Don't miss out on an opportunity to improve benefits determination and delivery in your state.


The Affordable Care Act (ACA) requires development or modification of state Medicaid eligibility systems. Recent guidance from the Administration for Children and Families (ACF), Centers for Medicare & Medicaid Services (CMS), and Food and Nutrition Services (FNS) has increased the stakes for state health and human service agencies, offering states an unprecedented opportunity to make the most of health care reform. This "tri-agency guidance" announced a specific exception to Office of Management and Budget (OMB) A-87 (2 CFR Part 225) and the new Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR Part 200). and encourages horizontal linkages between health and human services.

Opportunity for States

Specifically, the A-87 exception waives the requirement for cost allocation to other health and human service programs for costs that would have otherwise been incurred for development of a state's Health Benefit Exchange, Medicaid, and Children's Health Insurance Program (CHIP) systems – even if other health and human service programs will later build on the foundation of those systems.


For states, this means more potential federal dollars: For a limited time, CMS will pay 90 cents of every dollar for Medicaid changes, even if the changes benefit other human services programs like Temporary Assistance for Needy Families (TANF), the Child Care Development Fund (CCDF), and the Supplemental Nutrition Assistance Program (SNAP).


It also means administrative planning and administrative challenges:

  • States will need to identify and report which systems development costs will be leveraged by both health and human services, and which costs are exclusive to health or human services.
  • Incremental costs for additional requirements needed for the inclusion of other programs, either at initial or later stages, must be charged entirely to those programs.
  • If a rule is required only for non-Medicaid purposes, Medicaid will not pay for the cost.

With 25 years of experience helping state and municipal governments to design and implement streamlined business processes, allocate and claim federal funds, and integrate health and human service eligibility requirements, Public Consulting Group (PCG) can help your organization successfully navigate the Affordable Care Act's (ACA's) challenges and opportunities.

PCG brings expertise from the fields of health, human services, and technology. Our integrated eligibility services include

Cost Allocation and Reporting

Comprehensive cost allocation plans (CAPs) set the foundation for successful claiming and revenue recovery. PCG can help you maximize ACA funds and assess structural and fiscal issues that might impede your agency's ability to maximize this revenue. We can also help to ensure your agency's practices are compliant with all federal and state regulations.

Eligibility Systems Planning, Design, and Procurement

States will invest millions of dollars to implement health care reform and new eligibility systems that span health and human services programs. PCG can help your agency maximize the return on investment with thoughtful strategizing for both the technical requirements, procurement, and testing of these new systems.


With our structured planning processes, emphasis on data-driven decision-making, and commitment to demonstrable results, PCG will help your agency meet its demands and measure your expectations, progress, and success.

Policy Analysis and Expertise

To successfully use the A-87 exception announced in the tri-agency guidance, states will need complete and up-to-date knowledge of federal policies associated with both health and human service programs. PCG provides policy expertise and research skills that can help you meet federal requirements as they continue to evolve. We can help you pinpoint the similarities and differences of eligibility requirements among programs, and create a more holistic approach to eligibility determination.

Process Assessment and Redesign

The development of integrated eligibility systems across health and human services programs will bring with it demands for new business procedures, administrative policies, and deliberate coordination. PCG can provide guidance to help agencies put in place and sustain cross-agency collaboration and effective governance structure. We can also provide assistance with increasing efficiencies, improving customer service, and uniform training of front-line workers and management to promote smooth operations through transition and beyond.


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For more information about PCG Health's Eligibility Services for Health Care Reform please contact us at or 1-800-210-6113.