It’s a pre-election dose of the Weekly WHAT. I’ll save the political implications and prognostications for others--just don't forget to vote! Here’s what you need to know when it comes to federal policies impacting state tech.
Key Takeaway: NASCIO Responds to FirstNet RFI, Public Notice
When the FirstNet Board of Directors met on September 17, they announced the release of two documents seeking public input into how to move forward with the FirstNet public safety broadband network: a) a Request for Information (RFI) on how the authority should build the network; and, b) a Public Notice discussing the statutory interpretation of FirstNet and its mission. NASCIO responded to both documents on October 27.
According to FierceWirelessTech, FirstNet received 63 responses to the Public Notice and 122 responses to its Request for Information (RFI). The RFI responses are not public, but the public notice responses are available here. The public notice received 20 state responses, plus the District of Columbia, as well as regional and local authorities, and non-profit associations that represent public safety professionals.
In NASCIO’s response to the RFI, it recommended a number of changes. Perhaps the strongest overarching theme was a clear nexus between the vendor driven purchasing process, state consultations, and use of infrastructure. It also recommended including state and local consultation in the statement of objectives (SOO) that will guide FirstNet’s core vendor relationship decisions. In addition, NASCIO recommended flexibility for customization of the network for opt-in states, diverse pricing options for a wide variety of uses, and a strong look at procurement at all levels of government. NASCIO’s response to the RFI can be found here.
In our response to the Public Notice, NASCIO recommended FirstNet set the statutory rural milestones as part of the state consultation process, as well as the user base in each state. We partially challenged FirstNet’s definition of utilizing existing infrastructure “to the maximum extent economically desirable,” clarifying this may include the betterment of state and local taxpayers. NASCIO’s response to the public notice can be found here.
Other Buzz: Support for State Health and Human Services Systems Integration and Modernization Extended
In a significant victory for states that should lead to significant cost savings at all levels of government, the federal government announced a three-year extension of the A87 waiver authority to enable states to complete their work on integration of health and human services eligibility and enrollment systems through December 2018, along with new regulations that will codify the availability of the 90/10 federal matching funds for Medicaid eligibility and enrollment systems on a permanent basis.
This ideally allows states to build systems that ensure those applying for government benefits are viewed in a holistic manner, with their eligibility for various human services programs considered all in one system. Recently, NASCIO joined other stakeholders in writing to the key federal agencies, urging them to extend the exception, along with the 90/10 cost share. This extension gives certainty to states who did not believe they would be able to finalize systems before these efforts were slated to end on December 31, 2015. It will likely mean lower costs in the long-run for taxpayers at all levels of government through more efficient and effective programs. You can read NASCIO’s letter to the feds on this topic here.
For those interested in the background: in 2011, CMS released regulations authorizing an enhancement to the federal medicaid matching rate for eligibility and enrollment systems modernization – increasing the level of Federal support from 50 percent to 90 percent for new systems builds and from 50 percent to 75 percent for maintenance and operations. In coordination with this new regulation, the Office of Management and Budget also offered a waiver of OMB Circular A87 cost allocation rules to support the integration of eligibility systems between health and human services programs, such as the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF). This waiver allowed States that wish to build integrated systems to do so without having to allocate the costs of developing shared eligibility services to human services programs. NASCIO has advocated that states use the enhanced funding to bring Medicaid Eligibility and Enrollment Systems into compliance with the Affordable Care Act, and leverage the Exception to integrate human service agencies’ activities.
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