- CMS released guidance Tuesday outlining how states should apply for modular certification of Medicaid Management Information Systems (MMIS).
- The aim is to increase Medicaid programs’ ability to update and change their systems as well as allow earlier access to enhanced rates for implementing IT systems.
- Under a December 2015 final rule, states are eligible for a temporary increase in the federal financial participation rate to support the design, development, installation and maintenance, and operations of Medicaid Eligibility and Enrollment systems.
Previously, an MMIS could only be certified after the entire system was implemented and had been used for a designated period. But CMS says that approach often resulted to projects that were overly large, expensive, lengthy and high-risk.
“With smaller, more incremental projects, risk and costs should be reduced for all aspects of the project,” Medicaid Director Vikki Wachino says in a letter to state Medicaid directors. “Modular MMIS certification will allow the states to access the 75 percent enhanced FFP for M&O of the certified module(s) prior to having completed their total MMIS system replacement, improving the state’s cash flow.”
While states can now seek certification as old modules are replaced or new ones added, CMS may also require certification when the changes are deemed to be high risk, Wachino says.
Project risk will also a determining factor in whether to grant enhanced FFP for a project, she adds.
Reviews of modular enhancements will focus on three issues: how module’s functions with the overall MMIS; how it interfaces with other MMIS modules; and how effectively and efficiently it fulfills its goal within the MMIS. States must also verify that they’ve completed regression testing with the new module and that it won’t negatively affect other parts of the system.
Modular certification reviews won’t be considered until six months after the new module went live. To help states prepare, CMS has created a set of checklists based on requirements in its Medicaid Enterprise Certification Toolkit.
To further facilitate adoption of new technologies, CMS is offering a precertification program that allows vendors of Medicaid IT modular solutions to submit their products for agency review before they have been implemented in any state.