Transmittal Letter (rfp 1)

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Phase 1: Full Impact and Gap Analysis (RFP 3.2.2)

FOX understands that the implications and effort it will take to complete a full impact and gap analysis for the IME. This section details that understanding, describes the FOX approach to NPI and how it corresponds to this RFP, presents a brief overview, the FOX Process Framework, Project Kickoff process, and then RFP Key Activities for Medicaid policies, systems, interfaces, and business processes.

The FOX Approach

The overall purpose of HIPAA and the NPI is to improve the Medicare and Medicaid programs, and the efficiency and effectiveness of the health care system, by encouraging the development of a health information system that features standards and implementation specifications to facilitate the electronic transmission of certain health information. To help accomplish this goal, HIPAA mandates the adoption of the NPI by every health care provider that conducts standard HIPAA electronic transactions.
FOX’s impact and gap analysis methodology is designed to help state Medicaid agencies upgrade or modernize existing systems to process the HIPAA NPI. Our approach to the NPI issue has three phases, as depicted in the following figure:

Figure 3: FOX’s Approach to NPI

Figure 3 has been redacted.

These phases correlate to the IME phases in the following way:

Table 1: Comparison of Approach

Iowa Medicaid Enterprise Approach	FOX NPI Approach
Full Impact and Gap Analysis (RFP 3.2.2.1, 3.2.2.2, 3.2.2.2.1, and 3.2.2.3) FOX understands that this phase involves a complete review of Medicaid policies, systems, interfaces, and business processes. Matrices will be developed that identify the NPI impacts and Gap Analysis Reports that detail the gaps that exist for IME. These matrices and reports will be used to select the appropriate Remediation Strategies.	Impact Assessment The Impact Analysis phase provides clear and specific answers which enable management to develop budgets, determine conversion priorities, and develop a strategy to solve problems associated with the implementation of the NPI requirements. Systems, business processes, and appropriate documentation are analyzed in detail to give a complete picture of the remediation effort needed to comply with NPI. This parallels the IME ‘Full Impact and Gap Analysis’ approach required in this RFP.
Remediation Strategies (RFP 3.2.3.1, 3.2.3.2, and 3.2.3.3) FOX understands that this phase involves the presentation of recommended remediation strategies, with accompanying cost/benefit analyses, for the Medicaid policies, systems (including coding, interfaces and business rules), and business processes within IME.	Planning The Planning phase defines specific logical “units-of-work” for application modification, based on the output of the Impact Analysis phase, which should enable remediation activities to begin immediately. This approach allows the information technology and executive management to understand and support the entire implementation process early in the cycle without delaying opportunities to begin actual code and dataset modifications. The NPI Planning phase identifies project goals and objectives, prepares a detailed implementation work plan, identifies a conversion plan (if necessary), and schedules the project from pilot to completion. This relates to the IME ‘Remediation Strategies’ in that remediation options are presented along with cost benefit analyses of each option. This also ties into the IME ‘Implementation Tasks’ phase in that the work plan is developed that plans out the entire remediation effort, with regard to the business processes, the Medicaid policies, and the systems.
Implementation Tasks (RFP 3.2.4.1, 3.2.4.2, 3.2.4.3 and 3.2.4.4) For IME, this phase includes the development of detailed work plans for the remediation strategy chosen for the Medicaid policies, systems, and business processes. These must all be coordinated to ensure fluidity, consistency, and harmony in the overall remediation effort. In addition, an APD is developed in order to be submitted to CMS for the purpose of obtaining enhanced funding for the remediation of Medicaid systems and processes due to NPI.	Remediation Finally, the Remediation phase manages and implements the required changes in a structured, systematic manner that has been documented in the Planning phase. This is the ‘Implementation Tasks’ of IME’s approach. The IME has separated the tasks of analyzing Policies, Systems, and Business Processes. While FOX will develop the RFP deliverables accordingly, and in line with the Department approved work plan, FOX will not analyze each Key Activity in a vacuum. The policies are tied to the business processes, which are tied to the various systems.

FOX’s NPI approach is built on a foundation of core components that can be customized to accommodate the IME structure and environments. Each phase is designed to support the requirements of the next. This approach gives IME the ability to effectively identify the extent of changes necessary to implement the NPI in all systems that are impacted. These three phases are influenced and guided by the people responsible for the organization, the business processes, and the technological systems.

Overview

The IME NPI analysis, remediation, and implementation will require substantial participation of project team members from within and external to the IME. These stakeholders have a vested interest in how the system is modified without loosing functionality. They may be involved with payment structures, fraud and abuse detection, quality assurance, reporting, budgeting, accounting, etc. The figure below indicates potential internal and external stakeholders and their interests, impacted processes, systems, and programs:

Figure 4: Potentially Impacted People, Processes, Systems, and Programs

Impact for Iowa Providers

The NPI has a significant impact on Iowa providers. FOX has developed a standardized approach to analyzing NPI impacts for both health plans and health care providers. Individual Providers only have one (1) NPI, however, organizations may have more than one. Organizations may opt to have one NPI for all facilities, one NPI per location, one NPI per taxonomy per location, or one NPI per taxonomy across locations. (The provider taxonomy is a unique 10 character alphanumeric code that defines the provider’s scope of practice for use in the standard HIPAA transactions.) IME functions as both a health plan and provider. The decision on how to enumerate subparts is up to the Provider, not the health plan. The IME has two hospital/schools that function as providers: Glenwood Resource Center and Woodward Resource Center. In addition, IME also has four mental health institutions that may need to identify subparts, as well as obtain individual and organizational NPIs: Cherokee Mental Health Institute (MHI), Clarinda MHI, Eldora State Training School, Independence MHI, Mt. Pleasant MHI. Consideration may also be given to the Civil Commitment Unit for Sexual Offenders (CCUSO), located on the MHI campus at Cherokee. There are field service providers that may need to be enumerated as well. The DHS administers services statewide with a central administrative office in Des Moines, eight [8] Service Areas across the state, and local DHS offices in each of the 99 counties, either full time or part time. Potentially impacted areas within the field service areas may include those providers within the Department of Public Health - Division of Substance Abuse, Magellan Behavioral Health, and Service Providers and the Coalition for Family & Children’s Services. While assessment of the provider impact is out of scope for this engagement, it is important to keep in mind that IME will be impacted by how other provider organizations, as well as their own, choose to implement the NPI, particularly as it relates to their subpart designations.

FOX’s Framework

The process framework in the figure below represents a structured process for analyzing any covered entity.

Figure 5: FOX Process Framework

FOX utilizes the FOX Portal Knowledge Repository (Portal) to collaborate and coordinate the NPI Impact Analysis efforts. FOX has developed a number of surveys, interview tools, and system search tools to structure and quantify the effort required to remediate systems to move forward with the NPI transition process. These tools and the results of their use are stored on the Portal.
The surveys and interview tools vary from health plan to health care provider because the needs to accommodate each one for NPI remediation are different. However, all of the tools are stored on and available through the Portal.

Project Kickoff

FOX begins every project with a comprehensive Project Kickoff, where the actual Kickoff meeting represents a culmination of activities that occur beforehand. Through this process, the foundation for the support and management of the NPI impact activities is established.

Figure 6: NPI Kickoff Activities

The project plan for the Impact Analysis phase is finalized, along with resources assignments and the project schedule. A discussion regarding the Success Factors of the project helps to focus on the critical elements of the scope of work, as well as elicit ‘informal’ cultural aspects of the project that may be helpful to avoid any pitfalls or barriers to the analysis. The Project Notebook, internal to FOX, tracks engagement issues, metrics, and financials. Training the Project Team encompasses both the FOX team to issues essential to understanding IME, as well as IME team participants understanding NPI and the tools that will be utilized in the analysis. Refer to Project Management Activities (RFP 3.2.1).

Figure 7: Project and Procedures Coordination

The Project Kickoff defines project roles and responsibilities. The defining of roles and responsibilities ensures that each team member from both FOX and IME know what is expected of them.
The completion of the Project Kickoff process represents a finalization of project management activities and the readiness to begin the data collection and the ‘real work’ of the engagement.

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