Transmittal Letter (rfp 1)
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Key Activity: Review Medicaid Policies for Impacts of NPI Compliance (RFP 3.2.2.1)Key Activity: Review Medicaid Policies for impacts of NPI compliance Contractor Responsibilities:
Deliverables:
Performance Measures:
Key ActivitiesThe IME has done significant work as a result of implementing MITA principles in the enterprise. IME’s business process model addresses IME operational procedures manuals, which will aide in FOX’s assessment in the development of the matrix which lists each Medicaid policy and the NPI impact on that policy. Because DHS is the single State agency responsible for the administration of the Iowa Medicaid program, and the responsibilities are dispersed within several Divisions, policies related to these Divisions will be reviewed for NPI impact. Policies will also be reviewed for NPI impacts related to the MMIS vendors and system/application interfaces between the many partners in IME. In addition, IME may want take into consideration the Medicaid policies that deal with select Medicaid-related contractors, such as the Iowa Foundation for Medical Care (IFMC), who provides prior authorization for transplantation and other medical procedures, and conducts long-term care facility utilization and quality reviews, and supports the SURS member analysis functions. There may be NPI impacts relative to the use of the 278 prior authorization and referral transaction and reports generated by the Fiscal Agent to IFMC containing monthly paid claims files to support its research and analysis. Contractor ResponsibilitiesFOX has extensive experience in reviewing policies and conducting gap analyses. The FOX team will review Medicaid policies, identify specific impacts of the NPI on those policies, and identify gaps within the policies relative to the NPI. DeliverablesFOX will create a matrix listing each Medicaid policy and the NPI impacts on each for the following:
FOX also will develop a Gap Analysis Report that identifies any gaps in the Medicaid policies relative to NPI. Performance MeasuresThese deliverables will be submitted in accordance with the dates in the Department approved work plan. Key Activity: Identify and Review Medicaid Systems for Impacts of NPI compliance (Attachment 8) (RFP 3.2.2.2)Key Activity: Identify and review Medicaid Systems for impacts of NPI compliance (Attachment 8). Systems include:
Contractor Responsibilities:
Deliverables:
Performance Measures:
Key ActivitiesFOX recognizes that IME has gone to great length to begin the journey toward “MITA-sizing” the IME in configuring the technical environment according to business needs for operational efficiency, and using flexible, adaptable modularity. FOX will undoubtedly find the IME’s MITA self assessment helpful in examining the documentation of the various Medicaid Systems for impacts of NPI compliance. FOX will review each system, validate its completeness, and validate the most recent version of the MMIS business rules. Specific impacts of NPI to each system, as well as gaps within each system, will be identified at the code level. 
Figure 8: Health Plan Impact Assessment Methodology The Inventory Systems Survey determines all of the systems in use at IME by having each subsystem owner complete the survey. For IME, NPI will impact the MMIS, TXIX, Medicare Buy-in System, ISIS, IABC, ELVS, Dakota Imaging System, IME Web Portal, MQUIDS, Medicaid Data Warehouse, and OnBase Workflow Process Management System. FOX then compiles the surveys into a single spreadsheet that populates the NPI Inventory Report. Care must be taken to ensure that IME identifies all of the systems/applications that are applicable to provider identification, including those that are small, homegrown, or specific use only. This inventory may have been completed to comply with Security provisions of HIPAA, but if not, this is a critical opportunity. Excessive use of non-traditional systems/applications may present business process re-engineering opportunities. Once the Inventory Systems Survey is completed, it is necessary for FOX systems to collaborate with IME staff to determine which of these identified systems are necessary to search for potential remediation. Contractor ResponsibilitiesFOX understands that this key activity requires a review of Medicaid systems, including a validation of the completeness of identified systems, a validation of the most recent version of MMIS business rules, the compilation of systems as necessary, and identification of specific impacts of NPI to the systems at the code level, as well as a gap analysis within the systems relative to NPI at the code level. FOX may advise that all systems should be searched; however, the IME staff may determine that some do not require search or remediation, or they may determine to conduct this operation internally for some of the systems. The result of this process is an inventory of essential systems/applications determined by the IME staff to be part of the scope of the engagement. An example of what an inventory might look like for an MMIS system is found in the figure below: Figure 9: Sample of System Inventory Results Survey for MMIS Program: Name: Email: Phone:
The systems and applications identified as impacted by NPI must be defined further by the use of the Application Survey. This survey is completed by the individual responsible for the named system or application, or during interviews with these people. It determines the platform for the system, the uses of the system, the use of historical data, and the existence of interfaces or Commercial Off The Shelf (COTS) products involved with the system/application. The last few questions of the application survey are intended to prompt the IME staff regarding potential new issues soon to confront IME, such as alignment with the Medicaid Information Technology Architecture (MITA) vision and strategic planning, as well as compliance efforts related to the potential mandates of the National Plan Identifier, ICD-10, or Claims Attachments. While none of these new issues are required at this point, IME must plan for their arrival and may choose to address certain key issues while they conduct their NPI Impact process. There is one survey for each application that the IME staff and FOX identify as needing in-depth review from the System Inventory. A very brief example of the Application Survey is provided on the following page. Figure 10: Application Survey Sample General 2. What is the status of this application? (a) The application is slated to be ELIMINATED before May 27, 2007 (b) The application will be REPLACED with a new package or re- written before May 27, 2007 (c) The application is critical and must be prioritized for NPI remediation 2.1. If (b) or (c), what Platform (e.g. Mainframe/Client-Server) and Programming Language (e.g. COBOL/390/C++/Java) are used in this application? ____________________________________________________________ ____________________________________________________________ 2.2. Is this application a COTS product? YES NO 2.2.1 What is the COTS product? ___________________________________ 2.3 Are there any COTS products integrated into this application? YES NO 2.3.1 What is the COTS product? ___________________________________ 3. If this application is a COTS product, is the source code available for all programs in the application? YES NO Processing Logic 1. Does this application currently handle the processing of HIPAA Transactions? YES NO 2. Does the application execute a SORT on the Provider ID field(s)? YES NO 2.1. If YES, is the SORT internal to the programs or an External Process step? Internal External 2.1.1. If External, what SORT package is used? _______________________ 3. Are there any special processing that is done by the application based on any portion of the Provider ID field? YES NO 3.1. If YES, describe: __________________________________________________________________ __________________________________________________________________ The results of the Inventory Systems Survey and Application Survey are compiled into the FOX NPI Inventory report listing the systems and subsystems considered as part of the scope of the project and the specifics of the systems. This information will go into the Matrix and Gap Report as fulfillment of the deliverables for this Key Activity. The text of the report may indicate some descriptions of the systems represented and begins a look at the breadth and complexity of the issue. This report also depicts the impending new requirements and IME’s preparedness to address those issues. The Inventory Report may be represented graphically, as depicted in the figure below, or in tabular format as depicted in the sample Inventory Report on the following page. Figure 11: System by Component and Count 
Figure 12: NPI Inventory Report
After completion of the Systems Inventory Survey and the Application Survey, a more intense search is conducted. Data DictionaryThe data dictionary is critical to locating all iterations of the provider number within all of the systems identified by IME. Preliminary work on determining the identification of provider number indicates that many systems use many forms of the provider locator. Some examples include: provider number, prov no, prov num, prov id, phys no, etc. Each search of systems will encounter some new versions which will be added to the IP (Intellectual Property). IME system subject matter experts will also have ideas of how the concept of provider identifier is displayed within their systems. The data dictionary may vary from IME Division to IME Division. The best places to start collecting the keywords are:
Based upon the IP from FOX and the interviews with the various IME staff, a Data Dictionary is developed for use to search the IME systems/applications for instances of ‘Provider Identifiers’. Using automated search tools, each system/application is searched for all occurrences of provider identifiers. This search may need to occur several times in order to capture all of the modifications and nuances of the IME system’s coding of provider identifiers. Concurrently, FOX conducts a manual search of the Copy Books to determine how occurrences of provider identifiers have been altered over time or migrated to other systems. Any new iterations of ‘provider identifier’ are added to the Data Dictionary for use in scanning systems and will be considered part of the intellectual property for this project Table 2: Partial Sample Data Dictionary
Use the Data Dictionary to Search ApplicationsThe search/scan tool is one of the most important tools to assess the NPI Impact. Using the Data Dictionary developed so far, the initial search of the systems/applications is conducted using an automated search tool. Each system may need to be searched more than one time, since each search will produce more variations on the provider number concept. The system/application search will determine the systems impacted, the number of data names impacted, and the lines of code impacted by provider number. FOX then examines the impacted codes listed by the search tool and verifies whether the data has been moved TO or FROM the keyword to some other keywords. Those words are also included in the Data dictionary (e.g. MOVE WS-HOLD-PROV-NO TO PR-REFER-PROV. Here, include PROV-NO as well as REFER-PROV to the Data dictionary). FOX assures that the keyword contains enough characters to uniquely identify the Legacy Provider ID (e.g.: If we use just PROV, the search tool might extract PROV-NAME or PROV-ADDR1 or DATE-APPROVED). FOX uses a keyword like PROV-NO or PROV-NUM to extract Provider ID. There is no need to include all the different field names as keywords that contain a string to uniquely identify a key word (e.g. instead of listing WS-PROV-NO or A-PROV-NO or A-PAY-TO-PROV-NO, just include PROV-NO). Alternatively, FOX may also utilize the following tools that are already at the IME site (options 1 thru 4 below) to scan all of the mainframe libraries:
In addition, other options may be exercised using existing options at the IME site:
Manually Search the Copy Books for Processes that Reference Provider IdentifiersManually searching the copy books for processes that reference various provider identifiers is labor intensive, but is necessary to ascertain whether the provider identifiers have migrated to different locations under different names. This process may also determine the interrelatedness of various systems. One system may seek information regarding providers from another system, but may reference the identifier differently. Similarly, one system may transfer data to another system using terms not previously located in the data dictionary. The result of this process will be details of processes affected by provider identifiers. FOX also searches the copybooks for ‘Redefine’d field names. It is a common to practice to initially define a field name or set of field names, and in the following line ‘Redefine’ the initially defined fields and use it to store some other data. If the Provider ID field was expanded, then FOX searches whether those fields were redefined in a later version of a previous line. If so, then FOX expands the redefined fields accordingly. In addition, rather than listing the Provider Id fields alone, FOX documents the record name defined in the copybook (that uses Provider Identifier). In certain cases, instead of writing commands to move fields one by one, sometimes the program moves all the fields at once by moving the entire record. Again, if FOX decided to expand the Provider Id field, and the program moves the record, FOX documents the record name(s) that receives data and make to sure to expand that record too. Based on the gathered information through ‘Application Inventory’ and ‘Application Survey’ and system search/scan, FOX prepares the following reports:
NPI Impact AnalysisAll systems identified by IME will be scanned using the Data Dictionary and search tools that are part of the FOX resources. The IME will be provided the full scope of the scan conducted, and will be included in the NPI Impact Analysis. This analysis indicates the number of systems impacted by provider identifier issues as well as the number of lines of code contained in those systems and the number of lines of code impacted by provider identifier. This analysis establishes the depth of the problem and supports recommendations for the resources required to remediate the problem. The NPI Impact Analysis will be represented in tabular and graphic format and will be presented to the IME as a prelude to recommendations for remediation. Table 3: Sample NPI Impact Summary
F  igure 13: Sample Impact by Subsystem Graph - Number of Lines
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