5. The Federal Data Services Hub or Other Electronic Service

The Federal Data Services Hub, operated by CMS, is an electronic service through which States can access a number of data sources for use in verifying Medicaid eligibility. Existing regulations in § 435.949 require that to the extent that information related to eligibility for Medicaid is available through the Hub, States must access the information through that service to obtain information from Federal agencies and other data sources, including the SSA, the Department of the Treasury, and the Department of Homeland Security, except as provided in § 435.945(k). We expect to establish connections to additional data sources and provide States information through the Hub and/or another Federally operated electronic service to verify certain factors that could impact whether someone is subject to the community engagement requirement, and if so, whether they demonstrate or are deemed to have demonstrated community engagement, including additional sources related to qualifying activities under § 435.552, mandatory exceptions under § 435.553, optional short-term hardship exceptions under § 435.555, and specified excluded individual criteria under § 435.554. Examples of these additional data sources include the National Student Clearinghouse and the VA. We are also establishing other Federal services, such as the Eligibility Made Easy (Emmy) tool, through which States can access information specific to community engagement. Once those data sources are established and reliable information relevant to verifying compliance with the community engagement requirement becomes available through the Hub, § 435.557(e) requires States to access the data available via connection to the Hub as soon as practicable, but no later than 12 months after their initial availability through the Hub. We are also establishing other Federal services, such as the Eligibility Made Easy (Emmy) tool, through which States can access information specific to community engagement.

A State may obtain approval under § 435.945(k) to establish a direct connection to access information available through the Hub through an alternative source or mechanism as soon as practicable, but no later than 12 months after the information relevant to verifying compliance with the community engagement requirement becomes available through the Hub. The 12-month period allows States time for planning and implementation, including the system development and changes States will need to make for their eligibility systems to ingest and use information from newly available electronic data sources. Section 435.557(e)(1) provides that we may determine a Hub waiver as described at § 435.945(k) is not required if the State establishes a connection to access information available through the Hub from certain alternative Federal electronic services, such as the Emmy API , should such services become available, that provide reliable and relevant information. We would make such a determination that a waiver is not required in circumstances where it is likely that a direct connection to or alternative mechanism for accessing information from the new data source would be likely to satisfy the criteria in § 435.945(k).