Skip to Main Content

Read this if you are a division of motor vehicles, or interested in mDLs.

What is a mobile driver’s license?

A mobile driver’s license (mDL) is a solution that allows citizens to access, update, and use their driver’s license via a smart phone or other internet-accessible device (e.g., laptop, tablet, smart watch). An mDL is a form of electronic identification (eID), but where eIDs include other forms of licensure like hunting/fishing/gaming licenses or military IDs, mDLs are used to designate driving privileges and, in some cases, to designate age-based/identity privileges for citizens who cannot drive (e.g., buying alcohol, TSA PreCheck®).

Why should you care?

Technology has replaced physical product functionality within various areas of modern life. Many people have transitioned to electronic credit/debit card payments (e.g., Apple Pay), making paying for everyday items faster, easier, and cleaner, while also introducing risks to consumer data security. Similar functionality will soon exist within the eID space, starting with mDLs. This provides challenges for departments of motor vehicles (DMVs), businesses, and consumers; however, the benefits of adopting mDL functionality outweigh the growing pains of establishing the programs.

How does it work and when will it be implemented?

The mDL will function similarly to electronic credit cards and mobile payment applications: an mDL user loads their mDL to their mobile device using a mobile application and can use it to verify their age and driving credentials at mDL-reading establishments and with law enforcement. Relevant establishments will require both hardware and software solutions to read mDLs. 

mDLs aren’t intended to replace physical licenses—at least not yet. While state and county pilot programs resolve some of the challenges associated with mDLs, physical IDs will remain required for years to come. 

Additionally, the American Association of Motor Vehicle Administrators (AAMVA) created two groups—a Card Design Standard Committee and Electronic Identification Working Group—to develop interoperable standards to assist license issuing authorities (e.g., DMVs) in developing their mDL programs. These standards will ensure that mDLs work using different hardware, software, vendor applications, and within different jurisdictions. 

Benefits and challenges

Benefits

mDLs provide numerous benefits to citizens and DMVs alike, including information security, user convenience, and administrative convenience.

Information security

  • mDLs are harder to fake than physical driver’s licenses due to the mDL’s connection to back-end license data within the DMV system. 

  • mDLs allow users the option to communicate specific data to the receiving party without sharing all of the user’s license information (e.g., confirming the user is over age 21 without sharing their specific age or street address). 

User convenience

  • Users will be able to update their credentials fully online and see in-real-time updates.
  • mDLs will possess single sign-on verification and use for users via a biometric lock or PIN, making them quick to access and easy to use.

Administrative convenience

  • The decline in DMV wait times due to online-update functionality will save DMVs money in administrative costs.

Challenges

As with all technological advancement, there are several challenges around the development of mDLs. The primary challenge is ensuring the protection of user data while also rolling out the complex—and often costly—infrastructure needed to support mDL use across a region. 

Information security 

  • Issuing agencies can choose whether some, none, or all mDL user data is stored on the user’s device and must ensure all data stored this way is done so securely.

  • mDLs must ensure hands-free exchange of information with law enforcement to protect user data when presenting identification.
  • Technological errors are bound to occur: if an mDL-reading establishment is not able to read a citizen's mDL for any reason, a citizen will require a physical license to complete the transaction.

Program rollout

  • States and mDL vendors will need to support interoperable mDL standards to ensure that an mDL works with different vendor software and across jurisdictions.

  • Establishments and law enforcement will need the necessary mDL-reading hardware (smart phone, smart watch, tablet, laptop, point-of-sale terminal) and software (QR code readers, Bluetooth functionality, Wi-Fi Aware, Nearfield Communication, etc.) to read mDLs.
  • mDLs must be able to function in both offline and online scenarios to ensure the security of consumer data and proper functionality.

The future

mDLs are just the beginning of the opportunities eID technology will bring. Once established by DMVs, eID technology can and will be used to find and buy insurance services, check medical prescriptions, apply for social/welfare benefits, open hunting/fishing/gaming accounts and display appropriate credentials, and access pension information. 

The versatility that eID technology provides will streamline American citizens’ identification arsenal, and the advancing mDL technology puts us on the path to get there. The question is not will mDLs become widespread, but when.
 

Article
Introduction to mobile driver's licenses (mDLs): What are they and why are they important?

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification or modernization efforts.

This article is based on the Outcomes-Based Certification scalability and project outcomes podcast:


Over the last two years, the Centers for Medicare and Medicaid Services (CMS) has undertaken an effort to streamline MES certification. During this time, we have been fortunate enough to be a trusted partner in several states working to evolve the certification process. Through this collaboration with CMS and state partners, we have been in front of recent certification trends. The content we are covering is based on our experience supporting states with efforts related to CMS certification. We do not speak for CMS, nor do we have the authority to do so.

How might Outcomes-Based Certification (OBC) be applied to more complex areas of the Medicaid enterprise?

The question of scaling—that is, to apply the OBC process to more complex components while maintaining or increasing its level of efficiency—is an important next step in certification. OBC has been (or is being) scaled across the technical components of the MES in two primary ways. First, OBC has already successfully been scaled horizontally across similar but discrete components of the MES such as electronic visit verification (EVV), provider management, or pharmacy. The second, perhaps more interesting way we are seeing OBC scale is vertically. OBC—or what is now being referred to as Streamlined Modular Certification (SMC)—is now being scaled up and into larger and more complex components like financial management and claims processing. Beyond that, however, we are now seeing outcomes-based concepts scale a third way—across the Medicaid business.

How does the certification of one module impact the rest of the MES?

We are seeing CMS and states work through this question every day. What we know for sure is that each state is likely going to draw its own set of boxes around its business modules and service components based on its Medicaid business. Because modularity is only defined at a macro level, states have the freedom to work with their vendors to define the parameters of their modules. As a result, we have seen CMS work with states to define those boxes and in doing so, we are really seeing a three-layered approach.

The first layer represents the primary module a state is certifying. A primary module is that module that is responsible for all or most of a business process such as paying a claim. It is safe to assume that the most detailed evidence will come from the primary module. The second layer represents the module—or modules—that might not have responsibility for a business process, but provide functionality integral to that business process being performed successfully. Finally, the third layer represents the module—or modules—that feed data into the business process, but do little else when it comes to performing that business process. For the second and third layer, a state can likely expect to provide evidence that supports the successful transmission of data at a minimum. This is where we are seeing CMS and states work together to define that scope.

What is the role of business process improvement, organization development, and organizational change management in MES modernizations?

This is really the cornerstone of this fundamental shift in certification we have seen over the last 12-18 months. During the 2020 virtual Medicaid Enterprise Systems Conference (MESC), we saw that CMS appears to be signaling it is no longer going to readily accept modernization efforts that do not reflect tangible improvements to the Medicaid business. Think about it this way: a state will likely not be able to go to CMS to request enhanced funding simply because it can no longer renew its existing contract vehicles or it is trying to procure new technology that fails to represent a marked improvement over its legacy system. 

As a result, states need to start thinking about reprocurement and modernization projects in terms of organizational development and business process improvement and redesign. What will a state get out of the new technology that they do not get today? That’s the question that needs to be answered. States should begin to focus more on business needs and less on technical requirements. States are used to building a custom, monolithic enterprise, often referred to as a Medicaid Management Information System (MMIS). Today, vendors are bringing commercial-off-the-shelf (COTS) products that allow states to perform business processes more efficiently. In turn, states need to move away from attempting to prescribe how a system should perform and focus on what the system should do. That means less prescriptive requirements and more business-oriented thinking.

Additionally, the concept of outcomes management will become integral to a state’s Advance Planning Document (APD) requests, Request for Proposals (RFP) development, and certification. We are seeing that CMS is beginning to look for outcomes in procurement documents, which is leading states to look critically at what they want to achieve as they seek to charter new projects. One way that a state can effectively incorporate outcomes management into its project development is to identify an outcome owner responsible for achieving those outcomes.

The certification landscape is seemingly changing weekly, as states wait eagerly for CMS’ next guidance issuances. Please continue to check back for in-depth analyses and OBC success stories. Additionally, if you are considering an OBC effort and have questions, please contact our Medicaid Consulting team

Article
Scaling project outcomes

Read this if you are at a rural health clinic or are considering developing one.

Section 130 of H.R. 133, the Consolidated Appropriations Act of 2021 (Covid Relief Package) has become law. The law includes the most comprehensive reforms of the Medicare RHC payment methodology since the mid-1990s. Aimed at providing a payment increase to capped RHCs (freestanding and provider-based RHCs attached to hospitals greater than 50 beds), the provisions will simultaneously narrow the payment gap between capped and non-capped RHCs.

This will not obtain full “site neutrality” in payment, a goal of CMS and the Trump administration, but the new provisions will help maintain budget neutrality with savings derived from previously uncapped RHCs funding the increase to capped providers and other Medicare payment mechanisms.

Highlights of the Section 130 provision:

  • The limit paid to freestanding RHCs and those attached to hospitals greater than 50 beds will increase to $100 beginning April 1, 2021 and escalate to $190 by 2028.
  • Any RHC, both freestanding and provider-based, will be deemed “new” if certified after 12/31/19 and subject to the new per-visit cap.
  • Grandfathering would be in place for uncapped provider-based RHCs in existence as of 12/31/19. These providers would receive their current All-Inclusive Rate (AIR) adjusted annually for MEI (Medicare Economic Index) or their actual costs for the year.

If you have any questions about your specific situation, please contact us. We’re here to help.

Article
Section 130 Rural Health Clinic (RHC) modernization: Highlights

Read this if your organization, business, or institution is receiving financial assistance as a direct result of the COVID-19 pandemic.

For companies and organizations that received federal funding to assist them during the COVID-19 pandemic, there have been some updates on Uniform Guidance. Here is a brief summary of those updates, audit threshold, federal funds subject to that threshold, and other pertinent information regarding the guidance.

Audit threshold

Non-federal entities that expend federal funds of $750,000 or more are required to have an audit in accordance with Subpart F of Title 2, U.S. Code of Federal Regulations, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).

Funds subject to threshold

  • 93.498 Provider Relief Fund
  • 21.019 Coronavirus Relief Fund
  • 84.425 Higher Education Stabilization Fund
  • 32.006 COVID-19 Telehealth Program
  • 84.184C CARES Act Project SERV
  • 93.461 COVID-19 Testing for the Uninsured
  • 93.527 Grants for New and Expanded Services under Health Center Program
  • 93.665 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19
  • 93.967 COVID-19 Testing for Rural Health Clinics

Funds exempt from threshold

  • 59.073 (Small Business Administration) Payroll Protection Loan Program
  • 59.072 Economic Injury Disaster Loan Emergency Advance

Audit options

  • Single Audit in accordance with Uniform Guidance
  • Program-specific audit (only applicable if the non-federal entity expends Federal awards under one single CFDA)

Reporting timetables

  • Automatic three-month audit submission extension for Single Audits of 2020 year-ends through September 30, 2020 (only if recipient received some form of COVID-19 funding subject to Uniform Guidance)
    • Example, a June 30, 2020 year-end’s initial date is March 31, 2021, however this was extended to June 30, 2021

Compliance supplement addendum takeaways

  • Released December 22, 2020
  • Provides guidance on auditing above CFDAs
  • For organizations with year-ends prior to December 31, 2020, above funding will be reported in the Schedule of Expenditures of Federal Awards (SEFA) for fiscal years ending in 2021

For-profit considerations

  • Department of Health and Human Services (HHS) has determined for-profit commercial organizations (which envelopes hospitals, senior living facilities, and other health facilities) are required to includes PRF payments in determining the $750,000 threshold
  • Currently, HHS guidance makes reference to organizations “receiving” not “expending” PRF, which is not in line with current Uniform Guidance definitions – AICPA has reached out for clarification
  • There is a third option under HHS guidance for organizations to have a financial audit performed in accordance with U.S. generally accepted auditing standards and U.S. generally accepted governmental auditing standards. However, there is uncertainty as to the specifics of this option and if this option would receive reporting extensions discussed above – AICPA has reached out for clarification

If you have questions about accounting for, or reporting on, funds that you have received as a result of the COVID-19 pandemic, please contact a member of our Single Audit Team. We’re here to help.

Article
Uniform Guidance—where we are today

The COVID-19 emergency has caused CMS (Centers for Medicare & Medicaid Services) to expand eligibility for expedited payments to Medicare providers and suppliers for the duration of the public health emergency.

Accelerated payments have been available to providers/suppliers in the past due to a disruption in claims submission or claims processing, mainly due to natural disasters. Because of the COVID-19 public health emergency, CMS has expanded the accelerated payment program to provide necessary funds to eligible providers/suppliers who submit a request to their Medicare Administrative Contractor (MAC) and meet the required qualifications.

Eligibility requirements―Providers/suppliers who:

  1. Have billed Medicare for claims within 180 days immediately prior to the date of signature on the provider’s/supplier’s request form,
  2. Are not in bankruptcy,
  3. Are not under active medical review or program integrity investigation, and
  4. Do not have any outstanding delinquent Medicare overpayments.

Amount of payment:
Eligible providers/suppliers will request a specific amount for an accelerated payment. Most providers can request up to 100% of the Medicare payment amount for a three-month period. Inpatient acute care hospitals and certain other hospitals can request up to 100% of the Medicare payment amount for a six-month period. Critical access hospitals (CAHs) can request up to 125% of the Medicare payment for a six-month period.

Processing time:
CMS has indicated that MACs will work to review and issue payment within seven calendar days of receiving the request.

Repayment, recoupment, and reconciliation:
The December 2020 Bipartisan-Bicameral Omnibus COVID Relief Deal revised the repayment, recoupment and reconciliation timeline on the Medicare Advanced and Accelerated Payment Program as identified below. 

Hospitals repayment, recoupment and reconciliation timeline 
Original Timeline 
Time from date of payment receipt  Recoupment & Repayment
120 days  No payments due 
121 - 365 days  Medicare claims reduced by 100% 
> 365 days provider may repay any balance due or be subject to an ~9.5% interest rate      Recoupment period ends - repayment of outstanding balance due 

Hospitals repayment, recoupment and reconciliation timeline 
Updated Timeline
Time from date of payment receipt  Recoupment & Repayment
1 year  No payments due 
11 months  Medicare claims reduced by 25% 
6 months  Medicare claims reduced by 50% 
> 29 months provider may repay any balance due or be subject to an 4% interest rate  Recoupment period ends - repayment of outstanding balance due 

Non-hospitals repayment, recoupment and reconciliation timeline
Original Timeline 
Time from date of payment receipt  Recoupment & Repayment
120 days  No payments due 
121 - 210 days Medicare claims reduced by 100% 
> 210 days provider may repay any balance due or be subject to an ~9.5% interest rate Recoupment period ends - repayment of outstanding balance due 

Non-hospitals repayment, recoupment and reconciliation timeline
Updated Timeline 
Time from date of payment receipt  Recoupment & Repayment
1 year No payments due 
11 months  Medicare claims reduced by 25% 
6 months Medicare claims reduced by 50% 
> 29 months provider may repay any balance due or be subject to an 4% interest rate  Recoupment period ends - outstanding balance due 

Application:
The MAC for Jurisdiction 6 and Jurisdiction K is NGS (National Government Services). The NGS application for accelerated payment can be found here.

The NGS Hotline telephone number is 1.888.802.3898. Per NGSMedicare.com, representatives are available Monday through Friday during regular business hours.

The MAC will review the application to ensure the eligibility requirements are met. The provider/supplier will be notified of approval or denial by mail or email. If the request is approved, the MAC will issue the accelerated payment within seven calendar days from the request.

Tips for filing the Request for Accelerated/Advance Payment:
The key to determining whether a provider should apply under Part A or Part B is the Medicare Identification number. For hospitals, the majority of funding would originate under Part A based on the CMS Certification Number (CCN) also known as the Provider Transaction Access Number (PTAN). As an example, Maine hospitals have CCN / PTAN numbers that use the following numbering convention "20-XXXX". Part B requests would originate when the provider differs from this convention. In short, everything reported on a cost report or Provider Statistical and Reimbursement report  (PS&R) would fall under Part A for the purpose of this funding. 
 
When funding is approved, the requested amount is compared to a database with amounts calculated by Medicare and provides funding at the lessor of the two amounts. The current form allows the provider to request the maximum payment amount as calculated by CMS or a lesser specified amount.
 
A representative from National Government Services indicated the preference was to receive one request for Part A per hospital. The form provides for attachment of a listing of multiple PTAN and NPI numbers that fall under the organization.

Interest after recoupment period:
On Monday, April 6, 2020, the American Hospital Association (AHA) wrote a letter to the Department of Health and Human Services and CMS requesting the interest rate applied to the repayment of the accelerated/advanced payments be waived or substantially reduced. AHA received clarification from CMS that any remaining balance at the end of the recoupment period is subject to interest. Currently that interest rate is set at 10.25% or the “prevailing rate set by the Treasury Department”. Without relief from CMS, interest will accrue as of the 31st day after the hospital has received a demand letter for the repayment of the remaining balance. The hospital does have 30 days to pay the balance without incurring interest.  

We are here to help
If you have questions or need more information about your specific situation, please contact the hospital consulting team. We’re here to help.

Article
Medicare Accelerated Payment Program