Chapter 7 - CMS Certification Milestone 5: Pre-Certification Meeting

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Primary Guidelines Medicaid Enterprise Certification Roadmap, Chapter 3, Third Protocol
Primary Methodology State- or Vendor-specific Methodology
Input MECT Checklists, (linked to solution proof points and certification artifacts)
Primary Activities Familiarizing state and CMS teams with the Medicaid solution via ReadyCert, preparing state and CMS teams for pre-certification meeting and onsite visit
Output Final MECT Checklists, (linked to solution proof points and certification artifacts, updated if applicable with information to aid state and CMS teams)
Downstream Activities Supported CMS Certification Visit

Introduction

The Medicaid Enterprise Certification Roadmap calls for a pre-certification meeting with CMS before the actual certification visit is conducted. The purpose of this meeting is to allow time for CMS to assemble a team and familiarize the team with the Medicaid solution that is to be evaluated for certification. It also provides an opportunity for the state to prepare its staff to perform the pre-certification meeting and certification visit.

Figure 6-1: States must achieve 6 CMS certification milestones to receive federal funds for their IT investments

CMS advises states that after about two months of operation of the new or replacement Medicaid solution, the state may request the pre-certification meeting. CMS requests four months to assemble its team and prepare them for the certification activities. CMS requires six months of data from which to conduct the actual certification visit. Therefore, by the time CMS is ready to have the pre-certification meeting, six months of data is generally available.[1]

The Medicaid Enterprise Certification Toolkit, Chapter Three, Third Protocol, provides the guidelines states follow for the pre-certification meeting.[2] ReadyCert’s design aligns directly with this protocol, eliminating the need to repeat like-work activities. Completed MECT Checklists have been finalized as part of Milestone 4, Validated Medicaid Solution Functionality. These carry forward to Milestone 5 and require no additional work activity. The proof points have been linked to SRC, and all state and CMS required fields have been filled in. ReadyCert provides state and CMS staff with a single place to view SRC and proof points and certification artifacts. In addition, the state and CMS can link any SRC or MITA Business Objectives back to the SS-A and To-Be assessments, providing a positive audit trail from the deployed solution to the MITA Maturity Roadmap.

This section of ReadyCert 6CM follows the steps in the Third Protocol of Chapter Three of the Medicaid Enterprise Certification Toolkit. The approach for using ReadyCert in each of these steps is described. The overall project management methodology is used to direct the total work effort and, as such, the approach for completing general management and administrative activities is not covered here.

Request Certification (First Protocol, Step 1)

The Medicaid Enterprise Certification Toolkit, Chapter Three, Third Protocol, provides the specific information that is required to go into the certification request letter. CMS requires that a copy of the completed checklists be submitted with the certification request. At the start of this milestone, completed MECT Checklists are already in ReadyCert, available for submission to CMS.

Work with the CMS RO to inform them about ReadyCert. Show the benefit of accessing the checklists via ReadyCert, rather than on paper or an office automation application, such as Excel.

Include access to ReadyCert in the formal certification request to fulfill the requirement to submit completed MECT Checklists.

The state team should be in preparation mode and have an active schedule for practice sessions for state presenters, guided by the overall project management methodology. In the pre-certification meeting, the state presents an overview of the new or replacement Medicaid solution and more detailed information about its features and functions. The state team explains how the new or replacement solution supports higher levels of maturity in the State Medicaid Enterprise.

ReadyCert is used extensively by the state team to facilitate knowledge transfer. By having everything in one place, easily visible and integrated with related SRC and business processes, the time to learn the solution and prepare for the pre-certification meeting is greatly reduced. Even so, preparation should commence no later than the time the state formally requests certification.

Form Certification Review Team (Third Protocol, Step 2)

CMS forms a certification review team, called the CR Team, from the CO and RO. There are no activities in this step that involve ReadyCert.

Respond to Request for Certification and Specify Data Needs (Third Protocol, Step 3)

CMS formally acknowledges the state’s request for certification and presents comprehensive information about the certification process. The Medicaid Enterprise Certification Toolkit, Chapter Three, Third Protocol, provides a list of the information CMS presents to the state in this step. CMS also specifies what it needs from the state to familiarize the CR team with the solution and commence the actual certification activities.

Much of what CMS requires is evidence that the Medicaid solution:

  • Fills gaps between the As-Is and To-Be states, as described in the Gap Analysis;
  • Enhances the State Medicaid Enterprise's maturity, as described in the MITA Maturity Roadmap;
  • Achieves the state’s goals and objectives for the procurement, as described in the APD;
  • Functions as intended, as described in the APD and RFP.

The SS-A sets the whole process in motion. The BA, IA, TA and Seven Conditions are used to perform the SS-A. As such, new or replacement Medicaid solution decisions are taken based on the MITA framework. When the state goes forward with plans, and requests FFP, CMS evaluates, among other things, its compliance with the MITA framework. The idea is that if the SS-A is performed per the MITA framework, the resulting plans naturally align with the framework. Taking this to the deployed solution, the logic prevails. If the deployed solution aligns with the work products that described and justified it, then it, too, is complaint with the MITA framework. Therefore, the consistency of MECT Checklists, from their original generation at the conclusion of the SS-A to the completion of those checklists when certification commences, is key to achieving CMS certification at the earliest possible opportunity. Consistency and compliance lead to favorable certification findings.

Establish Checklists for the Onsite Visit (Third Protocol, Step 4)

This step overlaps with Step 1. The checklists referenced in this step are the same checklists referenced in Step 1. In Step 4, the CR Team actually reviews the checklists.

Perform Initial Review of Material (Third Protocol, Step 5)

This step overlaps with Step 5. The CR Team reviews all the material it requests, of which checklists are a component. The checklists have been reviewed in Step 5 and may be reviewed again in Step 6.

Brief Certification Review Team (Third Protocol, Step 6)

The CMS RO briefs the CR Team about the state’s request for FFP and the functional areas it intended to address by deploying a new or replacement Medicaid solution. This briefing is intended to provide the CR Team with comprehensive background information. While the RO may use the MECT Checklists to facilitate parts of this briefing, there is no specific work activity related to ReadyCert in this step.

Conduct Pre-Certification Meeting (Third Protocol, Step 7)

The state prepares the agenda and engages all the necessary resources, guided by the overall project management methodology. The state team uses ReadyCert as the primary tool to describe the features and functions of the solution.

To enhance the certification experience, the state team may demonstrate the linkage of the SRC to business processes and the To-Be assessments from the SS-A. The integration of the SRC to the To-Be assessments provides overwhelming evidence that the solution is aligned with the MITA framework.

The state may give each member of the CR Team access to ReadyCert or use a single copy that the CR team views during the pre-certification meeting.

Complete Preparations (Third Protocol, Step 8)

The CR Team and state finalize the pre-certification meeting and provide status updates after the meeting. This step is intended to close any open items that may have been identified during the pre-certification meeting. At the end of the status meeting, which is conducted about two weeks after the pre-certification meeting, the CR Team and state are ready for Milestone 6, the Certification Visit.

Notes

  1. In recent years, CMS has allowed alternate certification scenarios for some solutions in some states. States are advised to work closely with the CMS RO to explore alternate certification scenarios if they are to the state’s advantage.
  2. http://www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/MMIS/Downloads/mectchapter3.pdf