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e-SPA Introduction

This page is intended to provide information of interest to State and Federal staff regarding the electronic submission of State Plan Amendments (SPA).

The Centers for Medicare and Medicaid Services (CMS) currently receives a hard copy of each state's Medicaid State Plan that defines how a state will operate its Medicaid program. Once the appropriate CMS Regional Office receives the SPA, CMS has the option to approve or disapprove the amendment, or to send the state a request for additional information (RAI).

SPA submittal has historically involved mail or courier transmission of a hard-copy SPA document from the State to the CMS Regional Office. Problems with the traditional process include the delays associated with mailing this time-sensitive material, as well as a limited ability to share SPA contents during the review. This process has endured in large part because of the absence of a secure method to transmit a SPA, and to convey a State official's legal signature on the form 179 cover sheet. We believe that alternative solutions to these barriers are now available, and we are now able to make available an electronic process.

This electronic process is not intended to change the basic legal requirements for SPA submittals, requests for additional information (RAI) and SPA approvals. This process is intended to provide an alternative means of transferring the needed materials in a quick and secure manner to support the SPA process.

While this process offers the advantages of prompt transmission of time-sensitive SPA materials, it also implies a responsibility for both State and Federal parties to monitor their E-mail resources for receipt of SPA documents.

The Centers for Medicare and Medicaid Services (CMS) will provide licensed copies of the needed Constructive Key Management® (CKM®) software, and will facilitate obtaining a registered electronic signature code for each State and Federal SPA signing official. In the State, this will typically be the State Medicaid Director, who signs the form 179 SPA cover sheet. For the Federal Regional Office, the signing official will typically be the Associate Regional Administrator for the Division of Medicaid and State Operations.

The e-SPA Submittal Process will rely on E-mail as the transport mechanism between State, Regional, and Central offices. CKM technology and methodology provides the means by which data and information can be protected in transit and at rest, at the object level, using cryptography. CKM technology is designed to permit access to data/information by individuals who possess the necessary credentials (i.e. by individuals holding the necessary CMS-issued "authorizations" for access to the data/information).

The patented and standards-based CKM technology is provided to CMS by TecSec®, Inc.

The users credentials are included in their member profile and stored on a CMS issued software Smart TokenTM. In addition, the user's Public Key Infrastructure (PKI) certificate, used for e-signatures, will be stored on the Smart TokenTM.

Once the software is installed at each site, the CMS Central Office Administrator will generate and E-mail a "soft token" that authorizes the software to encrypt, decrypt and electronically sign secured transmissions.

Once installed, this software will allow users to take an existing electronic document file (e.g. a SPA with form 179 or an RAI letter or response) and encrypt it with an electronic signature code. The resulting encrypted file can then be forwarded as an E-mail attachment to the appropriate State or Regional Office.

For technical questions relating to e-SPA, contact (ESPAtech@cms.hhs.gov).



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Last Modified on Thursday, September 16, 2004