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Overcoming Schedule and Procurement Challenges for ACA

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Overcoming Schedule and Procurement Challenges for ACA

Overcoming Schedule and Procurement Challenges for ACA


Contents
Introduction .................................................................................................................................................. 3 Schedule and Phasing Considerations .......................................................................................................... 3 Key Requirements for the Affordable Care Act ........................................................................................ 3 Options for ACA Compliance and Integrated Eligibility Replacement ...................................................... 4 APSP Rapid Implementation Phasing Schedule ........................................................................................ 6 Contracting Options to Speed Procurement for Consideration ................................................................... 7 Inter-State Compact .................................................................................................................................. 7 Justified Sole Source ................................................................................................................................. 8 APD and Grant Guidance .............................................................................................................................. 8 Functional Considerations ........................................................................................................................ 8 Technical Considerations .......................................................................................................................... 9 Additional Details for APSP ........................................................................................................................... 9 Seven Conditions........................................................................................ Error! Bookmark not defined. Time and Cost Savings............................................................................................................................. 11 APSP Interfaces ....................................................................................................................................... 17

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Overcoming Schedule and Procurement Challenges for ACA

Introduction
The Patient Protection and Affordable Care Act of 2010, as amended by the Health Care and Education Reconciliation Act of 2010, referred to collectively as the Affordable Care Act (ACA), seeks to decrease the number of Americans unable to find affordable health care coverage by expanding Medicaid, creating new health insurance markets, and enabling self-service capabilities to support both. The federal government is fully funding system development for health care reform requirements through a series of grants, and matching 90% of development costs for new Integrated Eligibility systems put in place to support those requirements. States are encouraged to work together and share resources, documentation, and even technical capabilities in order to streamline the planning and implementation efforts they have undertaken. This will allow states to share the work required and decrease their federal funding needs, resulting in a more cost effective implementation and improved capabilities across state lines.

Schedule and Phasing Considerations


In spite of this unprecedented level of federal support, many states have not been able to put plans in motion that will meet federally mandated deadlines for implementation of Health Care Reform. The purpose of this White Paper is to identify and define IT design, development, and deployment services that can be procured by states seeking a fast and cost-effective solution to meeting the requirements of ACA while also taking advantage of this unprecedented funding opportunity for a new integrated eligibility system. This can include states in a range of positions: States that have not taken action on Health Care Reform States working on a new Integrated Eligibility system, but not yet building an Eligibility & Enrollment (E&E) Portal or Health Benefits Exchange(HBE) Marketplace (presumes new Medicaid Eligibility rules are being built into the new IE system) States working on ACA requirements (an E&E Portal and HBE Marketplace) but not yet building a new Integrated Eligibility system States that are behind schedule in their work on either ACA requirements or their new Integrated Eligibility system.

Key Requirements for 90/10 Funding


The following capabilities are required to implement health care reform: Develop an Eligibility & Enrollment Portal to serve both Medicaid and commercial insurance customers via a web browser Develop a Health Benefits Exchange, or insurance marketplace, in which commercial customers can compare plans and enroll Develop a Call Center required to support the E&E Portal, HBE, and (potentially) other health care and human services programs Fully enable new Medicaid Eligibility rules (also built into the portal) through either: o Modification of legacy eligibility systems to enable real-time determinations, or
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Overcoming Schedule and Procurement Challenges for ACA

Development of a new integrated eligibility system, like Accenture Benefits Management System (ABMS) (with 90/10 funding support) Deploy new infrastructure, a print center, data storage, and other technical architecture capabilities required to operate the above systems.

The Federal government has already created a backup plan for states that will not meet deadlines for basic compliance with Health Care Reform. The Federal Exchange, established and managed by the Centers for Medicare and Medicaid Services (CMS), will make basic portal and marketplace capabilities available to non-complaint states. States participating in the federal exchange will not have to build these capabilities themselves, but they will give up some measure of control over Medicaid eligibility and their insurance marketplace. This document is focused on states that want to do more than comply with ACA by taking advantage of 90/10 funding for a new integrated eligibility system as well.

Options for ACA Compliance and Integrated Eligibility Replacement


The traditional approach to procuring the IT services required to design, build, test, and deploy the services mandated by Health Care Reform would require multiple solicitations, each with their own procurement cycle. ACA provides a unique opportunity to change that, because so many states must implement the same set of requirements (with minor variations state-to-state that can be enabled through configurable software). As a result, each of the required activities listed above has a number of implementation options. The table that follows identifies options available to states, organized by the time leading up to the first critical ACA deadline: open enrollment in October of 2013. In order to meet that deadline, states must deploy required capabilities in September of 2013 at the latest. 12 months before September 2013 (September 2012): states can procure software, complete configuration activities, and integrate existing systems 9 months before September 2013 (December 2012): if certain entry criteria are already in place, states can: implement an out-of-the-box HBE marketplace like Accenture Health Benefits Exchange, including, interface to Federal Hub, underlying SOA architecture, like Accenture Public Service Platform (APSP), enterprise service bus, Rules Engine, Workplan, etc 6 months before September 2013 (March 2013): implement the E&E portal, like Accentures Self Service Portal (ASSP) only

In some cases, more than one option exists for a given capability if there is enough lead-time before October 2013. For example, with a project start date of nine months prior to the deadline, states can temporarily interface with their legacy eligibility system or leverage a cloud solution from another state, but they wont have time to deploy a new integrated eligibility system. In this case, deployment of the new system would come after October 2013 and the temporary interfaces would be retired. Finally, for illustrative purposes, the next section references reference the Accenture Public Service Platform (APSP) suite of products and a rapid implementation schedule as one example of an integrated eligibility solution. Briefly, APSP includes:

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Overcoming Schedule and Procurement Challenges for ACA

APSP Technical Architecture, which is a Service Oriented Architecture that supports the day-today functions performed by users in the APSP solution. Using this enterprise, architecture the Department can integrate legacy applications, COTS software, and new customized software while allowing the selective exchange of data across the enterprise through an enterprise service bus (ESB). Accenture Citizen Self-Service Portal (ACSSP), which is a secure, public-facing portal that uses a conversational, interview approach to collect data needed to assess the citizen's eligibility for benefits. The ACSSP application is a reliable, personalized application that engages customers, keeps infrastructure costs down, delivers solutions rapidly, and aligns with the APSP standardized application architecture. Accenture Benefits Management System (ABMS), which is an integrated, flexible, clientfocused solution designed for a range of public and social welfare programs such as Medicaid, CHIP, SNAP, and TANF. The functionality provided is the integration of eligibility determination and delivery of services and benefits, built on a well defined and successfully adopted business model. ABMS is a workflow-driven benefits management application and uses a COTS rules engine, such as Oracle Policy Automation (OPA), which can be easily updated by experienced business users.

All of the timeframes listed in the following table lead to the state procuring a new integrated eligibility system while meeting the mandates of Health Care Reform. Depending on when a state starts the process, their new system may be deployed in time for or shortly after the October 2013 deadline. In all cases, the goal is for states to take advantage of funding while remaining compliant with the ACA statute.

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Overcoming Schedule and Procurement Challenges for ACA

Accenture Public Service Platform (APSP) Rapid Implementation Phasing Schedule


ACA Required Capability Eligibility & Enrollment Portal Exchange Marketplace New MAGI Rules Customer Support (Call Center) 12 Months October 2012 AHBX* Portal and Marketplace (GetInsured) Interface to Federal Hub Includes Local Interfaces Includes APSP, Bus, Rules Engine, Workplan, etc Includes option for setting up a Print Center (for Premium Billing) Plan Mgmt can be SERFF or GetInsured NEW CALL CENTER Transfer/licensed C-IV component EXISTING CALL CENTER Interfaces can be built as part of an AHBX implementation, to existing Call Center 9 Months January 2013 Entry Criteria: State must already have a print center AHBX Out-of-the-box Interface to Federal Hub Includes APSP, Bus, Rules Engine, Workplan, etc Plan Mgmt must be GetInsured NEW CALL CENTER Transfer/licensed C-IV component EXISTING CALL CENTER Interfaces can be built as part of an AHBX implementation, to existing Call Center LEGACY SYSTEM Temporary interfaces built as part of an AHBX implementation, passing data through the legacy eligibility system to get to the MMIS SOFTWARE AS A SERVICE (Cloud) Leverage an existing state solution 6 Months April 2013 Entry Criteria: State must have a print center and have identified all plans with 6 months left AHBX Out-of-the-box Interface to Federal Hub Includes APSP, Bus, Rules Engine, Workplan, etc Plan Mgmt must be GetInsured Integration with existing Call Centers only

Integrated Eligibility

REPLACEMENT SYSTEM Vanilla ABMS** for core Medicaid (no waiver) No State Programs Interface to MMIS Limited Conversion (flow basis) Mandatory Reporting only LEGACY SYSTEM Temporary interfaces can be built as part of an AHBX implementation, passing data through the legacy eligibility system to get to the MMIS SOFTWARE AS A SERVICE (Cloud) Leverage an existing state solution *Accenture Health Benefits Exchange **Accenture Benefits Management System

LEGACY SYSTEM Interfaces can be built as part of an AHBX implementation, passing data through the legacy eligibility system to get to the MMIS

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Overcoming Schedule and Procurement Challenges for ACA

Contracting Options to Speed Procurement for Consideration


As states consider the options available for implementing the requirements of Health Care Reform and deploying a new Integrated Eligibility system, they should also consider the procurement and funding steps to be followed. CMS and APD partner agencies use the information in the grant applications and Advance Planning Document (APD) to confirm that states are taking appropriate steps to build a MITA-compliant system that will address ACA needs and be deployed in time for enrollment in October 2013. The guidelines that follow will serve as Dos and Donts that help states choose a procurement approach and develop grants and APDs that will increase the confidence of the federal agencies, making fast approval more likely. State procurement processes are one of the biggest threats to achieving the schedule requirements for Health Care Reform, as identified by CMS and CCIIO. This section describes three approaches states can take to streamline their procurement processes, and considerations for each: Inter-state Compact Justified Sole Source Leverage GSA Schedule.

Inter-State Compact
This refers to a State-to-State procurement of a SaaS (Software as a Service) or hosted instance of a combined Health Care Reform and Integrated Eligibility solution.

Description
Procuring State buys solution as a service or a separate hosted solution instance directly from offering state. A compact exists and allows this type of procurement Limited procuring state specific rules and configurations are purchased with solution

Considerations
Should be high degree of alignment with between procuring state requirements and offering state solution Requires offering state to be far enough along in implementation process to ensure on-time implementation Governance process must be established Considerations regarding training, change management and other cutover activities may be procured separately as these services are delivered within the offering state and may not be available to the procuring state

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Overcoming Schedule and Procurement Challenges for ACA

Justified Sole Source


A state procures directly from a vendor, following approved justification by federal partners.

Description
Procuring state adopts substantially similar APD, Contract, Solution Description and Requirements, and ConOps to another state that has already completed the procurement process (model State) Requires similar justification to Software selection process Procuring State enters into contract with vendor as sole source to deliver solution

Considerations
Differences in procuring state and model state approach should be limited to implementation timeline and phasing along with minor state specific requirement additions (example: state-only medical programs, funded with GR) Considerations regarding training, change management and other cutover activities may be procured separately as these services vary greatly across states

APD and Grant Guidance


The following sections identify and describe functional and technical considerations that states should incorporate into their grant applications and APD documentation. These themes can streamline the review process by CMS and other federal partners by highlighting the characteristics most important to those reviewers.

Functional Considerations
The following functional considerations are intended to emphasize willingness to do what it takes to deploy an ACA-ready solution in time for enrollment in October 2013. Every state is different, but the fundamental requirements for health care reform and base components of a modern integrated eligibility system are common across jurisdictions. By following the guidelines below, each state can create a compelling case for the funding required to implement ACA. Flexibility the description of the proposed solution should reflect a willingness to adapt local processes to an existing solution Re-use the solution should make use of existing components, including legacy systems (where applicable and feasible) and code modules from other states
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Overcoming Schedule and Procurement Challenges for ACA

Release Sequencing in all cases, the first release of a multi-release program should focus on Health Care Reform. The federal partner agencies have emphasized the importance of not allowing other functionality to put ACA compliance at risk.

Technical Considerations
A solution with the following technical qualifications could speed up procurement, approval and implementation. Proven eligibility determination business functionality o Self-Service Capability o Real-time benefits processing o Business Rules o Benefit Calculation o Data Collection o Pre-built federal reporting Demonstrated adherence to MITA Standards o MITA Self Assessment Completed on Products or Transfer Alignment with Seven Conditions and Standards o Mapping of Product or transfer Conservative conversion approach of active cases only (no history) Enterprise architecture o Pre-built web services o Pre-built workflows, o Security Services o Pre-built interfaces

Example: Seven conditions built in to Accenture Public Service Platform


The following diagram illustrates how the Accenture Public Service Platform (APSP) addresses the seven conditions required by the APD process.

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Overcoming Schedule and Procurement Challenges for ACA

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Overcoming Schedule and Procurement Challenges for ACA

Example: Time and Cost Saved Using APSP


The following table articulates the savings that can be achieved by leveraging APSP for ACA and Integrated Eligibility.

Component
Business Rules Engine (BRE) with Complete Rule Set pre-built for TANF SNAP Medicaid, CHIP, MAGI

Benefit
Accenture is a pioneer is rules development using Business Rules Engines (BREs), and APSP brings a complete set of eligibility rules. Our experience in other states shows that the use of a well developed set of rules that are isolated in a BRE is the single greatest contributor to time and cost savings in eligibility system implementations Accenture is a leader in the development of Business Process Management (BPM). We currently have built 9 workflows and have an additional 5 workflows in our Roadmap prior to the beginning of the project. These workflows, like Report a Change and Automatic Application, automate and make configurable end-to-end processes bridging applications and functions. For example, in Automatic Application, the BPM provides the capability to modify the criteria for application assignment and the conditions when an application is eligible for automatic processing.

Time Savings
MAGI Rules 100% Re-use SNAP Rules 85-90% Re-use TANF Rules 80 % Re-use CHIP Rules 80-90% Re-use Other Medicaid Rules 70 % Re-use Approximately 85% reduction in time associated with all rules development including rules integration Major processes and navigation are configurable, resulting in approximately 60% reduction in the development of processes such as the following: Automatic Application, Case Maintenance, Case Review Quality Assurance, Cost Avoidance and Recovery, Determine Eligibility, Hearings and Appeals, Overpayments/Underpayments, Registration, Report a Change, Recertification, Case Worker Assignment, Presumptive Eligibility, Screening, and Affordable Care Act screening There is approximately 70% reuse of existing prebuilt interfaces, which are configurable and would need to be tested in the state environment. (see list of 21 interfaces at end of table)

Cost Savings
Approximate 85% reduction over custom built rules Additional 40% cost savings associated with isolation of rules in BRE and access to the rules via rules mapping service instead of hard coded Approximate 60% cost saving over custom, tightly coupled processing.

14 Pre-Built Workflows in the Business Process Modeling (BPM) tool

Pre-Built Federal Interfaces 21 total interfaces

The Accenture Benefits Management System comes with pre-built interfaces that can be largely reused. These interfaces are also integrated with review processing. In addition, the roadmap of the APSP product suite is to review and adjust the interfaces to accommodate the changes related to the development of the Federal Data Hub as part of the Affordable Care Act.

The project cost savings is 70% for these interfaces. The associated cost is for configuring and adjusting the interfaces for the states environment and testing with converted data and integration testing.

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Overcoming Schedule and Procurement Challenges for ACA

Component
460 pre-built user interface pages using portal technology

Benefit
The Accenture Benefits Management System comes with configurable user interface pages that cover all major functions of benefits management. These pages are configurable in several respects: Many of them are made up of composite portlets, meaning that those pages can be combined and configured for specific roles. The labels on the pages are stored in XML format in items that are called resource groups. Those groups can be modified in a text tool without altering the page. The pages use a codes table utility that allows you to rapidly change the content of the drop down boxes. The pages use flexible workflow and a stateless logic that allows for changes in navigation and workflow The objects on the pages are mapped to the rules in the rules engine through a rules mapping service instead of hard coded.

Time Savings
The projected time savings due to the flexibility of the pre-built user interfaces is 40% over a typical, tightly coupled custom transfer system and 75% typical time savings from building a system from scratch. Pages exist in these following major areas: Application Registration, Case Maintenance/ Case Management, Worker Assignment and Reassignment, Central Index , Scheduling, Data Collection, Verifications, Eligibility Determination & Benefit Calculation (EDBC), SelfSufficiency Planning, Customer Activities and Progress Tracking, Skills Assessment and Job Matching, Needs Assessment, Supportive Services and Payment Requests, Child Care, Tracking and Application of Sanctions and Penalties, Benefit Issuance, Fiscal History and Claiming, Collections, Medicaid Recovery Third Party Liability and Other Health Coverage, Tracking of Time Limited Benefits, Quality Control, Interfaces, Administration).

Cost Savings
The projected cost savings is 40% percent over a transfer system and 75% from a custom build, because many of the changes to the pages can be accomplished through configurations (such as changing labels, drop down, navigation, look and feel)

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Overcoming Schedule and Procurement Challenges for ACA

Component
Self-service portal

Benefit
The Accenture Citizen Self-Service Portal is developed to maximize configurability and to provide functions for client submission of applications, changes, documentation, and survey responses. There are several key features that provide for the configurability of the self service portal: Full use of portal technology that provides for configurable home page and changes to look and feel. Primary and secondary questions for screening and application submission are configurable within tables instead of hard coded in pages. This dynamic question feature allows the business analyst to upload the root and follow-up questions to a table rather than have developers code the changes in the pages. A flexible survey mechanism that provides for the configuration of survey questions. Screening rules are configurable in the rules engine and called through a service rather than hard coded. BPM workflows, such as the automated application workflow. Data Transfer Service that is configurable to map outbound question response from the self service portal to the corresponding fields in the benefit system for automated processing.

Time Savings
The projected time savings is 60% over a custom transfer system because screening and application questions and subsequent transfer to the base transfer system is configurable.

Cost Savings
The projected cost saving is 40% over a custom transfer system and 80% over a system built custom due to the features of the self service portal and its initial pre-tested configuration of questions.

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Overcoming Schedule and Procurement Challenges for ACA

Component
Pre built web services

Benefit
The solution contains both pre-built technical and business services to speed development and integration. The technical service categories are explained below. Business services include data transfer and data consuming services that provide for the automated transmission of data from the self service portal to the benefits management system and configurable spring service managers in the key functional areas: Application Registration, Case Maintenance/ Case Management, Worker Assignment and Reassignment, Central Index , Scheduling, Data Collection, Verifications, Eligibility Determination & Benefit Calculation (EDBC), Self-Sufficiency Planning, Customer Activities and Progress Tracking, Skills Assessment and Job Matching, Needs Assessment, Supportive Services and Payment Requests, Child Care, Tracking and Application of Sanctions and Penalties, Benefit Issuance, Fiscal History and Claiming, Collections, Medicaid Recovery Third Party Liability and Other Health Coverage, Tracking of Time Limited Benefits, Quality Control, Interfaces, Administration)

Time Savings
The estimated time savings over a custom transfer system is typically 40% for business services because the business services and the corresponding interfaces can be configured. The estimate over building a custom system is 80% because major functionality and back end services exist through data services and back end service managers.

Cost Savings
The cost savings estimate is 40% for business service and 80% for technical services.

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Overcoming Schedule and Procurement Challenges for ACA

Component
Real time case processing

Benefit
The APSP product suite comes with an automatic application and report a change workflow that provides for various states of automated, real time case processing up to and including complete automation for select programs, such as those covered under the Affordable Care Act. The benefit of this real time case processing is two-fold: Case changes and a subset of case applications that meet specified conditions can be processed in real time, reducing case worker time The processes have points of configurability to provide for balance as to degree of automation and real time processing. The APSP Security Service Layer uses commercial Identity and Access Management suites to provide a centralized security infrastructure. The primary reusable component in the APSP Security Service Layer architecture is the security context. This Security Layer encapsulates authentication, authorization, entitlements, and identity management data from the commercial products in the security context. The security context is available throughout the SOA.

Time Savings
The pre-built workflows and interfaces between the components of the product suite reduce the time to implement real time case processing by an approximate 50% over a custom application with similar features due to workflow, data transfer services and configurable processes.

Cost Savings
The cost savings is estimated to be 40% 60% based on the level of automation.

APSP Security Service Layers

75% reduction in implementation of policy administration points and policy determination points for portal-based applications such as ABMS and ACSSP. Immediate availability of user authorization credential information for web service protection.

75% reduction in cost associated with implementation of security services throughout the SOA. Additional 75% cost savings for each additional application that consume the security services.

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Overcoming Schedule and Procurement Challenges for ACA

Component
APSP Forms and Correspondence Service Layers

Benefit
The Forms Management Service provides the capability for forms to be rendered and presented in APSP portlet or web views. System triggered events make use of the exposed services and API's in supported products to produce and render forms. The Correspondence Architecture Framework provides for the ability to jointly handle singular, highly customized correspondence and highvolume, dynamic content correspondence. The correspondence architecture uses the Forms Service Layer to merge a layout with data to produce correspondence, then routes that correspondence to a printer, content management software, or browser/PDF. The Reporting Service Interface initiates and presents reports. The Reporting Service Layer can route reports to content management software or browser/PDF.

Time Savings
Configurable standard layouts come with the application to include a Notice of Action layout that provides for a configurable notice of action transmission to clients based on the findings of the rules 50% reduction in creating dynamic, rules-driven forms and correspondence using the APSP Snippet architecture. 50% reduction in creation of new forms due to pre-defined layouts and snippet architecture. Allows forms developers to focus on content, not layout.

Cost Savings
50% reduction in cost for forms development. Additional savings for additional forms that re-use centralized, standard snippets (disclaimers, terms and conditions, headers, footers, etc.)

APSP Reporting Service Layer

30 Reusable federal reports included in solution with templates for other reports. 80% reduction in development of interfaces for reporting products. 80% reduction in development of interfaces for Enterprise Content Management (ECM) products. 80% reduction in development of interfaces for Address Normalization products. Additional time savings due to preconfigured Address Normalization methods. 80% reduction in development of interfaces for Proximity Search products.

80% savings in development costs for creating reporting engine interfaces.

APSP Content Management Service Layer APSP Address Normalization Service Layer

APSP Proximity Mapping Service Layer

The Content Management Service Layer enables a standard interface to provide document management and content management capabilities in APSP. The Address Normalization Service normalizes an address to USPS (United States Postal Service) Standards. The Address Service can normalize a single address or list addresses. In addition, the Address Service can retrieve a City/State information given a zip code. The Proximity Search Service returns route data between two locations. The Proximity Search Service will either display the route on a map, or can pass the route data to any geo-spatialcapable system.

80% savings in interface development costs for ECM interfaces. 80% savings in development of interfaces for Address Normalization products. Additional savings due to preconfigured Address Normalization methods. 80% savings in interface development costs for Proximity Search products.

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Overcoming Schedule and Procurement Challenges for ACA

APSP Interfaces
The interfaces that currently exist or are on the roadmap for the APSP Product suite include: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. Beneficiary Earnings Data Exch (BENDEX) Inbound Daily (SSA) SSI State Data Exchange (SDX) Inbound Daily State Verification Exchange (SVES) Inbound State Verification Exchange (SVES)(SSA) Outbound Public Assistance Rptg Info Sys (PARIS) Federal Wage Info Public Assistance Rptg Info Sys (PARIS) Interstate Recipient Match Public Assistance Rptg Info Sys (PARIS) Vet Benefit Info Public Assistance Rptg Info Sys (PARIS) (DMDC) Outbound MMIS Medicare Part A Inbound MMIS Medicare Part B Inbound MMIS Medicare Part C and D Inbound LTC File Medical Eligibility Information MMIS Medicare Part A Outbound (?) MMIS Medicare Part B Outbound (?) Third Party Liability (TPL) LIS Determinations (MIPPA) Medicare Entitlement & Enrollment Info (MEIN) Qualifying Work Quarters (Inbound) Qualifying Work Quarters (SSA) SSA Online Query (SOLQ/WTPY)

Conclusion
As this white paper illustrates, there is still time to meet the aggressive timeline imposed by ACA to be operational by October 2013. States need to determine a model that fits their strategy and take steps to move forward.

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