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National Human Services IT Resource Center

The Federal Perspective: Requirements for IT Planning

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The Administration for Children and Families strongly supports State efforts to improve planning and development of Human Services information systems.  In fact, Federal funding is available to support planning activities.  Once you've developed a strategic plan and you're about to move forward with an initiative, it's not only a good idea - in many cases, it's required - that you contact the appropriate Federal Agency before executing the plan.

This section provideds a brief overview of Federal requirements related to planning, developing, modifying, or replacing an information system.  This explanation is intended as a reminder and shouldn't be construed as a complete listing of Federal rules and requirements.  For more information about specific requirements, contact the appropriate Federal Agency.  A listing of relevant instructions and requirements is also provided (see Federal Guidelines, Requirements, and Information below).

If you are in doubt about Federal requirements, the best thing to do is contact the appropriate staff.

Advance Planning Document (APD) Thresholds

Dollar thresholds determine whether States must obtain written approval from HHS before proceeding or before authorized payments.  The threshold is $5 million dollars, total Federal and State expenditures, for "regular rate" funding (generally 50 percent Federal funding).  There is no threshold for enhanced-funded projects (see Federal Guidelines, Requirements, and Information for specific information).

The APD Process

If the system that you are considering replacing, modifying, or developing includes functionality that benefits one of the following programs and will exceed applicable thresholds, then the State is required to submit planning documents, in advance, to the appropriate Federal Agency.  The programs are Child Support Enforcement, Child Welfare under titles IV-E and IV-B of the Social Security Act, Medicaid, and Food Stamps.  

The APD process is just what the title says - documents that the State submits to the Federal Agency, or agencies, before implementing a project.  There are a number of steps in the process: 

The Planning Advance Planning Document (Planning APD) is the State's request for funding of the planning process (see Federal Funding for the Strategic Planning Process).  A Planning APD is a written plan of action to determine the need for, feasibility of, and projected costs and benefits of an automatic data processing (ADP) equipment or services acquisition. 

Planning APDs are used by States that want to be reimbursed for the costs of planning the implementation of a new system or modifying an existing system, including acquisition of equipment or services. 

Planning activities eligible for Federal financial participation (FFP) by HHS include:

The Planning APD is a very brief document prepared and submitted prior to initiating Planning Phase activities; it is a plan to plan.  The purpose is to develop a high-level management statement of vision, needs, objectives, plans, and estimated costs.  The focus is on describing how planning will be accomplished and demonstrating that the State has established a plan that is reasonable for the level of effort of the project.  Planning APDs that meet the standards for approval shown in the box on the preceding page will be approved within 60 days.

The Planning APD has four sections:

  1. Statement of need
  2. Project Management Plan for planning
  3. Planning project budget
  4. Estimate of total project cost

The Implementation Advance Planning Document (Implementation APD) is a written plan of action that States use to request FFP for the costs of designing, developing, and implementing the system.  Implementation activities eligible for matching funds from HHS include:

States are required to submit an Implementation APD prior to incurring costs for system design and development, when the total project costs (including planning) are estimated to exceed the thresholds in 45 CFR §95.611(b) . ( http://www.acf.hhs.gov/programs/oss/all_acf/part95.htm )

Unlike the Planning APD, the Implementation APD is a comprehensive and thorough document that sets forth specific, detailed information and summarizes or provides key documents prepared during the Planning Phase.  The detail in the Implementation APD should correspond to the complexity and scope of the acquisition.  For example, States can set forth the need, costs, and benefits for a mainframe upgrade in significantly fewer pages than required for a new, multiprogram, multimillion dollar system development project.  It is the State's responsibility to determine how much text and graphics are required to explain its plan of action with clarity.  However, as a rule of thumb, HHS does not expect submissions that are too large to fit in a 2- or 3-inch binder.  In general, less is better, provided clarity is not sacrificed. 

As described in 45 CFR §95.605 , ( http://www.acf.hhs.gov/programs/oss/all_acf/part95.htm ) the Implementation APD should have six sections, organized and categorized as follows:

The Annual Advance Planning Document Update (Annual APD Update) is the means by which States update the APD in order to inform Federal agencies of progress and changes in the plan.  The Annual APD Update includes the following sections:

The As-Needed Advance Planning Document Update (As-Needed APD Update) is used to:

Examples of significant changes are increases in costs of $1 million or more or extensions of over 120 days in the project schedule.  The thresholds are specified in the Federal rules at 45 CFR §95.611(b) ( http://www.acf.hhs.gov/programs/oss/all_acf/part95.htm ). For example, the State should use an As-Needed APD Update to:

The As-Needed APD Update may be submitted at any time, following the format of the APD being amended but including only those elements that have changed.  The State must include supporting documentation to justify the need for a change to project approvals.

Other Requirements

In addition to submission of APDs, States are required to submit contract documents (RFPs, contracts, and contract amendments) for prior approval if the total cost of the contract will exceed specified thresholds (generally $1 million for regular rate funding and $100,000 for enhanced funding.  Sole source contracts have special approval requirements and thresholds (see Federal Guidelines, Requirements, and Information).

Federal Funding for the Strategic Planning Process

The Strategic Planning Process described in the Survival Guides is, in a sense, a higher-level activity than activities for which an APD is required.  The strategic planning process is the means by which a State decides which initiatives it will undertake.  Any one of those initiatives might require an APD.  However, because the strategic planning process is not directed toward any one system or program, and it does not entail specific planning for the replacement, modification, or development of a system or system architecture, strategic planning is not subject to the APD requirements.  That doesn't mean that Federal funds are not available for the activity.  It just means that the costs of strategic planning should be considered as any other administrative cost that is not subject to the APD process.

Federal Guidelines, Requirements, and Information

Last Updated: May 4, 2005