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, Inc. April 18, 2013 10:30 AM – 11:30 AM, EST

2. Welcome Industry Collaborative Partners Presenters: Julie McBee, BA/POE David Carrier, Lead BA Dean Cook, Advisor/SME If you are having difficulty viewing the presentation, try changing the monitor resolution to 1280 x 1024 size. To download the draft versions of the checklists, visit the CMS End-to-End Testing web page at http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/End-to-End-Testing.html.

3. Agenda • Welcome and attendance • Opening remarks • Definitions • From the mailbox • Ballot questions and comments • Noblis/Ketchum/NGS content comparison • April 4 Session Homework Review • Transaction vs. Process Flows • Open Discussion • April 18 Session Homework Assignment • Test Scenarios • Questions • Closing remarks

4. Opening remarks

5. Industry Collaborative Partners (ICPs) • 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 * One partner; two divisions

6. 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. • All participants are asked to listen to and value all contributions equally. We are trying to make sure this is a collaborative effort where all industry voices can be heard. • We value your time so please keep your discussion focused. • We will be opening the call for each contributor to speak for up to 3 minutes. We will let you know when you are at 2 and 2:30 minutes to allow you to finalize your comments. • Silence equals agreement.

7. 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 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 industry testing of future standards, leading to more rapid adoption of the future standards.

8. Intended outcomes The intended outcome of the pilot is: • To provide documents and artifacts to all industry segments outlining the critical check-points needed to ensure compliance with the current and 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

9. Pilot overview • Phase I – Business and Gap Analysis started on September 24, 2012, and ran through December 21, 2012. Complete. • 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. We are here.

10. Definitions

11. Definitions • It was requested that we provide a definition of “covered entity” on the Definitions tab of the checklists. This is the definition we created. It will be added to the Definitions tab of all the checklists. • Covered entity • While every organization may not be deemed a covered entity per the Administrative Simplification standards, we highly recommend participants consider using this checklist as a guide in assisting their organization through the process of end-to-end testing in order to meet the end date of regulation changes and aiding in keeping system(s) current.

12. Definitions Comments 4/18/2013 • .

13. From the mailbox

14. From the mailbox These are comments from the most recent survey. • For all checklists: • On Initial Assessment Tab - A critical question is missing regarding: Has this business completed implementation of ACA-mandated HIPAA CAQH CORE Operating Rules Version X.X.X for HIPAA transactions? The URL for obtaining these operating rules is www.caqh.org. This information has been added to the Initial Assessment tab. • On Administrative Simplification Tab - Missing key/critical task re obtaining updated publications and tools such as the CAQH CORE Operating Rules Gap Analysis and Planning Tool. The URLs for obtaining these tools are http://www.caqh.org/ORMandate_Eligibility.php and http://www.caqh.org/ORMandate_EFT.php. This information has been added to the Administrative Simplification tab. • On ACA Tab - Missing reference to the required CAQH CORE infrastructure rules, such as connectivity, response time, system availability. This information has been added to the Administrative Simplification tab which now combines ACA and Administrative Simplification.

15. From the mailbox This information is actually from the most recent survey. • Huge program affecting multiple areas; concerned about payers readiness. • Put more ownership on all parties to meet regulations, concerned if payers don't update how will that affect our Providers revenue? • Some direction on who should drive the bus for the full E2E. For example, if Health Plans must be the entity to certify to CMS that they are compliant, should they be driving the E2E integration testing process once the individual pieces (vendors, payers, providers) are ready?

16. From the mailbox Comments 4/18/2013 • .

17. Ballot questions and comments

18. Ballot questions and comments • Emdeon approves these checklists as comprehensive and generally representative of key testing activities. However, we do not feel the Level 2 and Level 3 checklist activities can be scaled to support the volume of Trading Partners for an organization like Emdeon. Our pilot needs a bit more clarification on what changes you think need to be added or deleted. • A minor comment would be to add a definition of “Covered Entities” and “Trading Partners” in the front section.  A covered entity is explained in G.1 in the small physician spreadsheet, but an overall definition in the Definitions section would be helpful those not familiar. “Covered entity” has been added to the Initial Assessment, Lessons Learned/Notes section and to the Definitions tab. Will add to Definitions if it benefits users. • Another suggestion is to consider providing a visual map of critical steps to make these steps seem less tedious, especially for the smaller practice. After viewing the visual flows, is there still a flow needed? • If helpful, the various URLs to AMA’s ICD-10 materials is www.ama-assn.org/go/icd-10 and 5010 resources is www.ama-assn.org/go/5010 . Will add links where applicable.

19. Ballot questions and comments • I have reviewed the “vendor-to-payer” detailed spreadsheet and have a considerable number of concerns.  First, the “covered entity” checklist is confusing.  Even if the vendor is not a covered entity, they should be looking at how up to date they are.  We are adding Lessons Learned/Notes entry on Initial Assessment to explain “covered entity” and recommend using the checklist for tracking whether covered or not. • Looking at Task 3.6 under Level 2, I don’t see how we expect vendors to complete a minimum of two cycles with “each” trading partner.  A representative sample should suffice. Adding consistent and standard verbiage to state that it is with the determined mission-critical trading partners on all checklists in all areas where applicable.

20. Ballot questions and comments Comments 4/18/2013 • .

21. Noblis/Ketchum/NGS content comparison

22. Noblis/Ketchum/NGS content comparison CMS requested that NGS review the various ICD-10 materials produced and distributed by Noblis/Ketchum to locate consistencies and inconsistencies. In the case of inconsistencies, NGS was requested to address its findings. NGS has only one recommendation for the Noblis/Ketchum materials. The definitions of “levels” in their documents do not align with those on the NGS checklists, especially “Level 3”. NGS recommends that Noblis/Ketchum update their documents to include the “Level 3” definition. Small/Medium Provider • Noblis/Ketchum include project management and project plan development information in their implementation guide. NGS is not developing or instructing development of a project management plan or template. • Noblis/Ketchum include a list of the types of providers impacted by ICD-10. NGS does not include such a list, but lists those that constitute small and medium providers who should employ the checklists.

23. Noblis/Ketchum/NGS content comparison Small/Medium Provider (continued) • Noblis/Ketchum explain about using the 5010 format. NGS includes item in the Initial Assessment about 5010 compliance. NGS will update checklists to include the ICD-10 implementation date in conjunction with 5010 compliance on all checklists. • Noblis/Ketchum compare the ICD-9 format to the ICD-10 format. NGS does not provide this information, but links to websites are provided where this information is available. • Noblis/Ketchum defines small physician as 1 – 5 physicians, single specialty or multi-specialty, but does not mention staff numbers. NGS defines similarly. • Noblis/Ketchum defines medium practice as 6 to 20. NGS will alter from 6 to 24 to 6 to 25. • Noblis/Ketchum timelines are more refined and defined. NGS timelines are guidelines and not intended to be a building block for a project plan. • Noblis/Ketchum includes timeline entry for training of coders. NGS includes a Task (2.2) about training and links to associations like AAPC (Task 1.2). • Noblis/Ketchum includes development of a Communication Plan. NGS will add this task to all of the High Level Checklists. It is already listed as one of the plans to be developed in the detailed checklists.

24. Noblis/Ketchum/NGS content comparison Small/Medium Provider (continued) • Noblis/Ketchum materials contain information that would serve the users of the checklists for development of communication, training, and risk management plans. NGS will add links to the appropriate Noblis/Ketchum materials on all detailed checklists. • Noblis/Ketchum implementation guides include definitions for the various types of testing. NGS will add links to the Noblis/Ketchum implementation guides rather than the Wikipedia links already included in the NGS checklists.

25. Noblis/Ketchum/NGS content comparison Large Provider • The Noblis/Ketchum implementation guide includes historical and implementation information about ICD-9 and ICD-10. NGS includes links to various websites where such information can be obtained. • Noblis/Ketchum include a list of the types of providers impacted by ICD-10. NGS does not include such a list, but lists those that constitute large providers who should employ the checklists. • Noblis/Ketchum defines large practice as 25 or more physicians. NGS defines similarly. • Noblis/Ketchum timelines are more refined and defined. NGS timelines are guidelines and not intended to be a building block for a project plan. • Noblis/Ketchum phases do not match NGS Elements completely. Noblis/Ketchum has Communication and Awareness, Assessment, Operational Implementation, Testing, and Transition. NGS usesPlanning, Assessment, Design, Development, Testing, and Transition. • Noblis/Ketchum materials contain information that would serve the users of the checklists for development of communication, training, and risk management plans. NGS will add links to the appropriate Noblis/Ketchum materials on all detailed checklists.

26. Noblis/Ketchum/NGS content comparison Payer • The Noblis/Ketchum implementation guide includes historical and implementation information about ICD-9 and ICD-10. NGS includes links to various websites where such information can be obtained. • Noblis/Ketchum timelines are more refined and defined. NGS timelines are guidelines and not intended to be a building block for a project plan. • Noblis/Ketchum materials contain information that would serve the users of the checklists for development of communication, training, and risk management plans. NGS will add links to the appropriate Noblis/Ketchum materials on all detailed checklists. • Noblis/Ketchum implementation guide goes into detail about ICD-10 clinical documentation. NGS checklists have tasks to identify impact to business processes and provides links to the CMS ICD-10 web page.

27. Noblis/Ketchum/NGS content comparison Vendor • Only timeline and checklist materials are available from Noblis/Ketchum for vendors. However, NGS offers links to websites for information about ICD-10 from other sources such as CMS, other agencies, and national associations. • Noblis/Ketchum timelines are more refined and defined. NGS timelines are guidelines and not intended to be a building block for a project plan. • Noblis/Ketchum materials contain information that would serve the users of the checklists for development of communication, training, and risk management plans. NGS will add links to the appropriate Noblis/Ketchum materials on all detailed checklists.

28. Noblis/Ketchum/NGS content comparison Comments 4/18/2013 • .

29. April 4 session homework review

30. Transaction versus process flows

31. Transaction versus process flows

32. Transaction versus process flows Comments 4/18/2013 • .

33. April 18 session homework assignment

34. Test scenarios • The test scenarios will be added to the detailed checklists as a fifth tab. • The test scenarios tab information will be emailed to you for your review. We will discuss it during the April 25 session. • If you have questions or comments prior to the April 25 session, send them to the ngs.compliancetesting@wellpoint.com mailbox.

35. Questions?

36. Closing remarks

37. Upcoming webinars . • The Listening Session webinars are open to everyone who wants to attend. • To request an invitation, the attendee must send contact information to the ngs.complaincetesting@wellpoint.com mailbox. • Each session is limited to 100 participants. • As sessions fill up, additional sessions will be offered. • Complete schedule for May Listening Sessions coming soon!

38. Upcoming webinars .

39. Upcoming webinars . • The ICP webinars continue through April. • Complete schedule for May ICP webinars coming soon!

40. More information • Listening Sessions To register for continuing Listening Sessions, send us an email with your contact information to ngs.compliancetesting@wellpoint.com. • CMS ICD-10 web page located at http://www.cms.gov/Medicare/Coding/ICD10/ • CMS End-to-End Testing web page located at http://www.cms.gov/Regulations-and-Guidance/HIPAA-Administrative-Simplification/Affordable-Care-Act/End-to-End-Testing.html has links to all the checklists. • NGS WEDI End-to-End Testing Checklist presentations are available at http://www.wedi.org/forms/meeting/MeetingFormPublic/view?id=220AC00000156

41. Contact us • Send questions to ngs.compliancetesting@wellpoint.com • Our goal is to acknowledge all emails within one business day • Additional contact resources . . .