Current State

The existing Title V MCH – Title XIX Medicaid Inter-Agency Agreement (IAA) for Arizona is a data sharing agreement from 2013 defining the sharing of Blood Lead Level Data between AHCCCS and the ADHS’ Office of Environmental Health. Arizona’s Title V Program recognizes that this does not address the legislative intention of this requirement; however, there have been multiple challenges that Arizona’s Title V Program has faced in establishing an updated and more comprehensive agreement with AHCCCS, Arizona’s Medicaid agency.  

Recent Efforts and Challenges

In January 2021, Alison Lucas, Block Grants Program Manager, had a one-hour phone call with Kay Johnson of Johnson Group Consulting, Inc. to discuss strategies for drafting a Title V–Medicaid IAA. In February 2021, Ms. Lucas presented virtually at the Medical Management/Quality Management/Maternal Child Health/ EPSDT Quarterly Contractors Meeting, hosted by AHCCCS, in which she provided an update on the Title V Program and discussed our joint need to establish a new IAA (per both agencies statute). In April 2021, Ms. Lucas, Martin Celaya, Chief, Office of Assessment and Evaluation, and Clarke Baer, Maternal Mortality Program Manager, met to discuss how to include both Title V and Maternal Mortality Review Program (MMRP) agreement needs within one IAA, since both programs are managed through BWCH. Ms. Baer began drafting an IAA based on the technical assistance and other resources shared by Ms. Johnson, pulling ideas and language from other states’ IAAs as well.

ADHS/BWCH wanted to include language around data sharing in the IAA, since this was a need of the MMRP. However, in May 2021, Ms. Baer received information from Dr. Tack at AHCCCS explaining that AHCCCS was unable to share data with ADHS because ADHS is not Minimal Acceptable Risk Standards for Exchange (MARS-E) compliant, which is a Federal requirement of theirs for any data to be shared. Ms. Baer and Mr. Celaya then reached out to ADHS’ Bureau of Public Health Statistics for clarification, and they explained that MARS-E is a HIPAA privacy standard, and the ADHS programs that are seeking this data are HIPAA exempt and that the law does not require HIPAA privacy standards from organizations whose activities are allowable public health activities exempt from HIPAA. Dr. Cara Christ, former ADHS Director, made it very clear before she left that ADHS’ position is that there can be no agreement unless we are able to provide AHCCCS with data (and vice versa) in a manner that does not put us in violation of state or federal laws. The former ADHS Bureau of Public Health Statistics was pursuing this matter in coordination with AHCCCS, so BWCH received guidance to hold off on any further negotiation with AHCCCS on agreements that include requests for data sharing at this time. In March 2022, the Bureau of Public Health Statistics was eliminated and most of its primary responsibilities were shifted to the ADHS Business Intelligence Office.

ADHS/BWCH recently obtained a letter from Jami Snyder, the Director of AHCCCS, to collaborate on a new Memorandum of Understanding that will outline a partnership and collaboration between the two agencies. For more details the signed letter from AHCCCS can be found in Appendix F.

Looking Forward

As our next approach to establishing this IAA, Arizona’s Title V Program plans to create an IAA that only describes the coordination that currently exists and does not include any requests for data sharing. We hope that it may be easier to establish an IAA of this nature, and that an IAA like that could potentially serve as a foundation to build on going forward.

Title V MCH – Title XIX Medicaid Coordination in Arizona

In spite of the challenges in establishing an IAA between Title V and Medicaid, Arizona’s Title V Program coordinates with AHCCCS, Arizona’s Medicaid Program, on a number of activities and initiatives serving our shared MCH populations outside of the formal mechanism of an IAA.

These activities include:

• Joint meetings with county health departments and ADHS, hosted by AHCCCS, to discuss suicide prevention efforts, track action plans, and share resources.
• A suicide prevention specialist serves on the Adolescent and Young Adult Behavioral Health CoIIN state team.
• An AHCCCS agency representative participates on the MIECHV-funded Inter-Agency Leadership Team (IALT) focused on home visitation infrastructure.
• Health Start sites work with clients to get them enrolled in AHCCCS, if they are not currently enrolled. Home visitors are aware of the enrollment process and the available health plans for their service areas and provide assistance to clients to complete the enrollment and access services.
• Health Start has worked with the AHCCCS Office of Maternal and Child Health committees on additional policy changes related to MCH services delivery on substance use screening and perinatal depression screening.
• An AHCCCS agency representative is a member of the Maternal Health Task Force, Maternal Mental Health Task Force, and the Alliance for Innovation on Maternal Health Steering Committee.
• ADHS maternal health programs are members of the AHCCCS-led State Pilot Grant Program for Treatment for Pregnant and Postpartum Women learning collaborative.
• There is ADHS maternal health program representation on the AHCCCS-led Maternal Mental Health Advisory Committee.
• AHCCCS is a participating member of the Maternal Mortality Review Committee.
• An AHCCCS agency representative participates in the Annual State Child Fatality Review Program meeting to discuss the final child fatality data that gets included in the annual report.