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 24, 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 • Definitions Julie McBee • Provider, Payer, Vendor Open Floor 5 minutes • Payer Checklist 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 will run 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)* • 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. 3 High-Level Definitions These 3 definitions for End-To-End, Readiness, and Compliance are considered complete and have been sent for review by CMS Legal. ngs.compliancetesting@wellpoint.com

10. Provider Readiness *Our revised definition is as follows: Provider Readiness is a state of preparedness in which the Provider and the Provider’s business associates have completed internal testing and tested with a Provider-determined percentage** of mission-critical external trading partners. Additionally, the Provider and the Provider’s business associates will have completed internal documentationand established communication mechanisms with external trading partners, training of appropriate personnel, scheduled testing, deployments, and/or software migration for each published standard in advance of, and/or by, and continued support after, the regulatory implementation date. *This is a catalyst for our initial discussions with our Industry Collaborative Partners for establishing a clearly refined definition of Provider Readiness based on Industry feedback and participation on January 22, 2013 webinar. **acceptable risk percentage will vary from Provider to Provider and should be documented in checklist(s) ngs.compliancetesting@wellpoint.com

11. Provider Readiness Depending on the regulation, one or more of the following examples may apply*: • All administrative, analytical, and clinical system upgrade(s) have been completed. (Electronic Healthcare Records (EHRs), Electronic Medical Records (EMRs), and Practice Management Systems) • Confirmation of successful testing with submission payer(s) • Confirmation of successful testing with vendor(s) • Confirmation of successful testing with clearinghouse(s) • Confirmation of successful acceptance of production-like claim(s) (837) submission(s) • Confirmation of successful submission(s) and receipt of response(s) for pharmacy claims using the NCPDP Telecommunication and/or Batch standards • Confirmation of successful return of TA1, 824, 999, 277CA acknowledgement(s) • Confirmation of successful retrieval of the claim(s) associated remittance(s) (835) • Confirmation of successful acceptance of claim(s) status inquiry submission(s) (276) • Confirmation of successful return of claim(s) status inquiry response(s) (277) • Confirmation of successful receipt of claim(s) eligibility status request(s) (270) • Confirmation of successful return of claim(s) eligibility status(es) (271) • Confirmation of successful submission(s) of service(s) review inquiry(ies) (278) • Confirmation of successful receipt of service(s) review response(s) (278) *this list is not all-inclusive ngs.compliancetesting@wellpoint.com

12. Payer Readiness *Our revised definition is as follows: Payer Readiness is a state of preparedness in which the Payer and the Payer’s business associates have completed all internal testing and tested with a Payer-determined percentage** of mission-critical external Trading Partners. Additionally, the Payer and the Payer’s business associates will have completed internal documentation and established communication mechanisms with external trading partners, training of appropriate personnel, scheduled testing, deployments, and/or software migration for each published standard in advance of, and/or by, and continued support after, the regulatory implementation date. *This is a catalyst for our initial discussions with our Industry Collaborative Partners for establishing a clearly refined definition of Provider Readiness based on Industry feedback and participation on January 22, 2013 webinar. **acceptable risk percentage will vary from Payer to Payer and should be documented in checklist(s) ngs.compliancetesting@wellpoint.com

13. Payer Readiness Depending on the regulation, one or more of the following examples may apply*: • All administrative, analytical, and clinical system upgrade(s) have been completed • All system upgrades (front-end translations and back-end adjudication systems) have been loaded and tested • Confirmation of successful testing with submitting provider(s) • Confirmation of successful testing with submitting vendor(s) • Confirmation of successful testing with clearinghouse(s) • Confirmation of successful acceptance of production-like claim(s) (837) submission(s) • Confirmation of successful receipt of submission(s) of return of response(s) for pharmacy claims using the NCPDP Telecommunication, Batch, and/or Subrogation standards • Confirmation of successful return of TA1, 824, 999, 277CA acknowledgement(s) • Confirmation of successful retrieval of the claim(s) associated remittance(s) (835) • Confirmation of successful acceptance of claim(s) status inquiry submission(s) (276) • Confirmation of successful return of claim(s) status inquiry response(s) (277) • Confirmation of successful receipt of claim(s) eligibility status request(s) (270) • Confirmation of successful return of claim(s) eligibility status(es) (271) • Confirmation of successful submission(s) of service(s) review inquiry(ies) (278) • Confirmation of successful receipt of service(s) review response(s) (278) • Confirmation of successful submission(s) of payment order(s) or remittance advice(s) (820) • Confirmation of successful receipt of payment order(s) or remittance advice(s) (820) • Confirmation of successful receipt benefit enrollment(s) (834) • Confirmation of successful return of benefit maintenance(s) (834) *this list is not all-inclusive ngs.compliancetesting@wellpoint.com

14. Vendor Readiness *Our revised definition is as follows: Vendor Readiness is a state of preparedness in which the Vendor and the Vendor’s business associates have completed internal testing and tested with a Vendor-determined percentage* of mission-critical external trading partners. Additionally, the Vendor and the Vendor’s business associates will have completed internal documentation and established communication mechanisms with external trading partners, training of appropriate personnel, new/change processes, scheduled testing, deployments, and/or software migration for each published standard in advance of, and/or by, and continued support after, the regulatory implementation date. *This is a catalyst for our initial discussions with our Industry Collaborative Partners for establishing a clearly refined definition of Provider Readiness based on Industry feedback and participation on January 22, 2013 webinar. **acceptable risk percentage will vary from Vendor to Vendor and should be documented in checklist(s) ngs.compliancetesting@wellpoint.com

15. Vendor Readiness Depending on the type of vendor your organization is and the regulation change, one or more of the following examples may apply*: • All administrative, analytical, and clinical system upgrade(s) have been completed • All system upgrades (front-end translations and back-end adjudication systems) have been loaded and tested • Confirmation of successful testing of analytics (reporting) • Confirmation of successful testing with submitting provider(s) • Confirmation of successful testing with submitting payer(s) and/or vendor(s) • Confirmation of successful testing with clearinghouse(s) • Confirmation of successful acceptance of production-like claim(s) (837) submission(s) • Confirmation of successful submission(s) and/or response(s) for pharmacy claims using the NCPDP Telecommunication, Batch, and/or Subrogation standards • Confirmation of successful return of TA1, 824, 999, 277CA acknowledgement(s) • Confirmation of successful retrieval of the claim(s) associated remittance(s) (835) • Confirmation of successful acceptance of claim(s) status inquiry submission(s) (276) • Confirmation of successful return of claim(s) status inquiry response(s) (277) • Confirmation of successful receipt of claim(s) eligibility status request(s) (270) • Confirmation of successful return of claim(s) eligibility status(es) (271) • Confirmation of successful submission(s) of service(s) review inquiry(ies) (278) • Confirmation of successful receipt of service(s) review response(s) (278) • Confirmation of successful submission(s) of payment order(s) or remittance advice(s) (820) • Confirmation of successful receipt of payment order(s) or remittance advice(s) (820) • Confirmation of successful receipt benefit enrollment(s) (834) • Confirmation of successful return of benefit maintenance(s) (834) *this list is not all-inclusive ngs.compliancetesting@wellpoint.com

16. Payer Checklist Feedback • Assessment • Overall • Holly - Did we discuss or are we going to include, dates of milestone to accomplish varies steps? We're discussing it internally. • Level 1 • Element: Design • Rich Cuchna-Comment on Reason code on why a claim was adjusted or not paid…. did we leave out Group/Remark codes? They are there. • Element: Testing • George Arges-All items are fine, but should we add another piece at the end about Test Plan having a mgmt. report that summarizes the volume success of the test; which items passed, which items failed? Pinpoint the volume of the success, where the failure occurred. That could be rolled into Best Practice later on. Good question, will consider it. • Debbie-Have we defined “mission-critical” yet? It has been mentioned as Provider and Payer defined mission-critical. Suggested that we used terminology “mission-critical” but we did not define it. Do we need to do that for better comprehension? • Shawn Turner-This is a universal framework…we can define in a number of ways, but we looked at high dollar/high volume/critical footprint. Changes depending upon the delivery. Could be partner or claim data from payer perspective. Not sure how critical it is. We could add disclaimer on what we mean by mission critical. ngs.compliancetesting@wellpoint.com

17. Payer Checklist Feedback #2 • Level 1 (continued) • Element: Testing • George-Mission Critical should be something each org will have to approach and identify if there is a disruption, what will cause the most problem to operations? Where it's cash flow or day to day production it doesn't need to be very critical. Maybe can be mentioned on the WEDI presentation. • Element: Transition • Holly-Likes the detail, it’s critical for coding. We may want to consider recommended dates because if there are significant problems there, we need time for remediation so they can have time to fix errors. • Level 2 • Element: Testing • Shawn Turner-Runs prior to E2E with no defects….you may find defects that are cosmetic or unrelated to E2E in other areas. Statement may not be black and white in 2.11. We could say “two successful” external tests but we may still have external issues. 2.11 - Has concern where it says “complete internal tests without issues”. • Level 3 • No comments ngs.compliancetesting@wellpoint.com

18. Questions ? ngs.compliancetesting@wellpoint.com

19. Closing Remarks • Next ICP webinar session is Tuesday, January 29, 2013 from 10am to 11am EST • ICD-10 website http://www.cms.gov/Medicare/Coding/ICD10/index.html?redirect=/ICD10 • Listening Sessions have begun: • Participants can join via a CMS website link. Below is the link for those sessions. http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/index.html ngs.compliancetesting@wellpoint.com

20. Suggested Audience for Listening Session Definitions Small Providers will include 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 will include 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 will include organizations comprised of Commercial, Medicaid, Medicare, Pharmacy Benefit Management (PBM), and Workers Compensation Government Contractors. Vendors will include 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