The Centers for Medicare & Medicaid Services (CMS) is moving forward with significant updates to its core data collection systems, specifically targeting how states report Medicaid and Children's Health Insurance Program (CHIP) data. This initiative, announced in a recent Federal Register notice, primarily addresses mandates from the Working Families Tax Cut (WFTC) legislation, which altered federal financial participation rules for certain non-citizen populations in these critical health programs. The agency is soliciting public comment on these proposed revisions, as well as on a separate initiative to gather qualitative feedback on agency service delivery.
Legislative Mandate: The Working Families Tax Cut Act
At the heart of the T-MSIS revisions is Section 71109 of the Working Families Tax Cut (WFTC) legislation, Public Law 119-21. This statute, effective October 1, 2026, significantly amends sections 1903(v) and 2107(e)(1) of the Social Security Act. It restricts Federal Financial Participation (FFP) for medical assistance under Medicaid and child or pregnancy-related health assistance under CHIP to specific categories of individuals. These FFP-eligible noncitizens include U.S. citizens and U.S. nationals, Lawful Permanent Residents (LPRs), Cuban/Haitian entrants, and Compact of Free Association (COFA) migrants. The legislative change represents a notable shift in federal policy regarding healthcare access and funding for non-citizen populations, requiring states to adjust their eligibility determination processes and reporting mechanisms accordingly.
T-MSIS Revisions for Immigration Status and Oversight
To comply with the WFTC legislation, CMS is proposing crucial updates to the Transformed-Medicaid Statistical Information System (T-MSIS). T-MSIS is the primary national repository for Medicaid and CHIP data, providing essential information on enrollees, beneficiaries, expenditures, and utilization. The accuracy of this data is vital for federal, state, and local officials, as well as researchers, to monitor program trends, conduct analyses, and estimate cost savings for legislative initiatives.
The proposed changes directly impact how states report immigration status. Specifically, the IMMIGRATION-STATUS data element will be updated with new valid values. These additions are designed to accurately reflect the revised state eligibility determination processes stemming from the WFTC Act. The goal is to ensure proper compliance with the new FFP restrictions, facilitate program oversight, and support accurate FFP claiming by states.
Furthermore, to enhance oversight of these immigration status changes, CMS plans to add two new valid values to the ELIGIBILITY-TERMINATION-REASON data element. These new values will allow states to specifically identify disenrollments that occur due to changes in immigration status or as a result of immigration verification processes. This granular data will be critical for CMS to monitor the implementation and impact of the WFTC provisions across states.
Tracking Home Health Services
Beyond the immigration-related updates, CMS is also proposing a change to the TRANSACTION-TYPE (FTX388) data element. A new valid value will be added, effective October 1, 2026, specifically for per-member-per-month home health service payments. While states are already expected to report these payments in their T-MSIS submissions, they often categorize them under a generic 'other' value. This new, distinct value will enable CMS to uniquely identify and track these payments, thereby supporting improved oversight of home health programs within Medicaid and CHIP.
Additionally, CMS is proposing three non-substantive changes to T-MSIS. These minor adjustments are intended to eliminate ambiguity in reporting guidelines, potentially reducing the need for technical assistance from CMS and easing the reporting burden on states.
Enhancing Agency Service Delivery
In a separate but related action, CMS is seeking to reinstate with changes a previously approved collection of information: a generic clearance for collecting qualitative feedback on agency service delivery. This initiative aims to gather customer and stakeholder feedback efficiently and continuously. The information collected through surveys and other feedback mechanisms will help CMS understand user perceptions, experiences, and expectations regarding its programs and services, particularly its public websites. The agency intends to use this feedback to identify areas for improvement in communication, training, or operational changes, ultimately enhancing the user experience and ensuring that its digital platforms effectively serve the public.
The Public Comment Period
Under the Paperwork Reduction Act of 1995 (PRA), federal agencies must provide opportunities for public comment on proposed information collections. This Federal Register notice serves as the second such opportunity, following an initial notice. Interested parties are invited to submit comments to the Office of Management and Budget (OMB) desk officer by November 6, 2026. Comments can address various aspects, including the necessity and utility of the proposed collections, the accuracy of burden estimates, ways to enhance data quality, and the use of technology to minimize reporting burdens. This public input is a crucial step in the federal regulatory process, allowing stakeholders to influence the final design and implementation of these significant data collection efforts.
