States to conduct ex parte verification of community engagement requirements, directing States to verify compliance or deemed compliance with or exclusion from, the community engagement requirement using reliable information available to the State without requiring additional information from an applicant or a beneficiary if able to do so.  

For purposes of verification requirements under Section 1902(xx)(5) of the Act, States must use reliable information available to the State reliable information which includes, but is not limited to, information from electronic data sources (as documented in the State’s verification plan) ; information from other State or local agencies to the extent that such information is needed to verify an individual’s eligibility; information from Federal agencies provided through the Federal Data Services Hub; information in the State’s eligibility system; information in the individual’s case record; payroll data; and claims, payment and or encounter data from the preceding 12 months for verifications related to community engagement. When there is no reliable information available to the State, or the reliable information available to the State is not reasonably compatible with the information provided by or on behalf of the individual, the State must seek additional information from the individual to verify the individual’s compliance or deemed compliance with the community engagement requirement or status as a specified excluded individual.

    B. Description of Information Collection

Regulations at §435.945(j) and §457.380(j) require states to develop, and update as modified, a verification plan describing the verification policies and procedures adopted by the agency in accordance with §435.940-435.965 and §457.380. States must use the template specified by CMS and submit their verification plans to CMS that describe their verification policies and procedures for individuals whose eligibility is based on Modified Adjusted Gross Income (MAGI). States may use one template for both Medicaid and separate CHIP programs if the verification policies and procedures are the same. If they are different, the State should submit two separate verification plans. 

To account for the new community engagement factor of eligibility, CMS is providing states a Verification Plan Supplement for states to reflect their verification policies and procedures related to community engagement. States will use the supplement to record their verification policies and processes, including the electronic data sources they will use to verify community engagement and when they will require additional information and documentation from individuals in accordance with §435.557. The supplement will allow states to only select and submit changes to verification policies and procedures related to community engagement to CMS without the need to make updates to underlying MAGI verification plan template or disaster addendum.

    C. Deviations from Generic Request

No deviations are requested.

    D. Burden Hour Deduction

Wage Data

To derive average costs, we used data from the U.S. Bureau of Labor Statistics’ May 2025 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 BLS’ mean hourly wage, our estimated cost of fringe benefits and other indirect costs (calculated at 100 percent of salary), and our adjusted hourly wage.

Table 1: National Occupational Employment and Wage Estimates
Occupation Title
Occupation Code
Mean Hourly Wage ($/hr)
Fringe Benefits and Other Indirect Costs ($/hr)
Adjusted Hourly Wage ($/hr)
Business Operations Specialist
13-1000
44.63
44.63
89.26
General and Operations Managers
11-1021
64.87
64.87
129.74
Health Services Manager
11-9111
67.77
67.77
135.54
Operations Research Analyst
15-2031
47.95
47.95
95.90

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.

Collection of Information Requirements and Associated Burden Estimates

Verification Plan Supplement (New)

With regard to our June 3, 2026, interim final rule with comment period, we estimate that each of the 43 States and the District of Columbia will have a one-time burden of 124 hours for each state to develop and fill out the verification plan supplement. We assume an Operations Research Analyst and a Business Operations Specialist will each perform approximately 50% of the effort for this task.  Of the 124 hours, we estimate it will take 60 hours at $89.26/hr for a Business Operations Specialists to prepare the verification plan supplement and 60 hours at $95.90/hr for an Operations Research Analyst to prepare and review these data. We also estimate it will take 4 hours at $129.74/hr for a General and Operations Manager to review the data and submit the verification plan supplement.  

Verification Plan (Approved)

This is on top of the existing approved burden for states to submit the required verification plan and disaster addendum. Currently, OMB has approved 2,240 hours (56 respondents x 40 hours/response) for states to submit their verification plans. We estimated that it would take a Business Operations Specialist 40 hours to complete one response for a cost of $3,570 (40 hours x $89.26/hr) per response. There is a potential universe of 56 respondents. In aggregate, we estimate 2,240 hours (56 responses x 40 hours) at a cost of $199,942 (2,240 hrs x $89.26/hr). Accounting for the Federal administrative match of 50 percent, the requirement will cost States $99,971 ($199,942 x 0.50).

Disaster Addendum (Approved)

We also already estimated it would take a Business Operations Specialist 30 minutes at $89.26/hr, and we estimated it would take a Health Services Manager 15 minutes at $135.54/hr to update and submit their disaster addendum to CMS. For the aggregate existing burden of submitting the disaster addendum, we estimated a one-time burden of 38 hours (50 states plus the District of Columbia x 0.75 hr/response) at a cost of $4,005 (51 states x [(0.5 hr x $89.26/hr) + (0.25/state x $135.54/hr)]). Accounting for the Federal administrative match of 50 percent, the requirement will cost States $2,003 ($4,005 x 0.50).

One-Time Burden Summary

In aggregate for both approved burden and new burden in this update, we estimate a one-time burden of 5,456 hours (44 States x 124 hr/state) at a cost of $511,657 (44 x [(60 x $89.26/hr) + (60 x $95.90/hr) + (4 x $129.74/hr)]) plus 38 hours (50 states plus the District of Columbia x 0.75 hr/response) at a cost of $4,005 (51 states x [(0.5 hr x $89.26/hr) + (0.25/state x $135.54/hr)]) for an aggregate one-time total of 5,494 hours and $515,662. Accounting for the Federal administrative match of 50 percent, the requirement will cost States $257,831 ($515,662 x 0.50). 

Annual Burden Summary

Additionally, we assume recurring, annual burden associated with updates after the initial verification plan submission. Annually, we estimate five (5) jurisdictions will require 5 hours at $95.90/hr for an Operations Research Analyst, 5 hours at $89.26/hr for a Business Operations Specialist to update their verification plan, and 1 hour at $129.74/hr for General and Operations Managers to review the data and submit the verification plan. 

In aggregate, we estimate an annual burden of 55 hours (5 States x 11 hr/response) at a cost of $5,278 (5 states x [(5 hr x $89.26/hr) + (5 hr x $95.90/hr) + (1 hr x $129.74/hr)]). Accounting for the Federal administrative match of 50 percent, the requirement will cost States $2,606. 

Total Burden Summary

Requirement
No. Respondents
Total Responses
Frequency
Time per Response (hr)
Total Time (hr)
Wage ($/hr)
Total Cost ($)
Federal Match ($)
State Share ($)
Submit verification plan to CMS (active)
56
56
One-time
40
2,240
89.26
199,942
99,971
99,971
Update and submit disaster addendum to CMS (active)
51 (50 States + DC)
51
One-time
0.75 (45min)
38
Varies
4,005
2,003
2,003
Verification Plan Supplement (new)
44 States
44
One-time
124
5,456
Varies
511,657 
255,829
255,829
Updates (new)
5 States
5
Annual
11
55
Varies
5,278
2,639
2,639
TOTAL
56
156
varies
varies
7,798
varies
520,940
260,470
260,470

Although this collection of information request proposes 7,798 hours of burden, this iteration requests the addition of 5,520 hours (7,798 hr [revised] - 2,278 hr [active]) to avoid double counting or recounting our active estimate of 38 hours.

Collection of Information Instruments

MAGI-Based Eligibility Verification Plan Template (no change)

Disaster Relief MAGI-Based Verification Plan Addendum (no change)

MAGI Verification Plan Supplement: Community Engagement Guidance and Template (new)

    E. Timeline

The changes in this 2026 collection of information request are associated with our Interim Final Rule with Comment Period (CMS-2454-IFC; RIN 0938-AV98) entitled, “Medicaid Program; Community Engagement Requirement for Certain Individuals.” The rule filed for public inspection on June 1, 2026, and published on June 3, 2026 (91 FR 33348). Comments must be received by July 31, 2026.