As a practical matter, human services agencies may benefit from developing strategies that minimize the demands their proposals place on Medicaid agencies’ time and effort. The Great Recession left in its wake understaffed agencies in most states, and the demands of ACA implementation on Medicaid administrators remain considerable, even after passage of the ACA’s initial sign-up deadlines.
One approach to address this challenge would, as suggested above, use an interface with the human services program to enhance the Medicaid program’s ability to verify eligibility through data matches. This would contribute to more efficient Medicaid operations by potentially reducing the need for caseworker verification. Put differently, the development of a Medicaid-human services interface could be one of several methods through which both Medicaid and human services benefit from the cost-allocation exception, thereby encouraging the Medicaid agency to devote at least some time to this effort.
Another possible approach would have the human services agency volunteer to invest much of the effort needed to build or procure the shared service or interface, thus limiting demands placed on the Medicaid agency. As noted earlier, the Medicaid agency would need to lead the process of gaining APD approval from CMS, but much if not most of the other work might be done by the human services agency. Operationally, Medicaid and human services would both benefit from the investment; state general fund dollars would be used to “draw down” federal Medicaid dollars to finance the investment; but given the competing demands on both agencies’ time, human services staff would do much of the work outside the direct interaction with CMS.