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January 27, 2018

What PASRR-related activities can states claim at the enhanced 75% match?

According to §1903(a)(2)(C) of the Social Security Act and 42 CFR 433.15(b)(9), activities that can be clearly tied to the administration of PASRR, and in accordance with an approved cost allocation plan, may be claimed at the enhanced 75% match. Examples include, but are not limited to:

• Time, including salary and fringe, of staff who administer PASRR at the three key state agencies: the State Medicaid Agency (SMA), State Mental Health Authority (SMHA), and the State Intellectual Disability Authority (SIDA);
• Time of the individual assessors who conduct the Level I screen or Level II PASRR evaluation. This applies to both state employees as well as assessors who are contracted by the state (i.e., vendors). States receive the enhanced match regardless of the outcome of the Level I screen or the Level II evaluation. States can claim the enhanced match based on share of staff time or the number of evaluations administered;
• Time to develop Request for Proposals (RFP) for a vendor;
• Time developing policy or program materials;
• Any information technology for PASRR administration, whether developed by the state or a vendor. For example, a web-based portal for tracking Level I screens and Level II evaluations could be claimed at the 75% match rate;
• Office overhead;
• Supplies and equipment;
• Management, including management of appeal activity;
• Development and delivery of training and professional education;
• Printing forms, copying, mailing notifications;
• Mileage and other travel;
• Professional consultations;
• Translation services;
• Stakeholder and interagency meetings;
• Quality assurance activities; and
• Any other costs necessary to carry out the PASRR program.

OMB Circular A-87 establishes principles and standards for determining costs for Federal awards carried out through grants, cost reimbursement contracts, and other agreements with State and local governments. The principles therein are for determining allowable costs only. According to the Circular, “The principles are for the purpose of cost determination and are not intended to identify the circumstances or dictate the extent of Federal or governmental unit participation in the financing of a particular program or project.”

As such, any doubts as to whether a specific PASRR-related activity can be claimed at the enhanced 75% match rate should be clarified with staff at the CMS Regional Office who are familiar with the PASRR program, the claiming processes, and the cost allocation plan. Note that these will generally be different staff with different types of expertise.

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