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EEOC Issues Proposed Rule to Amend Title II of GINA

January 29, 2016

The Centers for Medicare & Medicaid Services (CMS), the Administration for Community Living (ACL)  and the Veterans Health Administration (VHA) released a No Wrong Door System Reference Document for Medicaid Administrative Claiming Guidance document in early December to assist states in their effort to provide consumers with more coordinated long-term services and supports (LTSS). The document is designed to help states that are establishing No Wrong Door Systems across systems to access Medicaid funding for some of their work.

No Wrong Door (NWD) Systems are state-created programs that coordinate services across multiple agencies that serve older adults and people with disabilities, including employment services, so that people experience a streamlined user-friendly eligibility process regardless of where they enter the service system. The guide informs states about how they can appropriately claim federal matching funds, including Federal Financial Participation (FFP), for administrative work related to their NWD programs and services.

The guide clearly explains how matching funds can be claimed for certain activities, noting that states can only claim funds for NWD activities that match with a corresponding Medicaid administrative   activity for which the state incurs a cost. For instance, the state cannot claim funds for the activities of unpaid volunteers in the state’s NWD program working on outreach to people with disabilities or elders because there is no cost to the state or No Wrong Door System and therefore nothing to claim. Similarly, outreach activities conducted by NWD staff that are not directly related to the Medicaid program or that are made available free of charge to the general public would not be eligible for Medicaid funding or match. However, administrative match can be available for “Program Planning, Interagency Coordination and Continuous Quality Improvement” even if not directly Medicaid-related. In the Guidance, NWD  System personnel are provided with a code to use “when completing activities related to establishing  and maintaining documentation, internal processes, quality oversight and policies related to the provision of LTSS, health care services, and other supports that may assist an individual to remain in the community, return to the community, or otherwise enhance the person’s quality of life (e.g., income supports, energy assistance, etc.). They also use these codes when working with other partner agencies to improve the coordination and delivery of services, and performing collaborative activities with other agencies to provide services. Examples include: (1) Analyzing Veterans Health Administration data   related to the NWD System; (2) Participating in an advisory group for the Department of Labor to provide consultation and advice regarding the delivery of employment programs for people utilizing the NWD System; (3) Working directly with other agencies, such as the State Department of Education to improve the coordination of Vocational Rehabilitation Services and the NWD System.

Download the No Wrong Door System Reference Document for Medicaid Administrative Claiming Guidance document.