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 February 5, 2013 10 am to 11 am EST

2. Welcome ngs.compliancetesting@wellpoint.com

3. 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 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 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,.....). ngs.compliancetesting@wellpoint.com

11. 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). ngs.compliancetesting@wellpoint.com

12. 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. ngs.compliancetesting@wellpoint.com

13. 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. ngs.compliancetesting@wellpoint.com

14. 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. ngs.compliancetesting@wellpoint.com

15. 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. ngs.compliancetesting@wellpoint.com

16. Small Provider Checklist Feedback #3 • Might want to add a section toperform 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) ngs.compliancetesting@wellpoint.com

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

18. Questions ? ngs.compliancetesting@wellpoint.com

19. 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 ngs.compliancetesting@wellpoint.com

20. 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

21. 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