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The Centers for Medicare and Medicaid Services (CMS) published a final rule on April 19 confirming that 90 percent Medicaid federal financial participation (FFP) will be available for design, development, and installation or enhancement of eligibility determination systems integrated with Medicaid Management Information Systems and health insurance benefits exchanges under the Affordable Care Act (ACA).    The final rule is effective upon publication. The 90 percent FFP for eligibility determination systems will be available through December 31, 2015. The final rule also provides 75 percent FFP for on-going maintenance and operations of CMS approved eligibility systems. All enhanced FFP is subject to CMS approval of an Advance Planning Document (APD) and a Medicaid Information Technology Architecture (MITA) roadmap. The final rule mirrors a proposed rule that CMS issued on November 8 but CMS has addressed myriad questions that states astutely raised after review of the proposed rule. CMS confirms in the April 19 notice that 90 percent FFP may be available for enhancements of subsystems that are part of much larger legacy systems, but CMS says that it will make decisions taking into account possible fragmentation, performance risks and on-going costs of legacy systems. CMS also confirms that enhanced Medicaid FFP is not limited to stand alone Medicaid eligibility systems but that OMB A-87 cost allocation rules will apply to integrated systems benefiting multiple federal (CHIP, TANF, SNAP, WIC, etc.) and state programs.

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