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Medicare
Program Audit and Compliance Infrastructure Development Draft
Organizational Assessment Instrument
Task
11: Development of Parts C & D Measure Data Validation Standards
and Procedures
Medicare
Program Audit and Compliance Infrastructure Development
Parts
C & D Measure Data Validation Standards and Procedures
Interview
Discussion Guide
Draft
Submitted
to:
DEPARTMENT
OF HEALTH & HUMAN SERVICES
Centers
for Medicare & Medicaid Services
7500
Security Boulevard
Baltimore,
Maryland 21244-1850
Submitted
by:
Booz
Allen Hamilton
One
Preserve Parkway
Rockville,
MD 20852
Tel
1-301-838-3600
Fax
1-301-838-3606
www.boozallen.com
February
19, 2010
Table
of Contents
1.0overview
The
Interview Discussion Guide is a supplemental tool to the
Organizational Assessment Instrument (OAI) that data validation
contractors (reviewers) may use to obtain further information about
the organization and its reporting processes. It is intended to
facilitate discussions during the on-site visit and includes both
general and selected measure-specific questions that the reviewer may
choose to ask of the appropriate organization staff. The reviewer
may alter these questions depending on the information needed, and
may combine the measure-specific questions as appropriate to allow
for efficient use of on-site discussion time should the
organization’s staff be involved with reporting for more than
one measure.
2.0interview
discussion guide: Questions applicable to all measures
Interview
Discussion Guide for On-site Data Validation Review
Measure:
<MEASURE>
INTERVIEWEE
INFORMATION
Name:
Title:
Primary
Phone Number:
Email:
INTERVIEWER
INFORMATION
Name:
Date:
Time:
2.1Introduction/Background
2.1.1What are your roles and responsibilities in
your current position?
2.1.2Describe your expertise and experiences with
CMS reporting requirements.
2.2Data Production and Underlying Data Sources
2.2.1Describe the processes used to produce,
maintain and update the data contained in the underlying data
sources. Indicate all underlying data sources involved in the
reporting process, beginning with the originating data systems (e.g.,
claims adjudication system, enrollment system) and including all
other data sources used for data collection and storage, data
processing, analysis, and reporting. For each data source, discuss
the following:
Data
Source Name
Data
Collection/Production Process and Schedule
Data
Validation Process (for both electronic and manual processed data)
Responsible
Entities (if external, how are they managed?)
2.3Report
Production Questions
2.3.1Describe the processes involved with
producing the measures, including:
Data
Collection
Data
Analysis
Data
Validation (for both electronic and manually produced reports)
Report
Submission (for both electronic and manually submitted reports)
Data
Sources Used
Responsible
Entities (if external, how are they managed?)
2.4Data
Processing/Quality
2.4.1Has your organization encountered reporting
issues with any of the data elements? If yes, describe the issues
and how they were resolved.
2.4.2What are the unique identifiers used for
tracking purposes (e.g., Member ID, Provider ID, Agent ID)?
2.4.3How does your organization ensure the
appropriate date ranges for each measure are being reported?
2.4.4Has your organization experienced any
problems with data completeness? If yes, describe the problems and
how they were resolved.
2.4.5Describe your organization’s internal
control processes for assessing data completeness and accuracy (e.g.,
for a claims-based measure, how does your organization ensure that
all data from a claim is submitted and claims for all visits are
submitted)?
In
cases where data are incomplete due to delays in obtaining the data,
how is this handled by your organization?
When
data are questionable or invalid (e.g., claim appears inaccurate),
what are the processes for determining whether the data are accurate
and should be included for reporting purposes?
How
are duplicate records identified and addressed by your organization
to ensure that they are excluded from final reporting?
2.4.6How are missing or invalid data addressed
and corrected (e.g., missing data values)?
2.4.7What edit checks are in place to validate
data entry in HPMS (for both data submitted electronically (i.e.,
direct file upload) and data manually entered)?
2.4.8Has your organization implemented process or
system improvements as a result of previously encountered problems
with data processing, data management, reporting requirements or
deadlines? If yes, describe these improvements.
2.5Additional
Measure-Specific Questions
See
Sections and 4
below for additional measure-specific questions to incorporate into
applicable interviews. Note that not every measure included in the
data validation review has additional questions in this Interview
Discussion Guide. The reviewer may create additional
measure-specific questions depending on the information needed.
3.0Part
C Additional Measure-Specific Questions
3.1Benefit
Utilization
3.1.1How does your organization define services
and benefits that are covered/not covered for purposes of reporting
this measure?
3.1.2Describe your organization’s method
for assigning utilization types to the services indicated in the
measure. For example, does your organization use “Admits”
or “Days” to identify Inpatient Services?
3.1.3Provide evidence of the mapping of PBP
categories to service categories (per Part C Reporting Requirements
Technical Specifications).
3.1.4Describe how member cost-sharing amounts are
derived.
3.2Procedure
Frequency
3.2.1How many diagnosis and procedure codes are
captured by your organization’s claims data systems? To what
digit are the diagnosis and procedure codes specified?
3.2.2Does your organization map non-standard
codes to the standard codes provided by CMS in the Part C Reporting
Requirements Technical Specifications? If yes, provide details on
the mapping schema.
3.2.3Does your organization use global billing
for any of the services identified in this measure?
3.2.4Does your organization include services
based on claims that were denied for payment?
3.3Serious
Reportable Adverse Events (SRAEs)
3.3.1How many diagnosis and procedure codes are
captured by your organization’s claims data systems? To what
digit are the diagnosis and procedure codes specified?
3.3.2Does your organization map non-standard
codes to the standard codes provided by CMS in the Part C Reporting
Requirements Technical Specifications? If yes, provide details on
the mapping schema.
3.3.3Does your organization include services
based on claims that were denied for payment?
3.3.4How does your organization determine whether
the adverse event (signified by ICD-9 Diagnosis E876.5) was related
to Surgery on Wrong Body Part, Surgery on Wrong Patient, or Wrong
Surgical Procedures on a Patient?
3.4Provider
Network Adequacy
3.4.1When a provider is no longer part of the
network (e.g., provider does not renew contract), how is this
monitored and tracked?
3.4.2How do you determine validity of data? For
example, how do you determine whether the provider is contracted to
provide services in a specific network? What is the schedule for
this type of data validation?
3.4.3If contracting issues are encountered (e.g.,
expired contracts, new contracts), how are these addressed? How do
you ensure that these updates are made and incorporated into final
HPMS reporting?
3.5Grievances
(Part C)
3.5.1How does your organization identify a
grievance (i.e., distinguishing between grievances, inquiries,
organization determinations, and reconsiderations)? Describe any
internal processes used to ensure grievances are captured as
appropriate.
3.5.2How does your organization assign grievance
categories (e.g., marketing, enrollment, quality of care)? Describe
any internal processes used to ensure member issues are categorized
correctly.
3.5.3How does your organization log/track/respond
to identical grievances reported by the same member multiple times
and/or to multiple departments?
3.6Organization
Determinations/Reconsiderations
3.6.1How does your organization identify an
organization determination (i.e., distinguishing between grievances,
inquiries, organization determinations, and reconsiderations)?
3.6.2How does your organization assign a final
disposition category (i.e., definitions for fully favorable,
partially favorable, adverse)?
3.7Special
Needs Plans (SNPs) Care Management
3.7.1How does your organization identify
enrollees that are eligible for an annual reassessment?
3.7.2How does your organization identify the
health risk assessments that are performed on enrollees to determine
whether they are initial assessments or annual reassessments?
4.0Part D Additional Measure-Specific Questions
4.1Retail,
Home Infusion, and Long-Term Care Pharmacy Access
4.1.1When a pharmacy is no longer part of the
network (e.g., pharmacy does not renew contract), how is this
monitored and tracked?
4.1.2How do you determine validity of data? For
example, how do you determine whether the pharmacy is contracted to
provide long-term care services or home infusion services? What is
the schedule for this type of data validation?
4.1.3If contracting issues are encountered (e.g.,
expired contracts, new contracts), how are these addressed? How do
you ensure that these updates are made and incorporated into final
HPMS reporting?
4.2Medication
Therapy Management Programs
4.2.1How does your organization identify members
as being eligible for the MTMP?
4.2.2How does your organization identify and
track MTM interventions, including comprehensive medication reviews,
targeted medication reviews, prescriber interventions, and drug
therapy changes as a result of MTM interventions?
4.2.3How do you determine validity of data? For
example, how do you determine whether the beneficiary’s MTMP
enrollment status is current? What is the schedule for this type of
data validation?
4.2.4If a beneficiary’s enrollment status
is incorrect, how is this addressed? How do you ensure that invalid
enrollees are excluded from the final cleaned database used for HPMS
reporting?
4.3Grievances
(Part D)
4.3.1How does your organization identify a
grievance (e.g., distinguishing between grievances, inquiries,
coverage determinations, exceptions, and appeals/redeterminations)?
Describe any internal processes used to ensure grievances are
captured as appropriate.
4.3.2How does your organization assign grievance
categories (e.g., marketing, enrollment, quality of care)? Describe
any internal processes used to ensure member issues are categorized
correctly.
4.3.3How does your organization log/track/respond
to identical grievances reported by the same member multiple times
and/or to multiple departments?
4.4Coverage
Determinations and Exceptions
4.4.1How does your organization identify a
coverage determination/exception (e.g., distinguishing between
grievances, inquiries, coverage determinations, exceptions, and
appeals/redeterminations)? Describe any internal processes used to
ensure coverage determinations/exceptions are categorized correctly.
4.4.2How does your organization determine whether
a request is subject to the coverage determinations or the exceptions
process?
4.4.3How does your organization log/track/respond
to identical requests for coverage determinations/exceptions
requested for the same member multiple times?
4.5Appeals
4.5.1How does your organization identify an
appeal (e.g., distinguishing between grievances, inquiries, coverage
determinations, exceptions, and appeals/redeterminations)? Describe
any internal processes used to ensure appeals are categorized
correctly.
4.5.2How does your organization assign a final
disposition category (e.g., definitions for fully favorable,
partially favorable, and adverse)?
4.6Long-Term
Care (LTC) Utilization
4.6.1How does your organization determine whether
a member resides in a long-term care facility at the time a Part D
claim for that member is processed?
4.6.2How does your organization distinguish
between network LTC pharmacies and network retail pharmacies?
2
INFORMATION
NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW:
This
information has not been publicly disclosed and may be privileged
and confidential. It is for internal government use only and must
not be disseminated, distributed, or copied to persons not
authorized to receive the information. Unauthorized disclosure may
result in prosecution to the full extent of the law.
File Type | application/msword |
File Title | OAI Draft |
File Modified | 2010-02-19 |
File Created | 2010-02-19 |