P&P August 2015

processes and practices, how staff are trained and deployed, to realizing cost savings by eliminating redundancies across our enterprises. This chance to innovate how our programs are operated is now an opportunity few states can afford to let pass by. Calculate the budget savings possible through the reduced maintenance and operating costs of new systems versus the expense of operating aging, obsolete systems. Consider how realignment of eligibility and case management staffing across programs into consolidated service centers and similar organizational models can serve to improve service delivery and accountability. Think about the opportunity to look across human service programs to find opportuni- ties for further streamline delivery of those services. HHS and OMB,

almost an afterthought. Of course, many states misinterpreted the avail- ability of the 90 percent funding given to state Medicaid agencies. Upon learning that the enhanced funding was only for Medicaid, many states ended plans to innovate citing the dif- ficulty of calculating and managing the cost allocation plan. And yet, that was exactly the reason for the A-87 exception: to aid states in calculating what still remained to be appropriately allocated to the benefitting program. In fact, before I left government service, we published an updated Cost Allocation Methodology (CAM) Toolkit 5 to help states in this area. Long story short, if a state Medicaid agency wanted to build a new case management system, it could use the 90 percent funding to acquire and build it. If other human service

certain exceptions to the requirements for cost allocation as then defined by OMB Circular A-87 (now known as the Title II, Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 3 ). These two policies, guidance that went hand-in-hand, held broad promise for human service agencies willing to set course to rein- tegrate and innovate how services are delivered. But beyond just the idea of modern- izing antiquated, obsolete eligibility and case management systems in human services, the A-87 exception and the availability of 90 percent federal financial participation in their cost brought about a chance to struc- turally alter how government interacts with and supports our nation’s most vulnerable citizens. Today we have

Todaywe have far toomany families passing through systems that impose the requirement tomakemultiple, separate applications for services. Nowenvision those same clients having the opportunity tomake a single, universal application. One that coulduniformly determine all of the services that family is entitled to receive.

though the A-87 exception and the 90 percent federal funding, have enabled state human service departments to innovate and be creative in ways we haven’t seen in more than a generation. For almost three years now states have had this chance, and yet far too many have still not figured out how to take full advantage. On January 23, 2012, HHS and the Department of Agriculture issued what was called a “Tri-Agency Letter” 4 that laid out the cost allocation exception then referred to as the A-87 exception. In that letter, 19 unique automated system components, functions, and infrastructure supports were cited as examples of capabilities states could build using the A-87 exception. These 19 capabilities were deemed by both departments and OMB to be safe harbor opportunities—in other words, states could be confident that, if requested, funding approval was

far too many families passing through systems that impose the requirement to make multiple, separate applica- tions for services. Now envision those same clients having the opportunity to make a single, universal application. One that could uniformly determine all of the services that family is entitled to receive. Whether it is cash assis- tance from the Temporary Assistance for Needy Families (TANF), child care services, food stamps from the Supplemental Nutrition Assistance Program (SNAP), or energy assistance from the Low-Income Home Energy Assistance Program (LIHEAP), the ability to consolidate the data gath- ering, eligibility determination, and ultimately, the delivery of multiple services at once in near real-time brings more than just an improved customer experience for our clients. It brings real change to how government delivers those services: from business

programs wanted to use this new case management system, they could. Not that a TANF or SNAP program could use Medicaid’s 90 percent funding to, for example, convert their data from their aging human service system to the new case management system, but, alternatively, they didn’t have to participate in the initial cost of acquisition and construction either as long as Medicaid needed it. Now program unique functionality, such as additional rules for SNAP eligibility determination, would require those SNAP-unique costs be borne by the SNAP program. But even then oppor- tunities for savings abound. The rules engine that would be used to build the SNAP-specific eligibility rules could be originally purchased by Medicaid if needed for a new Title XIX eligi- bility and enrollment (E&E) system.

See My Turn on page 39

August 2015   Policy&Practice 25