Common Credentialing Advisory Group Meeting August 2, 2017 1 - - PowerPoint PPT Presentation

Common Credentialing Advisory Group Meeting

August 2, 2017

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Agenda

• Welcome and Introductions
• Implementation Update
• CCAG Membership Update
• Health Systems and Integrated Delivery Networks
• Interface Update
• Programmatic Updates
• Upcoming Work

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Implementation Update

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Introductions

• William (Billy) Morrissey, Director Civil and Health

Organization

• Elena Byrley, Senior Program Manager, Health

Programs

• George Webber, Project Manager

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CC Implementation Team

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Project Update

• All subcontract negotiations completed on July 28

– 3 months longer than expected – Terms and conditions required additional scrutiny by subcontractor legal counsel

• Evaluating a delay in Initial Operational Capability (IOC)

because of subcontract execution delay (Targeting Q2 of 2018 instead of Q1) Actions from Peraton to get project back on track

• Establish final Project Baseline (schedule)
• Complete requirement elaboration with Medversant
• Strengthen program management structure
• Identify schedule and process efficiencies

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CC Implementation Approach

7 CC/SI Implementation includes:

• Requirements and workflow reviews
• Development, integration, and

configuration to meet OHA’s requirements

• System, security, and performance

testing

• User Acceptance Testing (UAT) prior to

Initial Operational Capability (IOC) IOC will focus on Early Adopters, a subset of Oregon Credentialing Organizations and Practitioners.

CC/SI Implementation Warranty Period Year 1 - Maintenance and Operations (M&O) Credentialing Operations Services, Help Desk Services Early Adopters General Availability Ramp-Up to 90% Participation General Availability Normal Operations UAT CC Initial Operational Capability ∆ ∆ CC Operational Go Live

IOC is targeted for Q2 of 2018 CC Operational Go Live/General Availability is targeted for Q3 of 2018

CCAG Membership Update

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CCAG Membership Recommendations

Note: All appointments are pending OHA director approval

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Resigning Member Replacement Representation Mary Pohlman Khen Lau, Credentialing Manager, Kaiser Permanente Health System and Integrated Delivery Network Ann Klinger Christa Shively, Senior Director

• f Quality and Medical

Integration, Providence Health Plans Health System and Integrated Delivery Network Denal Everidge Ann Klinger, Director of Medical Staff Services (OHSU) Health System Shelley Sneed No Replacement (Ruby Jason to cover perspective) Health Care Regulatory Board Tooba Durrani Unknown (possible naturopath physician) Alternative Medicine Practitioner

Health Systems and Integrated Delivery Networks

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Fee Model Development

OHA worked with stakeholders on fee structure principles and on specific components of the OCCP fee structure whereby:

• Practitioners pay a one-time application fee
• Credentialing Organizations (COs) pay a one-time set up fee and

annual subscription fees

– Tiered fees for COs are based on practitioner panel size as a proxy for anticipated use of the system – Higher tiers reflect significant economies of scale discounts – Fully delegated practitioner counted only on panel of CO making decision – Health Systems that centralize decision-making count practitioners once

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Practitioner Fee: One-time initial application fee of $150 per practitioner Credentialing Organization Fees: Expedited Credentialing Fee: Up to $100/practitioner assessed to COs that optionally request an initial credentialing application be expedited.

Set-Up Fee Annual Fee Total Initial Fee Tier Practitioner Panel Size Fee Per CO Fee Per CO Per CO

Tier 1 1-100 $10/practitioner $90/practitioner varies Tier 2 101-150 $1,010 $9,090 $10,100 Tier 3 151-250 $1,500 $13,500 $15,000 Tier 4 251-500 $2,500 $22,500 $25,000 Tier 5 501-750 $5,000 $40,000 $45,000 Tier 6 751-1,500 $7,200 $60,000 $67,200 Tier 7 1,501-2,500 $11,500 $85,000 $96,500 Tier 8 2,501-5,000 $14,500 $110,000 $124,500 Tier 9 5,001-7,500 $17,000 $125,000 $142,000 Tier 10 7,501-10,000 $19,500 $140,000 $159,500 Tier 11 10,001-15,000 $22,500 $165,000 $187,500 Tier 12 >15,000 $26,000 $195,000 $221,000

OCCP Fee Model

5 Note: Possibility to reduce fees once the OCCP is operational and additional users participate.

Treatment of Health Systems

“Health System” an organization that delivers health care through financially owned hospitals, facilities, or clinics.*

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Questions Raised:

• 1. Should shared practitioners

in a health system be “de- duplicated?”

• 2. Should integrated delivery

networks** be discounted?

* Current definition in OCCP proposed rules, which is being further assessed ** “Integrated delivery network” is tentatively defined as an organization that financially owns both a health system and a health plan.

Health System Issues Considerations

OHA worked with stakeholders to assess issues:

• 1. Defining “health system” is complicated with no regulatory guidance
• 2. Health systems currently have some credentialing centralization
• 3. Generally, separate credentialing decisions are made at the CO level
• 4. Health systems want to be placed in a tier collectively
• 5. Health plans and hospitals governed by different accrediting bodies
• 6. Health system affiliations may shift over time
• 7. Integrated delivery networks* receive discounts in other programs

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OHA Programmatic Fee Adjustments for Discussion with Stakeholders

Adjustments Description Benefits Challenges Practitioner De-duplication Allow shared practitioners across a health system to be counted only

• nce
• Acknowledges

sharing of practitioners across systems

• Accounts for existing

centralization efficiencies

• Difficult to determine de-

duplicated practitioner panel sizes

• Inequalities due to fee

increases for other participants to ensure revenue Nominal Discounts to IDNs (15%) Provide a 15% discount to IDNs for both the health system and hospital

• Acknowledges current

centralization of businesses

• Incentivizes grater

OCCP support from IDNs

• Complexity of defining

and tracking health system and IDN affiliations

• Inequities due to fee

increases for other participants to ensure revenue

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De-Duplication Panel Size Example

• Health System A owns 2 hospitals.

– 200 practitioners are credentialed at Hospital 1 – 200 practitioners are credentialed at Hospital 2

• 100 practitioners are credentialed at both hospitals

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• Health System A’s “de-duplicated” panel

size is 300

– Shared practitioners counted once, so there are 300 unique practitioners being credentialed by the health system

IDN Fee Discount Example

• Organization A owns a health plan and a health system

with 5 hospitals and 1 ASC

– Health plan (HP) credentials 4,000 practitioners (tier 8) – Health system (HS) centrally credentials 1,000 unique (i.e., “de- duplicated”) practitioners (tier 6)

Total Fees = (HP Tier 8*85%) + (HS Tier 6*85%)

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Agreed Principles/Components Review

Fee Structure Principles:  Balanced, considering benefits and resources  Efficient and economical to administer  Transparent and justifiable in development  Stable to ensure predictable income to support costs Fee Structure Components:  Tiers based on practitioner panel size as a proxy for use  Higher tiers reflect economies of scale discounts  Fully delegated practitioners count only for the decision  Health systems that centralize the decision count shared practitioners once

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Feedback on adjustments?

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Next Steps for fee adjustments

Ove the next few months, OHA will be working to:

• Obtain final feedback on fee adjustments
• Assess health system definition impacts with the

Department of Justice and stakeholders

• Work with key stakeholders (those impacted, OHLC, and

OAHHS) to obtain final feedback on preferred definition

• Make a final decision and incorporate definition and fee

adjustments into final program rules to be finalized by the end of September 2017*

Note: There will be an opportunity for final review of final program rules by RAC, CCAG, and SMEs in September 2017

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Interface Update

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Some credentialing organizations want to consume practitioner data from the OCCP system into their individual systems.

Note: An interface to receive data directly is optional. All COs have the ability to access practitioner data from the OCCP system.

Survey Findings:

• COs need the ability to import bulk practitioner data into their
• wn systems
• COs need attachments (images) associated with each

practitioner record and may need each attachment separate

• Nightly frequency for posting data/attachments is acceptable
• Most respondents only want to download new/changed data, but

some expressed desire to receive the full data

Business Need for an Interface

What we know

• Medversant supports SFTP and this will meet the

requirement

• Ample lead time is required

– COs have internal procedures that must be followed when introducing these types of changes – COs require information (spec) in advance in order to secure funding and pursue changes with their vendors

• These activities are built into the project schedule and

will be communicated as soon as the schedule is baselined.

• A technical SME group may be pulled together

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Programmatic Updates

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Rulemaking Process

 Rules Advisory Committee (RAC) met May-June 2017  Statement of Need and Proposed Rule filed July 14, 2017

• Public Hearing scheduled for Wednesday, August 16, 2017
• Written comments accepted through August 18, 2017
• Final rule changes to stakeholders by October 1, 2017
• Conduct a final RAC in mid October 2017
• Final rule filed no later than January 1, 2017

Disclaimer: OCCP operational date and specific treatment of health

systems are tentative and will be finalized prior to Final Rule. OHA is working with vendors on the OCCP project schedule and key stakeholders

• n the health system component to finalize these areas.

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Credentialing Policies

• OHA made changes to Credentialing Policy & Procedures

document provided by Medversant

– Adjustments to make policy document specific to OCCP – Preliminary policy to ensure the appropriate workflow – Reviewed and gathered input on document from CC SMEs on 7/19

• Components of policy

– Initial application process – Credentials verification process and sources – Adverse action identification process – File audit process – Notification of completed credentials files – OCCP system notification/alerts process

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Credentialing Policies – Next Steps

• Finalize comments on notifications and verification sources
• Work with Medversant on changes and needs
• Develop final OCCP policy documentation

– Work with vendor team to develop and finalize an OCCP policy that can be shared with accrediting entities – Final policy documentation will be shared with CCAG/SME stakeholder workgroups for review

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Fiscal Services Update

OHA working with vendors/StateTreasurer’s Office on plan Preliminary Plan:

• Practitioners will pay through the system
• Credentialing organizations will be invoiced monthly:

– Annual fee (when applicable – annually) – Expedited requests – Optional practitioner fee payment* Note: Several organizations have expressed interest in covering the one- time application fee for practitioners. This is optional as the fee is the responsibility of the practitioner regardless of the panel they are on.

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Upcoming Work

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CCAG Work Ahead

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Work Item

2017 2018 Q3 Q4 Q1 Q2 Q3

CC Vendor Meet and Greet

X

Rule Changes Review

X

Accrediting Entity Follow-Up

X

Outreach & Marketing Materials Review

X

Credentialing Policies Review

X

CC Vendor Progress Updates

X X X X X

Business Change Leader Group

X

Public Comment

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Next meeting: October 4, 2017 Lincoln Building – 7th Floor Transformation Training Room 421 SW Oak St, Suite 775 Portland, OR 97204

More information can be found at: http://www.oregon.gov/OHA/HPA/OHIT-OCCP

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