Phase 2: Remediation Strategies (RFP 3.2.3)
FOX understands that the implications and effort it will take to move from a comprehensive gap analysis to appropriate remediation strategies for the IME. This section details the FOX approach to remediation strategies for Medicaid policies, systems, and business processes.
Overview
FOX begins the Remediation Strategies phase with a Management Assessment. This assessment measures the availability of an organization’s commitment and support to the remediation phase of the project. The projects’ success will not be realized without critical support from the management.
-
Commitment to NPI implementation
-
Funding for NPI implementation
-
Personnel resource management
The management assessment will determine which personnel from the IME staff are assigned to the project, their availability, and the management commitment to their work on the project. Although funding may be determined by the contract with FOX, it is important to discern the funding available within IME for the remediation efforts. If IME has very limited funding, or has not determined any funding, the assessment and the various remediation strategies may be compromised. The following table should be completed in the early phases of the project.
Table 5: Example of IME's NPI Team Logistics
Name
|
Expertise
|
Available Time/Week
|
Length of Time
Assigned to Project
|
Jane Doe
|
Business knowledge
|
10 hours
|
First 10 weeks
|
John Doe
|
Application expertise
|
20 hours
|
Full project – 15 weeks
|
|
Data expertise
|
40 hours
|
Full project – 15 weeks
|
|
Provider identifier expertise
|
10 hours
|
First 5 weeks
|
|
Testing expertise
|
40 hours
|
Last 5 weeks
|
|
Change management expertise
|
20 hours
|
Full project – 15 weeks
|
In addition to the ‘Application’ experts having a clear picture of what compromises their applications, the following tasks highlight some of the benefits that will be realized as a result of the NPI Impact project.
-
IME will have created an enterprise structure for the Impact project.
-
Program use for provider identifiers will have been identified
-
The systems involved will have been inventoried
-
The applications for NPI assessment will have been identified
Remediation strategies will depend largely on the following factors:
-
The number of systems impacted by the use of provider identifiers
-
The number of code lines impacted by provider identifiers
-
The number of processes impacted by provider identifiers
-
The scheduled maintenance/updating/elimination of the major systems involved
-
The availability of IT maintenance staff employed by the client entity
-
The IME response and remediation to manage HIPAA compliance for Transactions and Code Sets (e.g. system remediation, translator, other)
-
Anticipation of additional remediation efforts related to National Plan ID, ICD-10, Medicare Part D, MITA, etc.
-
Resources, both human and financial, for remediation
-
Risks involved with ineffective or inefficient remediation actions.
Key Activity: Recommend Remediation Strategies for Impact Medicaid Policies (RFP 3.2.3.1)
Key Activity: After completing analysis of Medicaid policies, recommend remediation strategies for all NPI impacted Medicaid policies including but not limited to taxonomy, billing, NPI subparts.
Contractor Responsibilities:
-
Upon completion of policy analysis recommend to the Department any remediation strategies needed to be considered to meet NPI compliance
-
Prepare a cost benefit analysis, comparing the recommended strategies and any other feasible strategies so the Department can compare costs
-
Present recommended strategies to the Department as part of a walk through so the Department has a clear understanding of all possible remediation strategies
Deliverables:
-
A report giving all remediation recommendations for Medicaid policies
-
A cost benefit analysis on each remediation strategy of impacted Medicaid policies
-
A scheduled meeting to walk through recommended remediation strategies
Performance Measures:
-
Report is due no later than noon on May 1, 2006
-
Cost benefit analysis is due no later than noon on May 1, 2006
-
Walk through must be scheduled within 5 days of final report and cost benefit analysis submitted
Key Activities
FOX will have completed a comprehensive analysis of the Medicaid policies in fulfillment of RFP 3.2.2.1, and will use this analysis to recommend remediation strategies for all NPI impacted Medicaid policies, including but not limited to taxonomy, billing, and NPI subparts as they relate to IME. The responsibilities of the Medicaid program are dispersed within numerous Divisions and among several contracting entities. Medicaid policies will impact the smooth transition of these contributing systems and the relationships of these various divisions. Additionally, the policy structure and decisions contained in them will influence the relationship with external providers contributing to Medicaid services and other health plans who comprise trading partners with IME.
Contractor Responsibilities
The FOX team will have reviewed the Medicaid policies, identified specific impacts of the NPI on those policies, and identified gaps within the policies relative to the NPI. This work will be reported in a Policy NPI Gap Analysis Report which will include the full gap analysis as well as the matrix listing each Medicaid policy and the NPI impacts on each. For this key activity, FOX understands that the tasks include recommending remediation strategies needed for NPI compliance, and a cost benefit analysis for each remediation strategy that compares the recommended strategy with other feasible strategies for cost comparison. FOX will explain the recommended strategies in a walk presentation to the Department and allow plenty of time for discussion.
Deliverables
FOX will develop a report giving all remediation recommendations for Medicaid policies based on the Gap Analysis performed during the Impact Analysis Phase. The report will include a cost benefit analysis on each remediation strategy of impacted Medicaid policies. FOX also will deliver a presentation of the recommended remediation strategies in a scheduled meeting of identified stakeholders.
Performance Measures
FOX understands that the report is due no later than noon on May 1, 2006, including the Cost Benefit analysis. The presentation/walk through will be scheduled within 5 days of the final report and cost benefit analysis submission.
Key Activity: Recommend Remediation Strategies for Impacted Medicaid Systems (RFP 3.2.3.2)
Key Activity: After completing analysis of Medicaid systems including coding, interfaces and business rules, recommend remediation strategies for all NPI impacted Medicaid systems including strategies for crosswalking, and current and historical conversions.
Contractor Responsibilities:
-
Upon completion of system, interface and coding analysis, recommend to the Department any remediation strategies needed to be considered to meet NPI compliance
-
Prepare a cost benefit analysis comparing the recommended strategies and any other feasible strategies so the Department can compare costs
-
Present recommended strategies to the Department as part of a walk through so the Department has a clear understanding of all possible remediation strategies
Deliverables:
-
A report giving all remediation recommendations for Medicaid systems
-
A cost benefit analysis on each remediation strategy of impacted Medicaid systems
-
A scheduled meeting to walk through recommended system remediation strategies
Performance Measures:
-
Report is due no later than noon on May 1, 2006
-
Cost benefit analysis is due no later than noon on May 1, 2006
-
Walk through must be scheduled within 5 days of final report and cost benefit analysis submitted
Key Activities
FOX will have completed a comprehensive analysis of the Medicaid policies in fulfillment of RFP 3.2.2.1, and will use this analysis to recommend remediation strategies for all NPI impacted Medicaid policies, including but not limited to taxonomy, billing, and NPI subparts as they relate to IME. The responsibilities of the Medicaid program are dispersed within numerous Divisions and among several contracting entities. Medicaid policies will impact the smooth transition of these contributing systems and the relationships of these various divisions. Additionally, the policy structure and decisions contained in them will influence the relationship with external providers contributing to Medicaid services and other health plans who comprise trading partners with IME.
Contractor Responsibilities
The FOX team will have reviewed the Medicaid policies, identified specific impacts of the NPI on those policies, and identified gaps within the policies relative to the NPI. This work will be reported in a Policy NPI Gap Analysis Report which will include the full gap analysis as well as the matrix listing each Medicaid policy and the NPI impacts on each. For this key activity, FOX understands that the tasks include recommending remediation strategies needed for NPI compliance, and a cost benefit analysis for each remediation strategy that compares the recommended strategy with other feasible strategies for cost comparison. FOX will explain the recommended strategies in a walk presentation to the Department and allow plenty of time for discussion.
Deliverables
FOX will develop a report giving all remediation recommendations for Medicaid policies based on the Gap Analysis performed during the Impact Analysis Phase. The report will include a cost benefit analysis on each remediation strategy of impacted Medicaid policies. FOX also will deliver a presentation of the recommended remediation strategies in a scheduled meeting of identified stakeholders.
Key Activity: Recommend Remediation Strategies for Medicaid Business Processes (RFP 3.2.3.3)
Key Activity: After completing analysis of Medicaid business processes, recommend remediation strategies for all NPI impacted Medicaid business processes including but not limited to provider enrollment/re-enrollment, provider outreach, billing requirement.
Contractor Responsibilities:
-
Upon completion of business process analysis, recommend to the Department any remediation strategies needed to be considered to meet NPI compliance
-
Prepare a cost benefit analysis comparing the recommended strategies and any other feasible strategies so the Department can compare costs
-
Present recommended strategies to the Department as part of a walk through so the Department has a clear understanding of all possible remediation strategies
Deliverables:
-
A report giving all remediation recommendations for Medicaid business processes
-
A cost benefit analysis on each remediation strategy of impacted Medicaid business processes
-
A scheduled meeting to walk through recommended business process remediation strategies
Performance Measures:
-
Report is due no later than noon on May 1, 2006
-
Cost benefit analysis is due no later than noon on May 1, 2006
-
Walk through must be scheduled within 5 days of final report and cost benefit analysis submitted
Key Activity
FOX’s Management Report not only gives remediation options for systems, but ties them into the affected business processes as identified through the Program Questionnaire. FOX understands that the outcome of activities described in this section is a report and cost benefit analysis of recommended remediation strategies for all NPI impacted Medicaid business processes including but not limited to provider enrollment/reenrollment, provider outreach, and billing requirements.
Contractor Responsibilities
FOX will provide IME with recommendations for remediation strategies needed to be able to implement the NPI. FOX will prepare a cost benefit analysis comparing the recommended strategies and other feasible strategies to give IME the opportunity to compare costs. This information will be presented as part of a walk through in order to ensure the Department’s full understanding of the issues.
FOX is familiar with the business processes that states deal with on a daily basis that are greatly impacted by the MMIS and subsystems. Business priorities are identified prior to determining the conversion strategy for the entire project. These priorities are based on the examination of whether an application provides value in one or more predetermined areas. Applications that exhibit higher relative business value are given more priority for early conversion scheduling or for inclusion in conversion strategic planning. Some business priorities are listed below; however the IME may identify others and may choose to rank them.
-
Provider enrollment/reenrollment
-
Provider outreach
-
Billing requirements
-
Maintaining patient services
-
Equitable payment to providers
-
Prompt provider payments
-
Maintaining good provider relationships
-
Accurate data collection
-
Fraud and abuse detection
-
Data comparability over time (current vs. historical)
-
Secure integrity of data exchange
-
Minimizing project costs
-
Minimizing business project disruptions
Deliverable
FOX will develop a report that contains all remediation recommendations for the Medicaid business processes that were identified in the NPI Impact Gap Analysis Report in Phase 1 of the IME engagement. This report will include a cost benefit analysis for each remediation strategy and a reference to the impacted systems associated with those processes. This information will be presented in a walk through of the deliverable.
Performance Measures
FOX understands that the report and cost benefit analysis are due no later than noon on May 1, 2006. In addition, FOX will schedule the walkthrough within 5 days of the submission of the final report and cost benefit analysis.
Phase 3: Implementation Tasks (RFP 3.2.4)
Implementation of the remediation options are of critical importance. FOX understands that implementation is not strictly a linear process with predictable outcomes. Rather, the implementation processes are plagued by contingencies and are personified by organizational dynamics that, due to the complexity of healthcare organizations, cannot always be predicted. Implementation should encompass the changes in business processes, system changes, training, and evaluation in an iterative fashion.
Key Activity: Implementation Work Plan for Medicaid Systems (RFP 3.2.4.1)
Key Activity: After completing analysis and recommendation phases, and once the Department has elected a remediation strategy, lay out an implementation work plan for each Medicaid or Medicaid-related system impacted including all related interfaces of each system.
Contractor Responsibilities:
-
Based on the decisions of the Department for systems remediation, create a work plan for each impacted system and its related interfaces.
-
Include in the work plan key tasks and timelines
-
Obtain Department approval for each of the final work plans
Deliverables:
-
A work plan for each NPI impacted Medicaid or Medicaid-related system and related interfaces
-
A scheduled meeting to walk through to review and obtain approval for all work plans
Performance Measures:
-
Work plans are due 21 calendar days from election of the Department’s remediation strategy
-
Walk through must be scheduled within 5 days of submission of work plans
Key Activities
FOX will have developed an NPI Impact Gap Analysis document and an NPI Management Report from the first two phases of the project. A Work Plan for the chosen remediation option is the next logical step. FOX will develop a work plan for each NPI impacted Medicaid or Medicaid-related system and related interfaces. A walk through of all work plans will be scheduled for approval.
Contractor Responsibilities
The details of the work plan will be fleshed out in the actual analysis; however, a sample of high level contents for the work plan for two remediation strategies that includes key tasks and timelines is provided in the table below.
Table 6: Remediation Strategy One: Recoding of Existing Systems
WBS
|
Timeframe
|
Additional Considerations
|
Transitional Planning
|
Identify uses of provider ID
|
1 month
|
Consider all systems and applications as well as interfaces between systems. Need to consider atypical providers and those who will not get NPIs
|
May or may not allow for dual strategy of legacy providers and NPIs for a period of time.
|
Develop maps and cross walks of all uses of provider IDs
|
1-2 months
|
Legacy number will be exchanged for NPI but new logic will need to be coded in to process correctly
|
Is dual strategy or dual system an option? Consider how to phase various components during transition
|
Recode NPI with maps
|
2-4 months
|
Depends on complexity of uses of legacy provider numbers
|
Parallel systems during recoding time
|
Recode impacted interfaces
|
2-4 months
|
Time depends on numbers of interfaces
|
|
Rewrite technical processes related to coding
|
2-4 months
|
|
|
Develop testing platform
|
1-2 months
|
Testing platform must test system for complexity and volume
|
Dual systems can compare test platform to processed transactions to predict accuracy
|
Test transactions internally
-
837I, P, D
-
NCPDP
-
835
-
276/277
-
270/271
-
278
-
834
|
1-3 months
|
|
|
Test with providers
|
1 month
|
Providers may not have enumerated yet.
|
|
Test COB with other plans
|
1 month
|
Other plans may not be NPI compliant yet.
|
|
Convert DDE systems
|
1 month
|
If DDE systems exist
|
Need to train providers on new screens and additional data required
|
Convert keying processes (screens)
|
1 month
|
Convert screens
|
Train keying personnel
|
Convert Historical Data
|
6-12 months
|
Begin with recent data but can convert as far back as determined necessary
|
Consider how to manage fair hearings and appeals
|
Dual strategy with providers
|
4-6 months
|
Need to write companion documents
|
Provider training and perhaps provider re-enrollment
|
Go live
|
May 23, 2007
|
|
|
Some of the WBS tasks in the following table may be completed concurrently.
Table 7: Strategy Two A: Use of Existing Wrapper
WBS
|
Timeframe
|
Additional Considerations
|
Transitional Planning
|
Assess and define transition issues
|
1-3 months
|
Mapping must be carefully crosswalked and consider all contributing interests (financial, program, decision support, etc.)
|
Make policy decisions relating to transitions
|
Create crosswalk
|
2 weeks
|
Actual system crosswalk takes into account the above issues. Consider atypical and non covered providers
|
Consider paper transactions
|
Code crosswalk
|
1-2 months
|
Time depends on complexity and number of providers
|
Allow for transition planning and training of providers
|
Develop testing platform
|
1-2 months
|
Testing platform must test for complexity and volume
|
Involve all programs in test development
|
Test internally
|
1 month
|
Must test all maps/crosswalks developed for reliability
|
|
Test with providers
|
1 month
|
Providers may not have enumerated yet.
|
Work with providers to develop enumeration strategies (i.e. subparts)
|
Test COB with other plans
|
1 month
|
Other plans may not be NPI compliant yet.
|
Work with other plans to request similar additional/situational data
|
Convert DDE systems
|
1 month
|
Allow for additional data capture in DDE systems
|
Provider training
|
Convert keying processes (screens)
|
1 month
|
Allow for additional data capture in keying systems if paper transactions maintained
|
Key data entry staff training
|
Dual strategy with providers
|
4-6 months
|
Need to write companion documents
|
Provider training and perhaps provider re-enrollment
|
Go live
|
May 23 - 2007
|
|
|
The following strategy presumes that a wrapper/translator strategy is chosen, but such technology must be purchased and installed prior to the actual remediation process.
Table 8: Strategy Two B: Purchase of wrapper/translator
WBS
|
Timeframe
|
Additional Considerations
|
Transitional Planning
|
Assess and define transition issues
|
1-3 months
|
Mapping must be carefully crosswalked and consider all contributing interests (financial, program, decision support, etc.)
|
Make policy decisions relating to transitions
|
Write requirements
|
1-2 months
|
May be begun prior to completion of assessment but not totally completed
|
Involve procurement divisions
|
Issue RFP
|
1-2 months
|
Time estimate may be unrealistic in light of State constraints.
|
Continue with crosswalking activities concurrently
|
Review responses
|
1-2 months
|
Time must be established according to State guidelines and previous history
|
|
Contract with vendor
|
1 month
|
This may take longer, depending on procurement policies
|
|
Install wrapper/translator
|
1-4 months
|
Depends on the vendor chosen
|
Conduct training of staff who will code wrapper/translator
|
Create crosswalk
|
2 weeks
|
Actual system crosswalk takes into account the above issues. Consider atypical and non covered providers
|
Consider paper transactions
|
Code crosswalk
|
1-2 months
|
Time depends on complexity and number of providers
|
Allow for transition planning and training of providers
|
Develop testing platform
|
1-2 months
|
Testing platform must test for complexity and volume
|
Involve all programs in test development
|
Test internally
|
1 month
|
Must test all maps/crosswalks developed for reliability
|
|
Test with providers
|
1 month
|
Providers may not have enumerated yet although longer time to obtain wrapper may have improved this.
|
Work with providers to develop enumeration strategies (i.e. subparts) concurrently with procurement
|
Test COB with other plans
|
1 month
|
Other plans may not be NPI compliant yet.
|
Work with other plans to request similar additional/situational data
|
Convert DDE systems
|
1 month
|
Allow for additional data capture in DDE systems
|
Provider training
|
Convert keying processes (screens)
|
1 month
|
Allow for additional data capture in keying systems if paper transactions maintained
|
Key data entry staff training
|
Dual strategy with providers
|
4-6 months
|
Need to write companion documents. This time may be shortened due to rapidly approaching compliance deadline
|
Provider training and perhaps provider re-enrollment – consider concurrent operations.
|
Go live
|
May 23 - 2007
|
|
| Deliverables
The FOX Team will develop a work plan of all impacted Medicaid or Medicaid-related system and related interfaces and schedule a meeting with the Department to walk through, review and obtain approval for the plans.
Performance Measures
We understand that these work plans are due 21 calendar days from the day on which the Department selects a remediation strategy and that walk-throughs must be scheduled within five days of submission of the work plans.
Key Activity: Implementation Work Plan for Medicaid Policies (RFP 3.2.4.2)
Key Activity: After completing analysis and recommendation phases, and once the Department has elected a remediation strategy, lay out an implementation work plan for remediation of Medicaid policies.
Contractor Responsibilities:
-
Based on the decisions of the Department for Medicaid policy remediation, create a work plan for impacted policies that are to be changed.
-
Include in the work plan key tasks and timelines
-
Obtain Department approval for the final work plan
Deliverables:
-
A work plan for approved Medicaid policy remediation
-
A scheduled meeting to walk through on work plan for Medicaid policy remediation
Performance Measures:
-
Work plans are due 21 calendar days from election of the Department’s remediation strategy
-
Walk through must be scheduled within 5 days of final report and cost benefit analysis submitted
Key Activities
FOX will have developed an NPI Impact Gap Analysis document and an NPI Management Report from the first two phases of the project. A Work Plan for the chosen remediation option is the next logical step. FOX will develop a work plan for the remediation of impacted Medicaid policies.
Contractor Responsibilities
FOX will utilize the matrix developed in Phase 1 and the Management Report for Phase 2 of the IME engagement to create a work plan for approved remediation for identified impacted policies. The work plan will include, at a minimum, key tasks and timelines. Because many operations will be concurrent, some decisions related to policies will already be incorporated into plans for system remediation strategies.
Deliverables
The FOX Team will develop a work plan for remediation of impacted Medicaid policies and schedule a meeting with the Department to walk through, review and obtain approval for the plans.
Performance Measures
We understand that these work plans are due 21 calendar days from the day on which the Department selects a remediation strategy and that walk-throughs must be scheduled within five days of submission of the work plans.
Key Activity: Implementation Work Plan for Medicaid Business Processes (RFP 3.2.4.3)
Key Activity: After completing analysis and recommendation phases, and once the Department has elected a remediation strategy, lay out an implementation work plan for Medicaid business processes by IME units.
Contractor Responsibilities:
-
Based on the decisions of the Department for remediation to IME business processes, create a work plan for changes to business processes.
-
Structure the work plan in such a way as to create individual work plans by IME units.
-
Include in the work plan key tasks and timelines and identifying IME units impacted.
-
Obtain Department approval for the final work plan.
Deliverables:
-
A work plan to include each operational business process impacted by IME laid out by IME unit
-
A scheduled meeting to walk through work plan for business process remediation.
Performance Measures:
-
Work plans are due 21 calendar days from election of the Department’s remediation strategy
-
Walk through must be scheduled within 5 days of final report.
Key Activities
FOX will lay out an implementation work plan for Medicaid business processes by impacted IME units that corresponds to the Work Plan for system remediation. The two are intimately related to each other and great care must be taken to ensure that they compliment each other. The work plan includes key tasks, timelines, and the IME units impacted.
Contractor Responsibilities
Again, a key component of the FOX methodology includes identification of all affected business processes and both internal and external stakeholders. The Work Plan will include key tasks and timelines for each impacted IME unit. As impacted business processes are remediated, FOX will work with IME to develop a comprehensive compliance strategy and communication plan for all affected stakeholders. Additionally, IME will need to monitor the compliance with new or revised business processes by both trading partners and other external stakeholders. Identification of these stakeholders and complete communication and compliance monitoring are cornerstones of the FOX methodology for business process compliance.
Deliverables
The FOX Team will develop an implementation work plan for Medicaid business processes by IME unit and schedule a meeting with the Department to walk through, review and obtain approval for the plans.
Performance Measures
We understand that these work plans are due 21 calendar days from the day on which the Department selects a remediation strategy and that walk-throughs must be scheduled within five days of submission of the work plans.
Key Activity: Create APD (RFP 3.2.4.4)
Key Activity: Assist the Department in creating an advanced planning document (APD) to be submitted to CMS to obtain enhanced funding for the remediation of Medicaid systems and processes due to NPI.
Contractor Responsibilities:
-
Identify all activities from the Department’s remediation plans that would receive enhanced federal funding.
-
Create an APD according to requirements of CMS for Department approval to obtain enhanced funding for these activities.
-
Obtain Department approval on the final document to be sent to CMS.
Deliverables:
-
A report of all activities identified as qualifying for enhanced federal funding
-
An APD to be submitted to CMS requesting ninety percent funding for remediation of Iowa Medicaid systems and processes
Performance Measures:
-
Submit report of all activities no later than noon on May 15, 2006
-
Submit final APD to Department for submission to CMS no later than noon on May 22, 2006
-
APD created must meet all CMS criteria. Questions on APD from CMS should not be the result of any technical or mechanical failure by the Contractor.
Key Activities
The APD process is integral to the success of the IME NPI project. FOX has extensive experience with APD development as well as cost benefit analysis and cost allocation plan development. as indicated by the following table and also has shepherded several through the Federal approval process.
Table 9: APD Development Experience
State
|
Developed or Helped Develop APD/IAPD
|
Completed Cost Benefit Analysis
|
Completed Make Versus Buy Analysis
|
Alaska
|
|
|
|
Arizona
|
|
|
|
Oregon
|
|
|
|
Tennessee
|
|
|
|
North Dakota
|
|
|
|
Louisiana
|
|
|
|
Florida
|
|
|
|
Georgia
|
|
|
|
New Mexico
|
|
|
|
Mississippi
|
|
|
|
Virginia
|
|
|
|
Arkansas
|
|
|
|
Per the directions provided by CMS in the past through its draft APD Guide for HIPAA Planning, FOX assumes that a Planning Advance Planning Document (PAPD) is not required as this project is being conducted to provide compliance with the Administrative Simplification provisions of HIPAA. As such, we will develop an Implementation APD (IAPD) which is designed for states to request Federal financial participation (FFP), in the designing, developing and implementing of their MMIS. We expect to work closely with both the state and the regional and central offices of CMS to ensure that the IAPD is approved within 60 days. The APD that we help IME prepare will include all items required by for Federal approval and as referenced in 42 CFR Part 433, 45 CFR Part 85, and the State Medicaid Manual Part 11.
The developed APD will meet all of the following requirements and objectives.
-
The nature of the project and the program needs or the requirements that the proposed solution is intended to meet
-
The functions to be automated and the level of automation being used
-
How the project fits into the State’s long-term automation plans and, if appropriate, how it fits into the overall direction of its automation plans i.e., telecommunication plan, central automated data processing (ADP) center, Enterprise Information Systems (EIS) strategy
-
The involvement of the State’s top management in the project to ensure success and the proposed project management organization and responsibilities
-
The State’s plans concerning transfer including the source of any transfer under consideration
-
The schedule for developing and implementing the system, showing major milestones including a statement concerning the State’s judgment about its ability to meet this preliminary schedule
Contractor Responsibilities
In consultation with the Department, the FOX Team will modify its APD development process so that it meets the needs the State of Iowa. The FOX APD development process includes the following steps:
Kickoff Meeting
To define the scope and general approach to NPI project. This will include an overview of the federal APD process and requirements to the state staff.
Completion of Analysis Required for Each Section of APD
-
Definition of the needs and objectives
-
Requirements Analysis,
-
Feasibility Study,
-
Alternative Analysis including cost analysis
-
Cost/Benefit Analysis
-
Cost Allocation Alternatives
Project Planning Activities
-
Project Organization and Personnel Resources
-
State and Contractor Resource Needs
-
Assurances
-
Project Management Plan
Development of Draft Sections of the APD -
Statement of Needs and Objectives – a summary of the current environment and the new system needs, objectives, and anticipated benefits. A basic description of the modification or system utilized in order to make the MMIS NPI-compliant will be included.
-
Problems or deficiencies in existing system – a description of why the current IME MMIS is unable to process the new or changed requirements required by NPI.
-
New or changed program requirements – an explanation of any differences between the current MMIS and NPI requirements.
-
Summary of Requirements Analysis and Alternatives Analysis – summarizing the results of any previously conducted requirements analysis, feasibility study, and alternatives analysis including:
-
General Requirements – a general requirements analysis for NPI compliance efforts, describing both the functional and technical needs and include all analysis completed up to the point of submission of the APD.
-
Alternatives Analysis – a summary of which alternatives to the selected remediation effort were selected for evaluation of costs and benefits, and provide the rationale for selection of the chosen alternative.
-
Cost/Benefit Analysis – a summary of the results of the cost benefit analysis including program performance improvements, projected costs, and anticipated benefits the NPI-compliant system is expected to deliver. The narrative will address the basis, assumptions, calculations and measurement plan related to performance, cost and benefit goals. This section will indicate, through a check box, whether the following items are included with this analysis:
-
Cost/Benefit Profile – A brief cost-benefit profile of the chosen method for NPI compliance must be included;
-
Systems Life Benefits – A spreadsheet detailing the systems life of the chosen method of compliance.
-
Project Management Plan – this summarizes the project activities, deliverables and products; project organization; State and Contractor Resource needs and anticipated system life. Any differences in from the Project Management Plan from previously submitted APDs must be explained.
-
Proposed Project Budget – the proposed budget which considers all costs for Implementation Phase activities. This might include, but is not limited to, costs associated with system software and data conversion, software development, computer capacity planning, contractor costs, supplies, training, maintenance and operations. Miscellaneous automated data processing costs (ADP) may also be included.
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Assurances – statements related to the procurement of automated data processing equipment for mechanical claims processing, and whether it was procured under the appropriate requirements outlined in the Code of Federal Requirements listed, the appropriate sections of the State Medicaid Manual and a State Medicaid Letter (dated December 4, 1995). This section also refers to access to records, licensing, ownership of software and the safeguarding of information contained within the system.
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Cost Allocation – this section describes the prospective cost allocation model including procedures to identify, record, allocate, and report direct and indirect costs, partially and fully attributable to the system project.
Submittal of Draft APD to the State for Review and Approval
FOX will submit a draft APD to the State for review and approval. Following the State’s review and comments, we will incorporate revisions and develop a final draft APD for submission to the CMS regional office for initial review. Fox, at the state’s request will participate in conference call with CMS regional staff to discuss the draft and to note any changes requested by CMS. Fox will incorporate revisions suggested by CMS and approved by the state to develop a final APD.
Submittal of the Final APD to Department and CMS
FOX will submit the final APD to the State for sign-off, which will then submit it to CMS for review and approval.
A sample Table of Contents from an APD produced by FOX for another client is presented on the following page.
Figure 15: Sample APD Table of Contents
Deliverables
For this activity, FOX will prepare a report identifying all activities qualifying for federal funding, and prepare an APD that meets all CMS criteria for obtaining 90% federal funding of the project. We understand that questions from CMS regarding the APD must not be the result of any technical or mechanical failures on the part of FOX.
Performance Measures
FOX will submit the report of activities to the Department by noon on May 15, 2006. In addition, FOX will submit the final APD to the Department for submission to CMS by noon on May 22, 2006.
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