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Sustaining DMI: Medicaid Advanced Planning Document Process

Sustaining DMI: Medicaid Advanced Planning Document Process How state Medicaid agencies can request enhanced federal funding for Medicaid Enterprise Systems and related activities. Why is the Advanced Planning Document process important? Based on information from the Government Accountability Office (GAO), the Centers for Medicare & Medicaid Services (CMS), and the Federal Register, the Advanced Planning Document (APD) process is a procedure through which states develop a plan of action for their Medicaid information technology (Medicaid IT) projects. These plans are for designing, implementing, or operating Medicaid Enterprise Systems (MES) projects. State Medicaid agencies (SMAs) submit completed APDs to CMS—specifically a designated state officer in the Center for Medicaid and Children’s Health Insurance Program (CHIP) Services (CMCS) Data and Systems Group (DSG)—to request federal financial participation for their activities. The state officer reviews APDs to assess whether states’ requests for federal financial participation for designing, developing, implementing, or maintaining MES activities contribute to the economic and efficient operation of Medicaid and meet specific technical and operational criteria defined in statute, regulation, or sub-regulatory guidance. A state that receives federal financial participation can see increased access to stable federal funding to support MES activities. In addition, APDs are used to monitor a state’s project performance and outcomes. What are the three types of APDs? There are three types of APDs: Planning, Implementation, and Operational (Table 1). Table - Resource - Sustaining DMI: Medicaid Advanced Planning Document Process What are the major steps for states in the APD process? To request enhanced federal funding for MES, SMAs must complete the APD template that aligns with where they are in the development of their project (for example, design or maintenance) and submit it to the designated CMCS DSG state officer. The APD process contains five major steps and can take many months to complete: Meet with key state contacts and decision-makers. Based on information from the Public Health Informatics Institute’s information and tip sheets, before developing the APD, the SMA should identify and engage key state contacts and decision makers to solicit their input about the proposed project and secure their and their staff’s collaboration to complete and submit the APD to the CMCS DSG state officer. The state health agency (SHA) should work closely with the SMA during this process to ensure that they provide needed support to the SMA. For example, the SHA may gather information for the SMA to include in the APD or advise on how to complete particular sections of the APD. During this process, the SMA and SHA should consult with their respective agency leadership to discuss the type of technological solutions Public Health maintains, Public Health’s relationship with the state Medicaid program, and the opportunity to align systems to reduce overall state costs and improve state efficiency through the APD process. The SMA and SHA should also engage the MES lead, who can offer critical information about current MES components and component certification needed to complete the APD. In addition, GAO recommends states involve their chief information official in overseeing Medicaid IT projects because they can play a critical role in decision making related to IT budgets, management, and oversight. Next, the SMA and SHA should engage the CMCS DSG state officer to develop a strong understanding of how the APD can support the Medicaid program and serve a public health interest. Coordinating with the state project management office can help integrate the diverse parties and processes needed to develop and submit the APD for approval. It can also help ensure that states develop a comprehensive and flexible timeline for the APD process, stay aware of approaching deadlines, and meet ad hoc requirements. Develop the appropriate APD. Next, based on 45 C.F.R. § 95.610(c), the SMA and SHA should identify which of the three types of APDs to submit to the CMCS DSG state officer. Planning APDs are recommended for large and complex projects, such as statewide projects. However, if a state can identify a clear and easy pathway to integrate a public health information technology system with a current MES procurement or development phase, it can forgo developing a Planning APD and directly develop or update an existing Implementation APD. For example, if a state is looking to integrate its counties’ public health data into its MES at once, it should develop a Planning APD as the project is large and affects all counties in the state. However, if a state already has most of its counties’ public health data in its MES but is looking to add a single county’s data to its MES using the same process it previously and successfully used to add the other counties’ data, it may not need to submit a Planning APD. If a state has already successfully integrated its counties’ public health data into its MES and is looking to make major technology upgrades and improvements, it should submit an Operational APD. Regardless of the type of APD the state submits, the SMA and SHA should work together to ensure the request meets the Conditions for Enhanced Funding (see separate document Conditions for Enhanced Funding: The Basics). Submit the APD for approval and be available for revisions. Based on information from CMS, GAO, and the Office of Child Support and Enforcement, the state should then submit the APD to the designated CMCS DSG state officer. The SMA and SHA should plan to receive questions and revision requests from the CMCS DSG state officer and ensure that the state has staff capacity to answer questions and revise and resubmit. Approval conditions can be found at 45 C.F.R. § 307.15, but approval criteria might vary by Medicaid IT project and other factors. If approved, implement the plan. Next, the state can carry out the plan described in its Planning and Implementation APDs. After the Medicaid IT project has been operating for at least six months, states can request system certification from CMS. According to CMS, certification is required to receive the enhanced 75 percent federal financial participation for operations. The certification process includes states submitting to CMS an intake form, a certification request letter, and supplemental materials with information on its system. CMS may then start its review to assess whether the state’s system meets certification requirements. If approved, monitor and report progress and submit other APDs as needed. Based on 45 C.F.R. § 95.610(c) and 45 C.F.R. § Part 95 Subpart F and information from CMS, CMCS, Office of Child Support and Enforcement, as the state continues with its Medicaid IT project, it should adhere to monitoring and reporting requirements for enhanced federal funding. It also should submit annual APDs as required. If the state wants to make any major changes to the Medicaid IT project in concept, scope, cost allocation approach, timeline, and other key areas, it must develop and submit an as-needed APD. An as-needed APD is due no later than 60 days after the occurrence of the change. State examples: Medicaid Enterprise System projects Based on information from Alvarez & Marsel, state MES projects will vary based on factors such as the maturity of a state’s technology infrastructure, its specific data needs, and its available resources. As such, projects to design, implement, or operate MES can range in size, complexity, and timeline. For example, the Alabama MES Modernization Program, the Wyoming Integrated Next Generation System Project, and the Florida Health Care Connections project all seek to transform their singular Medicaid Management Information Systems (MMIS) into modular, multi-vendor MES, but differ in approach. In addition, Arizonia and Hawaii are collaborating to modernize their shared MES. For more information on state MES projects, see the Medicaid Enterprise System Solution/Module Contract Status Report. This webpage lists states’ MMIS and Eligibility and Enrollment contract information for their MES projects. It also lists contact information for state officers to reach out to learn more about states’ MES projects. website yes

2026 State Legislative Session Update

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2026 State Legislative Session Update 2026 State Legislative Session Update Learn about state legislation from FY26 focused on hot public health topics in this Health Policy Update. ASTHO’s 2026 Legislative Prospectus Series announced the top five public health state policy issues to watch this year. With at least 30 states scheduled to conclude their legislative sessions by the end of May, state legislatures focused on many of these public health topics. Expanding Access to Care As expected, a number of states considered legislation to expand access to care, including policies that promote community-based services and rural health care access. Doula birthing support services continue to be a topic for state legislatures with at least a dozen states considering legislation to expand coverage or access. Oregon enacted SB 1568, expanding coverage for birth and postpartum doulas and lactation counselors. Virginia enacted two bills that support access to doulas: HB 328 requires the Bureau of Insurance to select a new essential health benefits benchmark plan that includes doula care coverage starting in 2029, while HB 838 expands Medicaid coverage to include incentive payments for doulas to provide linkage to care visits in the postpartum period. For other licensed health care professionals, interstate compacts allow health care professionals licensed in one member state to practice in another without additional credentials. This year, legislatures have considered more than 100 health care professional compact bills so far, with at least six states enacting legislation: Arizona (HB 2190), North Dakota (HB 1622), and South Dakota (HB 1146) adopted the Physician Assistant Licensure Compact. New Mexico adopted the Interstate Medical Licensure Compact (SB 1) and the Social Work Licensure Compact (HB 50). Mississippi (SB 2543) adopted the Dentist and Dental Hygienist Compact. Washington (HB 2088) adopted the Dietitian Licensure Compact. Finally, at least two states enacted legislation to expand telehealth. Virginia HB 1284 specifies that its Medicaid provider-to-provider consultation provision includes services provided via telehealth, and Kentucky HB 424 eases the requirements for social worker telehealth practice. Behavioral Health Legislatures are also continuing to explore policies that address mental health and substance misuse. This includes legislation that supports people across the care continuum, explores the use of psychoactive substances in mental health treatment, and regulates emerging substances. At least seven states have enacted legislation to establish or enhance the continuity of care for people in a behavioral health crisis. This includes Maine LD 1216, which requires the Department of Health and Human Services to establish crisis intervention support services in all counties. Virginia enacted HB 453, which specifically allows amendments to the state’s Marcus Alert plan supporting the state’s comprehensive crisis system and requires state agencies and local partners to align their policies accordingly. States also continue to promote the availability of opioid reversal drugs through legislative action. Virginia SB 257/HB795 requires certain health insurance plans to include at least one opioid antagonist with limited cost-sharing on their drug formularies. Kansas HB 2534 requires schools to stock naloxone and establish polices to support its administration, and Utah SB 87 clarified its immunity provisions for administering opioid antagonists and will allow expired — but still effective — opioid antagonists to be dispensed and administered in certain situations. Another trend this legislative session is the legalization and regulation of use, medical study, and reclassification of certain psychedelic drugs for therapeutic purposes. Several states considered legislation to allow psilocybin for therapeutic purposes, including Oregon HB 4040, which already allows psilocybin service centers and expanded its licensing criteria for psilocybin service facilitators. At least 23 states considered, and five states (Mississippi SB 2056, South Dakota HB 1099, Utah SB 83, Virginia SB 379, and West Virginia SB 906) enacted legislation that would automatically reschedule psilocybin or certain formulations, pending federal approval and/or rescheduling. Finally, at least 10 states considered bills to support access or research into ibogaine, which is being studied in relation to PTSD and substance use disorder. States include Washington (SB 5204), Oregon (HB 4110), Tennessee (SB 2149/HB 2075), Louisiana (SB 43), Oklahoma (HB 3834), and Georgia (HB 1296), with Mississippi enacting HB 314 to allow the state health department to participate in a consortium supporting clinical trials for ibogaine drug development. A number of states are also taking action to address kratom, a plant-based substance with the potential for serious side effects, including substance use disorder and withdrawal symptoms. As of January 2026, 31 jurisdictions regulate kratom, with at least five states enacting legislation this year. New York (A 9472/S 8814), Virginia (HB 360), and West Virginia (SB 985) established or enhanced prohibitions on selling kratom to people under 21, while Nebraska (LB 901) enacted an excise tax on kratom products. Utah enacted two bills (HB 385 and SB 45) that regulate processors and retailers and New York mandated warning labels on certain kratom products (A 9443/S 8780). Healthy Food and Chronic Disease States continue to prioritize chronic disease by advancing policies recognizing the importance of prevention and how food impacts health. In 2026, a number of states considered legislation to address food insecurity, improve school nutrition, and promote chronic disease screening and prevention. At least 10 states considered legislation to limit ultra-processed foods or promote access to healthy foods, with Nebraska LB 940 prohibiting public schools from offering foods that contain certain color additives and Tennessee SB 2423/HB 1853 taking a similar approach but for any artificial food dye. States are also exploring ways to accommodate student dietary preferences. Minnesota (SF 2970), New Jersey (S 1676), New York (A 1834), and Washington (S 5878) introduced legislation that would mandate plant-based options in school cafeterias. Illinois enacted HB 1607, creating a health department task force to review state efforts to eliminate food deserts and requiring a report with recommendations by January 2028. Finally, state legislatures are taking action to support access to early detection and chronic disease management through insurance regulation. Mississippi enacted HB 565 to require Medicaid and other health plans to cover biomarker testing for the diagnosis, treatment, management, or monitoring of patients when supported by medical evidence. Additionally, Oregon enacted SB 1527, which limits out of pocket costs for medically necessary cervical cancer screenings and follow-up examinations. Finally, Alabama (SB 19) will prohibit certain insurance plans from imposing cost-sharing for prostate cancer screening of all men over 50 and younger men at high risk. Infectious Disease Prevention With recent changes to the membership and recommendations of the Advisory Committee on Immunization Practices (ACIP), a number of state legislatures have considered changes to vaccine policy in 2026. Several states enacted legislation to modify the role of ACIP, including Colorado (SB 26-032), Connecticut (HB 5044), Maine (LD 2146), Maryland (HB 637), New Mexico (HB 156), Oregon (SB 1598), Vermont (H 545), and Washington (HB 2242). Many of these bills address other components of vaccine policy, including: Vaccine Schedule Recommendations: Colorado, Connecticut, Maryland, New Mexico, Vermont, and Washington substitute or add state health agencies and/or organizations like the American Academy of Pediatrics, American College of Obstetricians and Gynecologists, American Academy of Family Physicians, and American College of Physicians as sources for vaccine recommendations. Insurance Coverage: Connecticut, Maryland, New Mexico, Oregon, Vermont, and Washington require health insurance plans to cover vaccines recommended by health agencies or other organizations, rather than ACIP alone. Pharmacist Scope of Practice: Maryland and Vermont substitute or remove ACIP recommendations as an authority for pharmacists to administer vaccines, and Colorado allows pharmacists to prescribe vaccines independently. Funding: Colorado, Maine, and Vermont expand vaccine purchasing programs to include vaccines recommended by bodies other than ACIP. Liability Protections: Colorado, Maine, and Vermont include liability protections for certain providers administering vaccines according to state or medical organization recommendations. Public Health Funding Legislatures in thirty-one states, the District of Columbia, and three U.S. territories will enact budgets for the 2027 fiscal year, while legislatures in three more states will enact biennial budgets for the 2027 and 2028 fiscal years. With reductions in federal funding, states continue to find ways to leverage state funds to invest in public health and public health infrastructure while adhering to balanced budget requirements. Eleven states have enacted FY 2027 budgets and three states enacted biennial budgets for FY 2027-FY 2028, with several states increasing public health funding, including Kansas (HB 2513), New Mexico (HB 2), and Wyoming (SF 0001). Additionally, three states passed FY 2027 supplemental budgets featuring public health provisions: Maine LD 2212 appropriates funding to support access to affordable prescription drugs in rural and underserved areas, Washington SB 6003 increases funding for the state’s Drinking Water State Revolving Fund, and Nebraska LB 1071 shifts funds to children’s health insurance, community-based aging services, and mental health operations. States have also