Table of Contents (RFP 4.2.2)
Transmittal Letter (RFP 4.2.1) 1
Table of Contents (RFP 4.2.2) 5
Executive Summary (RFP 4.2.3) 7
Proposal Certification (RFP 4.2.4) 9
Organizational Information and Past Performance (RFP 4.2.5) 11
Legal Structure (RFP 4.2.5.1) 11
Organizational History (RFP 4.2.5.2) 11
Organizational Structure (RFP 4.2.5.3) 12
Assigned Project Staff (RFP 4.2.5.4) 14
Project Team Roles and Experience 15
Resumes 18
Similar Services (RFP 4.2.5.5) 55
Contract Defaults (RFP 4.2.5.6) 68
Contract Terminations (RFP 4.2.5.7) 68
Financial Statements (RFP 4.2.5.8) 68
Letters of Reference (RFP 4.2.5.9) 125
Litigation (RFP 4.2.5.10) 129
Service Requirements (RFP 4.2.6) 131
Introduction (RFP 3.1) 131
Scope of Serivces (RFP 3.2) 131
Project Management Activities (RFP 3.2.1) 131
Key Activity: Workplan (RFP 3.2.1.1) 133
Key Activity: Meet with Iowa Medicaid Enterprise (IME) (RFP 3.2.1.2) 138
Key Activity: Reports (RFP 3.2.1.3) 139
Phase 1: Full Impact and Gap Analysis (RFP 3.2.2) 145
Key Activity: Review Medicaid Policies for Impacts of NPI Compliance (RFP 3.2.2.1) 151
Key Activity: Identify and Review Medicaid Systems for Impacts of NPI compliance (Attachment 8) (RFP 3.2.2.2) 152
Key Activity: Identify and Review MMIS Interfaces for Impacts of NPI Compliance (RFP 3.2.2.2.1) 163
Key Activity: Identify and Review Medicaid Business Processes for Impacts of NPI Compliance (RFP 3.2.2.3) 165
Phase 2: Remediation Strategies (RFP 3.2.3) 169
Key Activity: Recommend Remediation Strategies for Impact Medicaid Policies (RFP 3.2.3.1) 170
Key Activity: Recommend Remediation Strategies for Impacted Medicaid Systems (RFP 3.2.3.2) 171
Key Activity: Recommend Remediation Strategies for Medicaid Business Processes (RFP 3.2.3.3) 172
Phase 3: Implementation Tasks (RFP 3.2.4) 174
Key Activity: Implementation Work Plan for Medicaid Systems (RFP 3.2.4.1) 174
Key Activity: Implementation Work Plan for Medicaid Policies (RFP 3.2.4.2) 178
Key Activity: Implementation Work Plan for Medicaid Business Processes (RFP 3.2.4.3) 179
Key Activity: Create APD (RFP 3.2.4.4) 180
Subcontractors (RFP 4.2.7) 188
Acceptance of Terms and Conditions (RFP 4.2.8) 190
Certification of Independence and No Conflict of Interest (RFP 4.2.9) 192
Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion—Lower Tier Covered Transactions (RFP 4.2.10) 194
Authorization to Release Information (RFP 4.2.11) 196
Firm Bid Proposal Terms (RFP 4.2.12) 198
Certification Regarding Registration, Collection, and Remission of State Sales and Use Tax (RFP 4.2.13) 200
Appendix 202
List of Tables and Figures
Table 1: Comparison of Approach 146
Table 2: Partial Sample Data Dictionary 160
Table 3: Sample NPI Impact Summary 162
Table 4: Example of Embedded Intelligence to Provider ID 168
Table 5: Example of IME's NPI Team Logistics 169
Table 6: Remediation Strategy One: Recoding of Existing Systems 175
Table 7: Strategy Two A: Use of Existing Wrapper 176
Table 8: Strategy Two B: Purchase of wrapper/translator 177
Table 9: APD Development Experience 180
Figure 1: Sample Narrative Project Status Report 141
Figure 2: Sample Report Card Project Status Report 144
Figure 3: FOX’s Approach to NPI 146
Figure 4: Potentially Impacted People, Processes, Systems, and Programs 148
Figure 5: FOX Process Framework 149
Figure 6: NPI Kickoff Activities 150
Figure 7: Project and Procedures Coordination 151
Figure 8: Health Plan Impact Assessment Methodology 153
Figure 9: Sample of System Inventory Results Survey for MMIS 154
Figure 10: Application Survey Sample 156
Figure 11: System by Component and Count 157
Figure 12: NPI Inventory Report 158
Figure 13: Sample Impact by Subsystem Graph - Number of Lines 163
Figure 14: NPI Impact Assessment Health Plans Program Questionnaire 167
Figure 15: Sample APD Table of Contents 185
Figure 16: Subpart Example 203
Figure 17: Sample Management Report Table of Contents 204
Figure 18: Management Report Presentation 205
Executive Summary (RFP 4.2.3)
The bidder shall submit an executive summary that briefly reviews the strengths of the bidder and key features of its proposed approach to meet the requirements of this RFP.
As a recognized leader in health care management consulting, data analysis and reporting, business process improvement, and strategic systems planning, FOX brings a unique combination of expertise and staff to this project. We have provided leadership within various domains, including Y2K, MMIS, HIPAA and MITA and, based on our experience and expertise, have developed Practice Guides for NPI compliance. Therefore, FOX comes to the project with well-defined methodologies for assessing, planning, and implementing remediation plans for NPI compliance.
The process of assessing and remediating systems for NPI is similar to that required for Y2K. As a subcontractor to TRW, FOX served as a team member on the CMS Independent Verification and Validation (IV&V) team, providing technical support to assess state Medicaid systems for Y2K readiness using established protocols for MMIS, SCHIP (State Children’s Health Insurance Program), and eligibility systems.
FOX also has worked with over three-fourths of the Medicaid programs in the United States, from helping states define requirements for procuring new Medicaid systems to providing IV&V and Project Management Office (PMO) services during MMIS implementations. At the federal level, CMS has contracted with FOX to redesign the MMIS certification process, and FOX consultants are developing up-to-date MMIS certification review criteria, on-site review protocols, and a systems testing toolkit to validate compliance.
FOX has been one of the nation’s premier HIPAA consultants since the legislation was passed in 1996, offering expertise, vision, leadership, and compliance support for Transactions and Code Sets, Privacy, Security, and now, NPI. We offer a broad range of HIPAA consulting services that includes PMO support, awareness, education and training, assessment and gap analysis, compliance planning and strategy development, and remediation execution and monitoring. In 2004, CMS selected FOX to be the NPI Enumerator contractor responsible for assigning identification numbers to all providers.
We recognize and commend the Iowa Medicaid Enterprise for its early adoption efforts in structuring the IME according to MITA principles and goals. MITA is intended to help the MMIS become the central nervous system that supports the entire Medicaid enterprise based on the standards of system oriented architecture and the enterprise server bus. The State of Iowa has undertaken a major restructuring of its Medicaid program, and its vision includes increasing flexibility and adaptability and leveraging the State’s IT infrastructure. The IME has made efforts to utilize best of breed contractors and vendors for a cohesive organization, and is now contracted with nine vendors that are co-located with State staff in a common Medicaid facility in Des Moines. These vendors adhere to a performance-based model for Medicaid administration. This co-location and performance-based model has lead to enhanced communication and coordination, and the consolidation of program databases into a data warehouse is in alignment with MITA principles and should significantly strengthen program management, reporting and quality monitoring, thus facilitating service system integration and coordination. FOX assisted the Department in planning for and selecting the vendors to operate the IME in a highly collaborative process.
While the utilization of best of breed contractors and vendors strengthens the IME, it will also pose challenges for the implementation of NPI. Wherever provider identifiers are used and exchanged both within and between systems, the logic must be solid. The FOX methodology considers these business processes and the necessity for payment and reporting structures, data capture for budgeting and forecasting, and continuation of historical data collection for fraud and abuse prevention to be critical factors in the transition to NPI.
FOX has incorporated the FOX NPI Practice Guide for Health Plans into its response to this RFP. However, FOX also is aware that the Department has a number of facilities and field service areas that function as health care providers. The impact of NPI transition requirements on providers is extensive, and fundamentally different from the impact on health plans. Providers must deal with applications for, and updating of, NPIs; determination of subparts and their enumeration; capturing and transmitting additional situational data required by health plans; and distributing NPIs to health plans, other providers, and individuals with whom they do business. FOX has responded to this RFP as written to include only the Medicaid health plan functions (IME), and has priced the bid accordingly.
Inherent in all projects are common risks such as the coordination of documentation exchange and review for the completion of various phases and related deliverables, and the quality of information available for review, i.e., outdated system documentation or policies manuals. These types of risks can be mitigated using a variety of data collection and analysis techniques, but there is another risk to the overall effectiveness of the NPI remediation effort that is not easily addressed. How providers, including providers that are owned and operated by the Department, choose to enumerate their subparts will greatly impact the IME’s ability to effectively use the information, for example, fraud and abuse detection and other program management purposes, coming from providers. Undertaking a remediation process without knowing how provider organizations will choose to enumerate their subparts will pose a challenge. It is our intention to discuss fully the implications of this issue at the kickoff meeting and to work with DHS and IME to craft a solution that will move the project forward but one that can be easily modified as more information on provider enumeration becomes available.
In conclusion, FOX offers a unique combination of expertise and experience that make it the contractor of choice to complete this project. We have the background in HIPAA and Medicaid systems that is required to thoroughly understand the issues, we offer consultants with significant knowledge and expertise within the field, and we have already developed the assessment, planning, and remediation implementation methods and tools needed to help the IME achieve NPI compliance.
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