pilot for end-to-end testing of compliance with administrative simplification
DESCRIPTION
Pilot for End-to-End Testing of Compliance with Administrative Simplification. Presented By: National Government Services February 5, 2013 10 am to 11 a m EST. Welcome. Agenda. Welcome/Opening Remarks Julie McBee5 minutes ICP AttendanceDavid Carrier2 minutes - PowerPoint PPT PresentationTRANSCRIPT
Pilot for End-to-End Testing of Compliance with Administrative
SimplificationPresented By:
National Government ServicesFebruary 5, 2013
10 am to 11 am EST
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Agenda Welcome/Opening Remarks Julie McBee 5 minutes ICP Attendance David Carrier 2 minutes Ground Rules Julie McBee 2 minutes Goals, Intended Outcomes & Overview Mission-Critical Definition Review David Carrier 5 minutes
Small Provider Checklist Feedback Julie McBee Open floor 5
minutes Small Provider Checklist Review Cont’d Julie McBee
Open floor 40 Minutes
Questions Team Closing Remarks Team How to Contact Us Julie McBee
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Industry Collaborative Partners Introductions
• Aetna• American Health Insurance Plans (AHIP)• American Hospital Association (AHA)• American Medical Association (AMA)• CMS Medicaid• CMS Medicare Fee For Service• Emdeon• Healthcare Billing & Management Association (HBMA)• IVANS• Medicaid – CSG Government Solutions• Medical Group Management Association (MGMA)• Nachimson Advisors, LLC• Providence Health and Services• TIBCO Foresight• TRICARE• UNC Health Care• Walgreens• WellPoint • Veteran’s Affairs
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Ground Rules All participants will be muted upon log in for the start of the webinar. Once the opening presentation is done, we will open it up for questions. Please provide your name when asking a question so that we know who is
speaking. Additionally, we ask that only the primary and back-up points of contact
be your designated speakers on the webinar. With the number of participants we expect to participate on our webinars, we want to give each Industry Leader ample time to contribute.
Listen to and value all contributions equally. We are trying to make sure this is a collaborative effort where all Industry leaders can be heard.
We value your time so please keep your discussion focused. Specifically for today’s call, we will be opening the floor for each
contributor up to 3 minutes to speak. We will let you know when you are at 2 and 2:30 minutes to finalize your comments.
Silence equals agreement.
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GoalsThe goals of the pilot are:
• To develop and implement a process and methodology for end-to-end testing of the transaction standards, operating rules, code sets, identifiers, and other Administrative Simplification requirements adopted by the Secretary of Health and Human Services (HHS) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Patient Protection and Affordable Care Act of 2010 (ACA) based on industry feedback and participation.
• To develop an industry wide “Best Practice” for end-to-end testing that lays the ground work for a more efficient and less time consuming method for health care provider testing of future standards, leading to more rapid adoption of the future standards.
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Intended OutcomesThe intended outcomes of the pilot are:
• To provide documents and artifacts to all industry segments outlining the critical check-points needed to ensure compliance with the current mandates
• To provide documents and artifacts to all industry segments outlining the critical check-points which can be used as foundations with future mandates
• To provide a universal testing process and methodology that can be adopted by all industry segments
• To provide a framework and common understanding around the End-To-End testing process and definitions
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Overview• Phase I – Business and Gap Analysis started on September 24, 2012, and
ran through December 21, 2012 (Completed)
• Phase II - Development of Pilot Testing started on December 10, 2012, and will run through June 27, 2013 (approximately six months)*
• Phase III - The planned start date for Phase III, Implementation and Quality Assurance, is July 1, 2013, and will run through September 23, 2013 (approximately three months)*
*Actual dates are subject to change during detailed schedule development
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DefinitionsThe 3 definitions for End-To-End Testing, Readiness, and Compliance are considered complete and have been sent for review by CMS Legal.
The definitions for Provider Readiness, Payer Readiness, and Vendor Readiness are considered complete and have been sent for review by CMS Legal.
Mission-critical Feedback
₋ Comment - factor of a system, it points people to an IT system. We should find another word that may not refer to IT.
₋ I’m not clear on what “factor of a system” means.₋ Define “Factor of a system”.₋ Replace “critical failure” with “may result in negative impact of” ₋ 2 definitions suggested for Mission-critical.₋ Current definition is not very clear.₋ Mission-critical identifies those functions, systems and processes for an organization,
where, if unacceptable level of impact is experienced, could result in the negative functioning of business operations.
₋ Mission-critical refers to any process, catastrophic failure, instead of critical. ₋ To include in the checklist - Mission-critical may be different for each industry.₋ “Mission critical refers to any factor of a system…” remove the word ‘system’ and replace
with ‘process’ since use of system is too IT-focused or too IT-centric.₋ Mission-critical refers to any component of an organization's operations (equipment,.....).
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Mission-critical Feedback
₋ Also a suggestion - to replace the words “critical failure” and instead use the words “negative impact”
₋ Agrees to use the word “process” instead of “system”. May also want to consider using the word “catastrophic” instead of “critical”, since that word ‘catastrophic’ is commonly used in the industry (HIPAA).
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Mission-Critical
*Our revised definition:
Mission-critical refers to any essential service required for day-to-day operations, whose unacceptable impact to one or more business processes may result in the catastrophic failure of business operations. This may include trading partners, business processes, IT systems process, business associate, and/or vendor processes.
*This is a catalyst for our initial discussions with our Industry Collaborative Partners for establishing a clearly refined definition of Mission-Critical based on Industry feedback and participation on the January 31, 2013 webinar.
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Small Provider Checklist Feedback
─ In the Small Provider Checklist the following was noticed:─ 2.4.4 mentions “person they will assign to you” – perhaps change this to ‘contact
person’?─ 2.9.11 mentions “Implementation Guide” – should this really instead refer to
‘Companion Guide’?─ Size - Something that needs to be considered with the checklist, so providers are not
too overwhelmed, certain instances, to include steps to be compliant.─ As far as the acknowledgements – providers don’t receive 997, they receive a
translated report, any proprietary reports can be received, needs to be part of the testing.
─ I feel strongly that acknowledgement should not be eliminated. I just want to make that clear. It should be part of the testing.
─ Support what was said with acknowledgement process, needs to be some kind of process that indicates the transaction has been processed, can be an email confirmation, etc.
─ Needs to specify some type of acknowledgment.─ For any proprietary reports, we should eliminate the 277CA. ─ The acknowledgement should not be eliminated, should be part of the testing.
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Small Provider Checklist Feedback #2
─ Things on different tabs, think it would be confusing to come out with two different definitions for Admin Simp, ACA, ICD-10. Towards the end, it may be better to combine them all.
─ Critical comment – vendors are not covered entities; that has been an obstacle for small providers. It needs to be emphasized that there needs to be better relationships/communications between providers and vendors.
─ For E2E testing – everyone has to be ready. May need couple of timelines when different steps need to be taken, who needs to be ready first, second, and so forth.
─ Agree completely!! The entire chain needs to be ready.─ Examples will be given in the checklist. Mission critical factors may be different for
each entity.─ Comment on Task 2.3.6 (Level 1, Element 2 – Assessment) regarding the statement,
what do we mean by that? Why not? The ICD-10 codes need to be put in paper or electronic in replacement of the existing codes.
─ What do you mean in section 2.3.6? Why would they integrate it into existing record when clearly implementation of ICD-10 is date driven!
─ Suggestion to add a section for performance.
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Small Provider Checklist Feedback #3
─ Task 2.9.2 (Level 1, Element 2 – Assessment) May be changes to the acknowledgement they’re using. Make sure that they understand that’s part of the testing, any scanning of the forms (HCFA 1500) are being included. Some vendors need to understand that a lot of the software that processes is compliant with the EDI system - Print images that convert to the EDI systems. Needs to be communicated with the vendors. They need to give the providers a system in place that would alert the providers about that. If it’s an old system, that needs to be looked at. The ICD indicator needs to be changed from 9 to 10 on the print image. Most of their EDI files are generated through something else.
─ Shouldn’t covered entities hold vendors accountable through contractual agreement? BAs are held accountable in certain parts of the new HITECH privacy and security update.
─ Comment regarding paper – The E2E testing - does it apply for electronic submitters only or does it also apply for paper ones? Providers need to check with their vendor about their system(s).
─ Point for clarification – referring to HCFA 1500 system that converts to the electronic format - the print image they send it through (the EDI form) - Need to keep in mind it gets converted.
─ Payer’s perspective – they use paper to interpret to electronic.
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Small Provider Checklist Feedback #3
─ Might want to add a section to perform sample audits of various areas to ensure that the coding results meet the reporting requirements of ICD-10. (Internal Assessment) Educate and inform of management and department of results and take corrective action.
(Review to be continued on Tuesday, February 5)
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Closing Remarks• Next ICP webinar session is Thursday, February 7, 2013 from 10 am to 11
am, EST• End-to-End Testing web page (http://
www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/End-to-End-Testing.html)
• ICD-10 web page (http://www.cms.gov/Medicare/Coding/ICD10/)• Listening Sessions – Participants can join via a CMS website link on the
End-to-End Testing page at http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/End-to-End-Testing.html
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Suggested Audience for Listening Session Definitions
Small Providers includes small/medium sized organizations comprised of 99 or less physicians/staff, independent practices, dentists, durable medical suppliers, pharmacy, home health agencies/hospices, and specialty practices.
Large Providers includes organizations comprised of 100 or more physicians/staff, clinical labs, hospitals, critical access hospitals, nursing homes, rehab centers, skilled nursing facilities, ambulatory surgical centers, pharmacy, and Federally Qualified Health Centers (FQHC).
Payers includes organizations comprised of Commercial, Medicaid, Medicare, Pharmacy Benefit Management (PBM), and Workers Compensation Government Contractors.
Vendors includes organizations comprised of Billing Services, Clearinghouses, Electronic Health Record/Electronic Medical Record Systems, Network Service Vendors, Practice Management Systems, and Value Added Networks.
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How to Contact Us• All questions may be sent to [email protected]• Our expected level of service is to acknowledge all e-mails within 24
hours• Additional Contact Resources:
Resource Name Role E-mail Addresses Work Phone Cell Phone
David Carrier BA II [email protected]
(207) 253-1203 (207) 210-2340
Dean Cook SME/Advisor
[email protected] (502) 889-4762 (502) 376-6510
Julie McBee BA II – POE [email protected]
(317) 595-4908 (317) 586-0021