Pilot for End-to-End Testing of Compliance with Administrative Simplification

1. Pilot for End-to-End Testing of Compliance with Administrative Simplification Presented By: National Government Services January 31, 2013 10:00 am to 11:00 am EST

2. Welcome ngs.compliancetesting@wellpoint.com

3. Agenda • Welcome/Opening Remarks Julie McBee 5 minutes • ICP Attendance Julie McBee 5 minutes • Ground Rules Julie McBee 2 minutes • Goals, Intended Outcomes & Overview • Payer Checklist Feedback Julie McBee • Open floor 5 minutes • Mission Critical Definition Julie McBee • Open floor10 minutes • Provider Checklist Review & Feedback Julie McBee • Open floor 30 Minutes • Questions Team • Closing Remarks Team • How to Contact Us Julie McBee ngs.compliancetesting@wellpoint.com

4. 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 ngs.compliancetesting@wellpoint.com

5. 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 expectto 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. ngs.compliancetesting@wellpoint.com

6. Goals The 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. ngs.compliancetesting@wellpoint.com

7. Intended Outcomes The 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 ngs.compliancetesting@wellpoint.com

8. 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 ngs.compliancetesting@wellpoint.com

9. Definitions The 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. ngs.compliancetesting@wellpoint.com

10. Mission-Critical • *Our revised definition: • Mission-critical refers to any factor of a system (equipment, process, procedure, software, etc.) whose unacceptable impact to one or more business processes may result in the critical failure of business operations. • *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 January 29, 2013 webinar. ngs.compliancetesting@wellpoint.com

11. Mission-Critical Feedback • The failure of item is one factor, a significant (Significant reduction in cash flow, significant number of claims denied) issue in dealing with provider. "Failure of business operations" sounds too strict. For our purposes, this definition of Mission-Critical is a little too strict. Should we say “unacceptable level in one or more business processes impacting the patient care; we don’t want that to happen? • Agree with Stanley (use of the word “failure” is too strict). Mission component of revenue cycle, significant hardship. We need to zone in on the revenue cycle. • Suggestion to use "unacceptable level of impact" instead of using the word "failure“. • To say “unacceptable (impact)in one or more business processes”. WEDI has developed a factor for failures that our pilot can take a look at. WEDI has developed a number of measures to identify failure points. • I agree with your definition and that of Stanley; however, critical failure or important business component that an entity may not allow to fail depended on the entity.   You can keep the definition and list examples of some critical business process that may be important to an entity with the usual caveat that it is not all inclusive under the checklist. • (continued on next slide) ngs.compliancetesting@wellpoint.com

12. Mission Critical Feedback #2 • On the planning steps, I agree with Stanley that it could be overwhelming to the small providers and I will add that it probably goes beyond the scope of end-to-end testing.  While your steps are excellent they are project management issues.  Although end-to-endtesting is and should be a part of the process, all of these steps should have been done (or assumed to have been accomplished) before getting to end-to-end testing.  If small providers are using a third party to accomplish the tasks that entity should be assured all of these processes are accomplished before embarking on the testing.  If a small provider is engaging in these tasks on his/her own, the small provider may not be able to accomplish end-to-end testing in its true form until these tasks are properly accomplished. • How do we take into consideration these two scenarios?  We could have two – one table for those small providers who have accomplished the steps you listed and advise that they go directly to the testing;  and the second table for those who may not have accomplished these tasks to consider using the steps you suggested to ensure better end-to-end testing results.  ngs.compliancetesting@wellpoint.com

13. Small Provider Checklist ngs.compliancetesting@wellpoint.com

14. Small Provider Checklist Feedback • We have removed the 5010 version & replaced with "XXXX", transactions are listed on top. • The acknowledgements (are not necessary to be looked at under HIPAA) - we should indicate about the transactions not being required; should put something about operating rules - current 270/271 - We need to note these are not HIPAA transactions. What about the Operating Rules? Do we need to add those in? E2E is not only transactions, but appropriate Operating Rules to adhere to. Comment: this was discussed in the BA meeting with Dean. The Operating Rules E2E will be under the ACA tab vs. including in E2E testing of transactions and code sets which is in the ASCA tab. By the time ICD-10 is implemented, the testing of transactions and operating rules are covered. PAG, correct me if my assumption from yesterday’s meeting is incorrect. Can we explain that by the time ICD-10 E2E is to occur, ASCA will cover the transactions, code sets, privacy and security, identifiers? ICD-10 will be the necessary changes to do E2E testing of ICD-10 in the transactions. • Small providers don't understand about the transactions, so to add a new step to check with clearinghouse if they're compliant. As far as mission-critical, to add a component about that since each entity has a different definition. *Small providers do not understand the “behind the scenes” activities that occur. Confirm with business partner they are compliant. May want to add a point in the checklist for defining “Mission-Critical”. ngs.compliancetesting@wellpoint.com

15. Small Provider Checklist Feedback #2 • Small provider may say this is too much. They would need help on this, it is too detailed (it is way too detailed). This is a complete project plan, way more than E2E testing. We need to make things easier. There are guides available for ICD-10, even CMS has some. • The decision to include Communication, Assessment, etc., is a little too much for E2E testing (extremely burdensome). • Under Assessment where it says, "Claims received" - as far as providers, they bill claims, they don't receive claims. • 2.3.1.l and 2.3.1.m - are duplicates. • (To be continued on Thursday at section 2.3.4 m.) ngs.compliancetesting@wellpoint.com

16. Questions ? ngs.compliancetesting@wellpoint.com

17. Closing Remarks • Next ICP webinar session is Tuesday, February 5, 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 ngs.compliancetesting@wellpoint.com

18. 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. ngs.compliancetesting@wellpoint.com

19. How to Contact Us • All questions may be sent to ngs.compliancetesting@wellpoint.com • Our expected level of service is to acknowledge all e-mails within 24 hours • Additional Contact Resources: ngs.compliancetesting@wellpoint.com