HHSC Feedback: HHSC did not have any comments on this tab.

Transcription

1 Overview of the 16 Tracker Tabs and Tab Contact Information Description and HHSC Notes Each row represents one contact person while the row shading changes for each provider. Includes up to three contacts for each DSRIP provider, DSRIP IGT Entity, UC only provider, UC only IGT Entity, and collaborating organization. Data was compiled from the regional Anchor Template, RHP Organization tab. HHSC did not have any comments on this tab. Provider Info Each row represents one provider. Data compiled from the Provider Template, Provider Entry tab: Address information, primary county, if a provider chose to withdrawn, provider description, goals, alignment with community needs assessment, and additional counties. Data compiled from the Provider Template, Core Activities tab: Information on providers that previously participated in multiple regions how they will continue involvement. Data compiled from the Provider Template, Category C tab: Other attributed populations. HHSC did not have any comments on this tab. Provider Valuation Each row represents one provider and their DY7 8 valuation across Categories. Indicates at the top of the tab whether the private hospital participation requirement is met. Indicates whether a provider s MPT was met and any changes in valuation, specifically increases in regions with additional funds. HHSC did not have any comments on this tab. 3

2 Category B System Each row represents one system component while the row shading changes for each provider. Data was compiled from the Provider Template, Category B tab. As a reminder, system components are subject to audit. Also note, HHSC may require changes to the system definition based on provider s Category C selections and approvals. If HHSC has requested additional information to a system definition that requires a change, the provider should include any updated MLIU and Total PPP numbers with their response. The PPP tab may not reflect a Needs More Information request tied to the system component NMI. HHSC made an effort to confirm services and/or units that are listed in the system components. If a provider has omitted any aspect of the component, please explain and request any changes in the Provider Response column. HHSC has requested NMI responses on 8 system components. Category B MLIU PPP Each row represents one provider. Data was compiled from the Provider Template, Category B tab. Each provider must demonstrate maintenance (or increase) of the MLIU PPP goal in DY7 and DY8. The provider will be notified of the percentage of allowable variance from the maintenance goal with RHP Plan final approvals in June. HHSC may have requested additional information when there are significant changes in the PPP numbers between DY5 and DY6. The provider may not need to update their numbers, but should provide more concrete explanations for the shift in patient populations. HHSC has requested 1 NMI responses on requests to use DY5 or DY6 for the MLIU PPP goal or other requests for clarification. Category C Hospitals & PPs Each row represents one selected measure for each hospital or physician practice while the row shading changes for each Measure Bundle. Any requests for the measure to have an alternative denominator for achievement (e.g. all payer, Medicaid only, LIU only, requests for P4R), reporting milestone exemption, shorter or delayed measurement period, or baseline numerator of zero is also displayed on this row. Note that providers approved with a limited scope of practice will also appear on this tab and the explanation for selecting a Measure Bundle is duplicated for every measure within the bundle. 4

3 Data was compiled from the Provider Template, Category C Selection and Category C Additional Details tabs. HHSC has not approved most requests for use of an all payer denominator, insignificant volume, and no volume due to lack of explanation for such requests. Refer to the standard comments for detailed instructions on responding to common issues, starting on p. 9. HHSC has requested NMI responses for clarification or provider s requested exceptions for 8 measure selections. Some measures request responses for multiple issues. Providers should respond to all issues in the Provider Response column. Measures that require a response are indicated in the Provider Response Required column. Category C CMHCs & LHDs Each row represents one selected measure for each CMHC or LHD while the row shading changes for each provider. Any requests for the measure to have an alternative denominator for achievement (e.g. allpayer, Medicaid only, LIU only, requests for P4R), reporting milestone exemption, shorter or delayed measurement period, or baseline numerator of zero is also displayed on this row. Note that the explanation for selecting the measures is duplicated for every measure for each provider. Data was compiled from the Provider Template, Category C Selection and Category C Additional Details tabs. HHSC has not approved most requests for use of an all payer denominator, insignificant volume, and no volume due to lack of explanation for such requests. Refer to the standard comments for detailed instructions on responding to common issues, starting on p. 9. HHSC has requested NMI responses for clarification or provider s requested exceptions for 6 measure selections. Some measures request responses for multiple issues. Providers should respond to all issues in the Provider Response column. Measures that require a response are indicated in the Provider Response Required column. Category C Valuation Each row represents a Measure Bundle for hospitals and physician practices and a measure for CMHCs and LHDs. Note that limited scope providers will also show individually selected measures and explanations are duplicated for every Measure Bundle/measure that had a change greater than 1 percent for each provider. Data was compiled from the Provider Template, Category C Valuation 5

4 tab. HHSC has requested 4 NMI responses on changes in valuation. Category C Milestone Valuation Category A Project Transition This tab is for informational purposes to show the valuation of DY7 8 milestones based on the provider s proposed Measure Bundle/measure valuation and the requested volume for the achievement milestones (i.e. MLIU denominator with significant volume, insignificant volume, or no volume). Select a provider in the yellow cell and the table will populate with the milestones valuations. Each row represents a measure. Note that measure selections, denominator exception requests, and valuation may be pending NMI responses so the displayed valuation amounts are not final. Each row represents one historical DY6 project while the row shading changes for each provider. Data was compiled from the Provider Template, Category A Core Activities tab. It appears that providers had different understandings on whether to select Continuing as Core Activity in DY7 8 or Completed in DY2 6. HHSC may request additional information on continuation of DY2 6 projects at a later time through a separate process. Category A Core Activities Each row represents one Core Activity while the row shading changes for each provider. The related secondary driver(s) and change idea(s) up to five each are displayed on the same row. Data was compiled from the Provider Template, Category A Core Activities tab. It appears that some providers misunderstood the difference between a Core Activity to support improvement on a Category C Measure Bundle/measure versus implementing a measure. For example, there were NMIs for providers who selected B1 287 Documentation of Current Medications in the Medical Record and indicated that their Core Activity was to have providers enter medications in the hospital EMR. Some of the change ideas were not concrete in terms of what exactly is being done or how it is measured (e.g. Improve compliance with specific 6

5 protocols, with no additional information on how the improvement is determined). If a provider specified the action in the change idea(s), but some of the information is missing, HHSC approved the Core Activity. However, providers will be required to submit additional information during reporting specifying how exactly the provider is improving something and how it will be measured. HHSC will include additional guidance in the DY7 October Reporting Companion Document. HHSC has requested 14 NMI responses on Core Activities. Driver Diagram This tab is for informational purposes to display the driver diagram of Core Activities, Secondary Drivers, and Change Ideas that impact each Measure Bundle for hospitals and physician practices or measure for CMHCs and LHDs. Select a provider in the yellow cell and a driver diagram will populate for each Measure Bundle or measure for the selected provider. Category D Only the information for hospitals to request an HCAHPS exemption and physician practices impact on PQIs are displayed. Each row represents a provider. Data was compiled from the Provider Template, Category D tab. Children s hospitals should clarify if they are using a CAHPS child hospital survey instead of HCAHPS. HHSC has requested 1 NMI response on HCAHPS exemption requests. IGT Funding Each row represents an item for IGT funding (RHP Plan Update submission, Category A, Category D, and each measure for Category C) while the row shading changes for each provider. Data was compiled from the Provider Template, IGT Entry tab. This tab is for informational purposes as changes in IGT Entity or proportion may continue to be submitted during each reporting period. Note that the FMAP for DY8/FFY19 has been finalized as while the tracker shows amounts based on an estimated FMAP of HHSC will not be updating the amounts in the regional tracker; however, the correct FMAP of will be used in the DSRIP Online Reporting System and for payment processing. Provider Template Completion HHSC did not have any comments on this tab. Each row represents a provider. Data was compiled from the Provider Template, Overall Template Progress tab. 7

6 HHSC did not have any comments on this tab. Anchor Information Feedback Each row represents a tab from the Anchor Template and a row for general comments. HHSC did not have any comments on this tab. 8

7 Standard Comments from the Category C Hospitals & PPs and Category C CMHCs & LHDs tabs: Requesting All Payer Denominator for Achievement Milestone Provider requested an exception to use the all payer population for the Category C goal achievement milestone instead of the MLIU population. The approved PFM for DY7 and DY8 allow exceptions to the Category C goal achievement payer type with good cause such as data limitations or small denominator for the selected measure. If a provider has a significant MLIU denominator for a given measure and does not have data limitations that would reasonably prevent the provider from determining the payer type for cases within the denominator, than the provider does not have good cause to request that payment for a P4P measure's goal achievement milestone be based on a payer type other than MLIU. A significant denominator is 30 or more denominator cases for most measures. The provider s explanation for an alternative goal achievement payer type does not indicate that an all payer population is needed due to data limitations or a small denominator. HHSC has removed provider request for an alternative Category C goal achievement milestone. If provider disagrees with this HHSC change, provider should respond in the Provider Response column and provide the requested additional detail needed to justify an all payer population for the Category C goal achievement milestone. If provider is requesting an all payer achievement goal because of data limitations, provider should include a detailed explanation of why the provider is not able to determine the payer type for cases within the denominator of this specific measure. If provider is requesting an all payer achievement goal because of an insignificant MLIU denominator, provider should include a detailed description of the insignificant denominator including the MLIU and all payer denominator for a 12 month baseline measurement period for this measure. Requesting Reporting Milestone Exemption Provider requested an exception to reporting the Medicaid and LIU rate for achievement of the Category C measure's reporting milestone. The approved PFM for DY7 and DY8 allows a provider to be exempted from reporting its performance on the Medicaid only payer type or the LIU only payer type for a measure's reporting milestone with good cause, such as data limitations. If a provider does not have data limitations that would reasonably prevent the provider from determining the payer type for cases within the denominator of this measure, than the provider does not have good cause to request to be exempt from reporting the Medicaid only and LIU only payer type for this measure's reporting milestone. 9

8 The provider s explanation for a reporting milestone exemption does not indicate that an exemption is needed due to data limitations. HHSC has removed the provider request for an exception to reporting the Medicaid and LIU rate for achievement of the Category C measure s reporting milestone. If provider disagrees with this HHSC change, provider should respond in the Provider Response column and provide the requested additional detail needed to justify an exception to reporting the Medicaid and LIU rate for achievement of the Category C measure s reporting milestone. If provider is requesting an exception because of data limitations, provider should include a detailed explanation of why the provider is not able to determine the payer type for cases within the denominator of this measure. Requesting a Delayed Baseline Measurement Period Provider requested a delayed baseline. In the RHP Plan Update Companion (Page 21 22) and the RHP Plan Update Webinar (Slide 43 Baseline Data Planning Guidelines), HHSC included a list of preferred baseline scenarios organized in order of preference, with a delayed baseline as the least preferable option. In cases where a provider does not have twelve months of electronic OR SAMPLED data available that ends 12/31/17, providers should first consider a shortened baseline that ends 12/31/17, a baseline of zero if measure is eligible, an approximate baseline (for example, if a measure requires 5 screenings be completed, and a provider was only conducting three during baseline, the provider could request approximate specifications at baseline only where the baseline is specific to the 4 screenings already in place), and finally a delayed baseline. Provider request for a delayed baseline did not adequately address why sampling or an approximate baseline are not feasible. Provider should review baseline planning options and if more preferable resolutions are still not possible, include in the Provider Response column a detailed explanation of why more preferable baseline scenarios are not feasible for this measure. If a preferred scenario is available for this measure, provider should indicate in the Provider Response column that they would like to remove this request for a delayed baseline, and describe the resolution. System Component Comments appear to be referring to subsets (Hospital & PP only) Provider's explanation for selecting Measure Bundle includes primary system components related to this measure. As a reminder, system components are included in the Category C measure specifications for planning purposes, to ensure that measure bundle is appropriate for the provider's system. System components are not intended to limit a measure beyond what is included in the target population and measure specifications. Providers should include in the measure denominator all individuals that meet the target population and measure denominator from all components within the provider s DSRIP defined system. (NOTE: No response is required unless other issues are identified) 10

9 Requesting no numerator volume for PBCO measure HHSC encourages all providers to report PBCO measures, and to pursue necessary data sharing agreements or HIE arrangements if available to report PBCO measures. In negotiation with CMS on DY7 and DY8 protocols, CMS indicated PBCOs are a key measure of delivery system reform and all providers should be reporting as P4P or P4R if needed. Per AHRQ, These are conditions for which good outpatient care can potentially prevent the need for hospitalization or for which early intervention can prevent complications or more severe disease. The Prevention Quality Indicators and Pediatric Quality Indicators provide insight into the community health care system or services outside the hospital setting. For example, patients with diabetes may be hospitalized for diabetic complications if their conditions are not adequately monitored or if they do not receive the patient education needed for appropriate self management. PDIs screen for problems that pediatric patients experience as a result of exposure to the healthcare system and that may be amenable to prevention by changes at the system or provider level. While provider does not include any hospital or emergency department system components, provider should review available data sharing arrangements that may be leveraged to track key population health indicators for individuals the provider sees in an outpatient/primary care setting. Provider should indicate in the "Provider Response" column if reporting PBCO measure as P4R is feasible for DY7 and DY8, or indicate steps provider may be taking to be able to report measures in the future. As a reminder, the denominator for Category C measures must come from the DSRIP defined system, but numerator elements do not need to occur within the DSRIP system. If provider has access to any hospital utilization data for individuals in the target population, provider should evaluate ability to report measure as P4R or P4P. Requesting to report PBCO measure as P4R without sufficient rationale HHSC encourages all providers to report PBCO measures, and reporting as P4P is recommended for those with a reliable source of data and a significant numerator volume. Provider has requested to report as P4R and has not included an adequate rationale for this decision. In negotiation with CMS on DY7 and DY8 protocols, CMS indicated PBCOs are a key measure of delivery system reform and all providers should be reporting as P4P or P4R if needed as the included measures are key outcomes of delivery system reform. Per AHRQ, PQIs and PDIs are conditions for which good outpatient care can potentially prevent the need for hospitalization or for which early intervention can prevent complications or more severe disease. The Prevention Quality Indicators and Pediatric Quality Indicators provide insight into the community health care system or services outside the hospital setting. For example, patients with diabetes may be hospitalized for diabetic complications if their conditions are not adequately monitored or if they do not receive the patient education needed for appropriate self management. PDIs screen for problems that pediatric patients experience as a result of exposure to the healthcare system and that may be amenable to prevention by changes at the system or provider level. As a reminder, the denominator for Category C measures must come from the DSRIP defined system and is based on a significant outpatient relationship with the 11

10 performing providers system. Numerator elements do not need to occur within the DSRIP system. PBCO measures are best suited for measuring the success of primary care and outpatient disease management. Provider should evaluate ability to report as P4P. If provider must continue to report as P4R, provider must include a sufficient rationale for why the provider is not able to utilize these key population health indicators of delivery system reform in DSRIP in DY7 DY8. Eligibility to report as P4R under the approved protocols is not sufficient rationale as provider is also eligible to report as P4P. Provider should explain for example any limitations on data completeness, small numerator populations, or other reasonable issues that would prevent the measure from being used in a P4P context in DY7 and DY8. Provider should detail any steps being taken to prepare the provider to be able to report as P4P in future reporting years. Limited Scope of Practice Missing Rationale Provider was approved for a limited scope of practice and the RHP Plan Update Template did not give provider the opportunity to provide a rationale for selecting measure bundle. In the "Provider Response" column, provider should enter a response to the following required question taken from the RHP Plan Update Companion Page 17 step 13g: "Enter a rationale for selecting the Measure Bundle and the primary system components (names of clinics, facilities that will serve as the primary source of the denominators for measures in the selected Measure Bundles) that will be used to report on and drive improvement in the Measure Bundle. Please describe the process used to select measures, how selected Measure Bundles align with your overall DSRIP goals and identified regional community needs, and contribute to the continued transformation of the healthcare delivery system." Standard Comments from the Category C Valuation tab: Requesting a change to valuation >1% without sufficient rationale Provider requested to change valuation beyond the default valuation determined by measure bundle point value. Provider rationale for change does not adequately describe the rationale for the requested change. Provider should include in the "Provider Response" column greater detail on the primary justification for increased valuation. Provider should include comparative numbers (population size, baseline, cost) and any formulas used if relevant to determine requested percentage changes. Decreasing valuation for a specific bundle because a provider is unlikely to meet the goals within the bundle is not an adequate rationale for valuation changes and is not in line with the goals of delivery system reform. Level of effort to measure and report an outcome is also not an adequate rationale for valuation changes. 12