Please Share This Information with Administrative, Clinical and Billing Staff

The  Affordable  Care  Act  (ACA)  requires  that  states  create  a  Separate  Children’s  Health Insurance Program (SCHIP) for children that are ineligible due to new eligibility methodologies. Children who lose Medicaid or CHIP eligibility (with or without health insurance) due to the elimination of disregards as a result of the conversion to Modified Adjusted Gross Income (MAGI) shall have protective Medicaid coverage for one year if the child had Medicaid as of December 31, 2013, unless specific conditions are met.

As of January 1, 2014, Nebraska established a separate Children’s Health Insurance Program (SCHIP) for this population.  These children have coverage under SCHIP for one year if the child had Medicaid as of December 31, 2013, unless specific conditions are met. This protected group expires December 31, 2015 and will impact a limited number of children. The children enrolled in this program are considered insured and are not entitled to Vaccines for Children (VFC) program benefits.

Nebraska Medicaid has implemented a process whereby the provider will be able to identify children enrolled in SCHIP based on a printed notice provided by the child’s parent or guardian. This notice does not guarantee coverage; providers will need to verify current coverage through the Nebraska Medicaid Eligibility System (NMES).

Physicians may be reimbursed for private stock for children under the SCHIP plan. When billing Nebraska Medicaid for private stock, the physician should bill the applicable code for the vaccine without the SL modifier.  If the child is enrolled with a managed care plan, the vaccine given to this population should be billed to the managed care plan.

Coverage for VFC Vaccines




VFC Eligible



Not VFC Eligible



Vaccine Provided Through VFC

Vaccine Privately Purchased



Bill Administration Fee







Separate CHIP







Further questions regarding this bulletin should be directed to Elaine Bachel, Program Specialist RN, at 402-471-9124 or

Dr.  Leighton Ku, author of the policy brief  “Strengthening Immigrants’ Health Access: Current Opportunities,” will outline both  the opportunities and  obligations that federal health reform law will bring to lawfully present immigrants, who have obtained green cards or visas allowing them to work, study  and live in the United States.  Dr. Ku is Professor, Dept. of Health Policy and Director, Center for Health Policy Research in the School of Public Health and Health Services, George Washington University.  State-specific experience and commentary on immigrant insurance coverage and health care access will be provided by Elizabeth Swain, President & Chief Executive Officer, Community Health Care Association of New York State, and Bobbi Ryder President & CEO,  National Center for Farmworker Health, Inc.

Thursday, Feb 6, 2014, 2:00-3:30pm CST (1:00-2:30pm MST)

Go here to register: 

This webcast is pending for up to 1.5 CE credits by the American Academy of Family Physicians (AAFP). For the purposes of American Nurses Credentialing Center (ANCC), participants may use these contact hours.

CDN is a Designated Provider with NCHEC. This program is designated for Certified Health Education Specialists (CHES) and/or Master Certified Health Education Specialists (MCHES) to receive up to 1.5 total Category I continuing education contact hours.  Related areas of competency include selecting or designing strategies and interventions (2.3) and addressing factors that affect implementation (2.5).

Health Disparities Pulse is the new quarterly newsletter on minority health and health disparities from the National Institute on Minority Health and Health Disparities at the National Institutes of Health. In this issue: funding opportunities, exploring the environment in health disparities, web-based software for limited English proficiency patients and more. Download the inaugural issue.

Do you participate in the 340b program?  Did you know the Office of Pharmacy Affairs (OPA) requires all 340b-covered entities to recertify their information each year in order to continue participating in the 340b program?  Health Centers will begin the recertification process in February 10th and it is absolutely critical that contact information be updated by March 14th in order to get the latest information to ensure continued participation in the program.  For more information, stay tuned to the Policy Shop blog and the Office of Pharmacy Affairs website.

Find out How to Enroll in the Health Insurance Marketplace February 4 at 2pm CST (1pm MST).   Please submit your questions for this free webinar in advance to

News release from the U.S. Department of Health & Human Services

Nearly 2.2 million people had selected health insurance plans from state and federal ACA-mandated marketplaces by December 28.

On Thursday December 26, 2013, the Office of Management and Budget (“OMB”) released Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Grants (the “Supercircular;” also known as the “Omnicircular”). The Supercircular sets standard requirements for financial management of Federal awards across the entire Federal government.
The Supercircular supersedes and streamlines requirements from eight OMB Circulars A-21, A-87, A-110, A-122, A-89, A-102, A-133, and A-50 that have been codified at different times for different types of organizations and by different parts of the Federal government. The Supercircular is part of a larger effort by the Federal government to focus resources more effectively on improving performance and outcomes while still ensuring the financial integrity of taxpayer dollars.
The Department of Health and Human Services (“HHS”) and other Federal agencies must implement the Supercircular’s changes for their grantees and subrecipients by December 26, 2014. It is our understanding that the Supercircular’s requirements will apply to your FY 2015 awards made after December 26, 2014.
Non-Federal entities receiving Federal awards should begin to prepare now for implementation of the Supercircular and its myriad changes. Based on changes to the Common Rules, Cost Principles and Audit Requirements in the Supercircular, non-Federal entities will likely need to alter policies, procedures, and operational systems.
As stated in the preamble to the Supercircular, OMB is committed to reforming the Federal financial assistance framework, including grant-making, by targeting overall approaches to financial management that focus on improving program outcomes. The Supercircular is part of this Administration’s attempts at developing more efficient and transparent government while still ensuring financial integrity. The Supercircular builds on two previous proposed rules and notice and comment periods. Previously, OMB worked with the Council on Financial Assistance Reform to publish a February 28, 2012 Advance Notice of Proposed Guidance and a February 1, 2013 Notice of Proposed Guidance. OMB received hundreds of written comments on each. The preamble to the Supercircular explains and responds to common comments and identifies broad themes within the comments. The preamble is followed by the final text of the Supercircular.
When HHS promulgates its implementing regulations, 45 C.F.R. Part 74, Uniform Administrative Requirements for Awards and Subawards to Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations, and Commercial Organizations, and 45 C.F.R. Part 92, Uniform Administrative Requirements for Grants and Cooperative Agreements to State, Local, and Tribal Governments, will be superseded. The Cost Principles for Nonprofits (OMB Circular A-122, codified at 2 C.F.R. Part 230), State Local and Tribal Governments (OMB Circular A-87, codified at 2. C.F.R. Part 225), and Educational Institutions (OMB Circular A-21, 2. C.F.R. Part 220) are also being superseded by the new provisions of the Supercircular.
Additionally, the provisions of OMB Circular A-133, Audits of States, Local Governments and Non-Profit Organizations, are superseded by the Supercircular. Specifically, the audit provisions are effective for non-federal entities with fiscal years beginning on or after the effective date of the Supercircular (Dec 26, 2013). If grantees have biennial audits, if the biennial period started before December 26, 2013, then they are expected to follow A-133. If, however, the biennial period starts after December 26, 2013, then they are expected to follow the Supercircular.
Major Reforms in the Supercircular
The Supercircular includes a number of very significant changes for Federal grants administration including the following:

  • Time and Effort Reporting

The Supercircular makes significant reforms to time and effort reporting requirements that are intended to strengthen the requirements for internal controls over salaries and wages and provide some flexibility to grantees. The Supercircular requires non-Federal entities to comply with a new framework of internal control objectives rather than the previously-required prescribed personnel activity reports or periodic certifications. Part of the new framework expressly allows non-Federal entities to make interim charges based on budget estimates as long as final adjustments to charges are made to ensure that any amounts charged to Federal awards is accurate. The Supercircular preamble also notes that many non-Federal entities may find that existing procedures, such as personal activity reports and similar documentation, are the best method for meeting internal control requirements, but it does not specifically require them.

  • Procurements

While many of the main aspects of conducting proper procurements (such as maximizing competition) remain the same as what is currently in existence, the Supercircular includes are some new and different elements. Among other things, if grantees plan to do sole source procurements, they must now fit into one of four limited circumstances. Additionally, non-Federal entities with parent, affiliate, or subsidiary relationships must maintain written standards of conduct covering organizational conflicts of interest. A micro-purchase threshold (for non-Davis Bacon purchases under $3,000) is also included. The simplified acquisition threshold is clarified at $150,000.

  • Indirect Cost Rates

The Supercircular changes how non-Federal entities can obtain indirect cost rates for Federal awards. The Supercircular allows non-Federal entities that have never had a negotiated indirect cost rate with the Federal government to use a de minimis, 10 percent of Modified Total Direct Costs amount for their indirect cost rates.

Additionally, the Supercircular requires that if a grantee has negotiated an indirect cost rate with a Federal agency, other Federal agencies should accept it unless there is a statutory, regulatory, or otherwise-approved deviation. It also allows for a one-time extension of a Federally-approved negotiated indirect cost for a period of up to 4 years. The Supercircular also instructs non-Federal entity grantees to pass through their indirect cost rate to subrecipients.

  • Mandatory Disclosures

The Supercircular also requires grantees to timely disclose in writing to their Federal awarding agencies all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting Federal awards. It does not, however, specify a particular approach to disclosure.

  • Audit Changes 

The Supercircular raises the Single Audit threshold from an annual amount of $500,000 to $750,000 in Federal awards per year.

  • Other Key Changes

The Supercircular makes a number of other significant changes to grants administration and the allowably of costs under grants:

    • It incorporates IRS terminology and frameworks for “lobbying.”
    • It eliminates the existing allowability of employee “morale” costs.
    • It requires all non-Federal entities to safeguard personally identifiable information and other sensitive information.
    • It clarifies when computing devices are to be characterized as supplies or equipment.
    • It extends the closeout period for an award from 180 days to one year, and clarifies that non-Federal entities have 90 days from the end date of the period of performance to submit all final reports.

Many other changes are included throughout the Supercircular.
Preparing for Implementation

Non-Federal entities should begin now, with the assistance of counsel, to understand the nuances of the Supercircular and identify where changes will be required that affect them legally and operationally. Over the coming year, non-Federal entities will need to examine thoroughly the Supercircular’s new requirements and modify their systems, policies, and practices accordingly.

Feldesman Tucker Leifer Fidell LLP will conduct the first of many trainings for all interested grantees, sub-grantees, and other interested parties on the legal implications of the Supercircular on February 18, 2014 at 3:00 pm EST. See for more information.

For further information on the Supercircular or Federal grant issues, please contact Ted Waters at (202) 466-8960.

**This Client and Field Alert is informational in nature and is not intended to provide advice or counsel to any Federal Grantees, Sub-Grantees or other interested parties.**


We have a new name! Formerly known as the Community Action Grant.

Application details and application form are available to download at

Application deadline is Thursday, Feb. 13, 2014 5pm CST

Applications should be electronically submitted to

The American Heart Association is asking our partners across the nation to help us raise awareness of cardiovascular disease in the community.  We invite you to join us in our efforts, plan a heart-health awareness activity in February – or at any other time during the year.  National Wear Red Day is the first Friday, February 7, 2014, but any day can be Wear Red Day.  For additional information and to request materials, please contact if you have any questions.

HHS and the NCCC have created a toolkit to help your organization raise awareness about how women can protect themselves from HPV (human papillomavirus) and cervical cancer. Learn more.