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STATE OF OKLAHOMA OKLAHOMA HEALTH CARE AUTHORITY STATE MEDICAID HIT PLAN (SMHP) VERSION 1.0 July 26, 2010 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page i Prepared by OHCA with assistance from: 6263 North Scottsdale Road, Suite 200 Scottsdale, AZ 85250 (480) 423-8184 www.foxsys.com State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page ii TABLE OF CONTENTS 1 EXECUTIVE OVERVIEW...................................................................................................1 1.1 Background .....................................................................................................................2 1.1.1 Current HIT Landscape in Oklahoma............................................................................3 1.1.2 Vision of HIT Future....................................................................................................11 1.1.3 Provider Incentive Program Implementation ...............................................................12 1.1.4 MITA HIT Roadmap....................................................................................................14 1.1.5 Recommendations......................................................................................................17 2 CURRENT HIT LANDSCAPE ASSESSMENT – THE “AS IS” ENVIRONMENT.............18 2.1 Current HIT Activities and Impact on SoonerCare Members..........................................18 2.2 Current HIT Activities and Impact on SoonerCare EHR Incentive Program ...................21 2.2.1 Broadband Internet Access in Oklahoma....................................................................22 2.2.2 Beacon Community Grant ..........................................................................................23 2.2.3 Oklahoma Health Information Exchange (OKIE).........................................................24 2.2.4 Federally Qualified Health Clinics and Rural Health Clinics ........................................24 2.2.5 Oklahoma Exchange Networks...................................................................................24 2.2.6 Recommendations......................................................................................................25 2.3 State Medicaid HIT Plan Development ..........................................................................26 2.4 HIT Landscape Assessment..........................................................................................28 2.4.1 Existing HIT and Data Resources...............................................................................28 2.4.2 MITA State Self-Assessment (SS-A) ..........................................................................30 2.4.3 MMIS HIT/HIE Environment........................................................................................35 2.5 Environmental As Is Scan..............................................................................................35 2.5.1 Professional Providers (individual and group providers) Scan ....................................36 2.5.2 Hospital Scan .............................................................................................................37 2.5.3 Federally Qualified Health Clinics (FQHCs)/Rural Health Clinics (RHCs) Scan ..........38 2.5.4 Indian Health Service (IHS)/Tribal facilities/Urban Indian Clinic Providers ..................38 2.5.5 Selection of Environmental Scan Participants.............................................................39 2.5.6 Environmental Scan Questions...................................................................................39 2.5.7 Environmental Scan Analysis .....................................................................................40 2.5.8 Key EHR Characteristics ............................................................................................43 3 THE VISION OF HIT FUTURE – “TO BE” ENVIRONMENT............................................45 3.1 Participating Entities......................................................................................................45 3.2 Vision for HIT Environment............................................................................................46 4 SPECIFIC ACTIONS NECESSARY TO IMPLEMENT THE SOONERCARE EHR INCENTIVE PROGRAM ..................................................................................................52 4.1 Program Organization ...................................................................................................52 4.1.1 HIT Oversight Work Group .........................................................................................53 4.1.2 Planning Development and Implementation (PDI) Work Group ..................................54 4.1.3 Clinical Work Group and Statewide Meaningful Use Task Force ................................56 4.1.4 Finance Work Group ..................................................................................................58 4.1.5 Provider and Business Operations Work Group..........................................................60 4.1.6 Legal-Policy Work Group............................................................................................61 4.1.7 Technical – Information Systems Work Group............................................................62 4.1.8 Outreach, Education, and Information Work Group ....................................................64 4.1.9 Consumer Work Group...............................................................................................66 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page iii 4.1.10 Concept of Operations................................................................................................68 4.2 Communication Plan .....................................................................................................69 4.3 Policy and Regulatory Changes.....................................................................................70 4.3.1 Policy Changes...........................................................................................................70 4.3.2 Privacy Regulatory Changes ......................................................................................72 4.3.3 Other Regulatory Changes .........................................................................................72 4.4 OHCA Contract Changes ..............................................................................................72 4.5 Provider Eligibility for Incentive Payments .....................................................................73 4.5.1 Provider Eligibility Determination ................................................................................74 4.5.2 Eligible Providers........................................................................................................79 4.5.3 Provider Registration Process ....................................................................................79 4.6 Processing Payments to Providers ................................................................................80 4.6.1 Provider Registration and Payment Request ..............................................................81 4.6.2 Provider Payment Calculations...................................................................................85 4.6.3 Provider Payment Monitoring......................................................................................86 4.6.4 Provider National Provider Identifier (NPI) ..................................................................88 4.6.5 Role of Contractors in the SoonerCare EHR Incentive Program Implementation........88 4.7 Reporting Requirements................................................................................................88 4.8 Coordination with Medicare to Prevent Duplicate Payments..........................................89 4.9 Program Integrity (PI) Monitoring...................................................................................89 4.9.1 Incentive Payment Recoupment .................................................................................90 4.9.2 Fraud and Abuse Prevention ......................................................................................90 4.9.3 Provider Appeals ........................................................................................................91 4.10 Coordination with OFMQHIT .........................................................................................92 4.11 OHCA SoonerCare EHR Incentive Program Administration ..........................................93 4.11.1 Federal Financial Participation (FFP)..........................................................................93 4.12 Clinical Quality Data ......................................................................................................94 4.13 OHCA EHR Outcome Evaluation...................................................................................95 4.13.1 EHR Quality Assurance/Quality Improvement Outcome .............................................95 4.13.2 EHR Child Health Outcome Evaluation.......................................................................96 4.13.3 EHR Performance and Reporting Outcome Evaluation .................................................96 4.13.4 EHR Health Management Program (HMP) (Chronic Disease) Outcome Evaluation ...97 4.13.5 EHR Pharmacy Outcome Evaluation.............................................................................97 4.13.6 EHR Use – Care Management Outcome Evaluation .....................................................98 4.14 State Alternative Methods..............................................................................................98 4.14.1 Meaningful Use Criteria ..............................................................................................99 4.15 Dependence upon Federal Initiatives ..........................................................................100 5 HIT ROADMAP..............................................................................................................101 5.1 Oklahoma Vision for Moving from “As Is” to “To Be” HIT Landscape ...........................101 5.1.1 OHCA Programs “To Be” Vision ...............................................................................102 5.1.2 OHCA Role in the SoonerCare EHR Incentive Program...........................................104 5.2 OHCA Participation in Health Information Exchange (HIE) ..........................................113 5.2.1 Participation in Federal National Health Information Network (NHIN) .......................113 5.2.2 Participation in Statewide, Regional, and/or Local HIE Initiatives..............................114 APPENDIX A: COMMUNICATIONS PLAN............................................................................119 APPENDIX B: ENVIRONMENTAL SCAN QUESTIONS ........................................................124 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page iv APPENDIX C: PROGRAM INTRODUCTION .........................................................................130 APPENDIX D: OHCA ORGANIZATION STRUCTURE & DESCRIPTION..............................134 APPENDIX E: QUALIFYING PATIENT VOLUME TABLE .....................................................145 APPENDIX F: LETTERS OF SUPPORT ................................................................................146 APPENDIX G: ACRONYMS...................................................................................................149 APPENDIX H: GLOSSARY....................................................................................................152 LIST OF FIGURES AND TABLES Figure 1 MITA SS-A to SMHP Alignment ................................................................................... 5 Figure 2 Percentage of Providers Reporting EHR/EMR by Group.............................................. 7 Figure 3 Non-Hospital Responses by Provider Type.................................................................. 7 Figure 4 Indian Health Service (IHS) and Tribal Providers ......................................................... 8 Figure 5 Hospital EHR Environment........................................................................................... 8 Figure 6 Hospital Future EHR Plans .......................................................................................... 8 Figure 7 Provider Participation Selection.................................................................................... 9 Figure 8 Hospital Broadband Access ......................................................................................... 9 Figure 9 Hospital Existence of Meaningful Use Criteria.............................................................10 Figure 10 Hospital Participation in HIE......................................................................................10 Figure 11 MITA Roadmap.........................................................................................................15 Figure 12 Oklahoma Proposed Broadband Fiber Backbone .....................................................22 Figure 13 MITA SS-A to SMHP Alignment ................................................................................27 Figure 14 MITA Framework Components..................................................................................28 Figure 15 Percentage Having EHR/EMR by Group...................................................................41 Figure 16 HIT Oversight Work Group Organizational Structure.................................................52 Figure 17 Health Care Authority Board .....................................................................................68 Figure 18 MITA Roadmap.......................................................................................................102 Table 1 Existing Regional Health Information Exchange (HIE) Efforts.......................................25 Table 2 Executive Guiding Principles and Objectives................................................................30 Table 3 Professional Provider Scan Timeline............................................................................37 Table 4 Hospital Scan Timeline.................................................................................................38 Table 5 FQHCs/RHCs Scan Timeline .......................................................................................38 Table 6 Performance Measures for SoonerCare Provider HIE Participation..............................49 Table 7 Work Group Members and Positions............................................................................54 Table 8 SoonerCare Patient Volumes .......................................................................................77 Table 9 Eligible Professional Attestations..................................................................................81 Table 10 Eligible Hospitals and CAHs Attestations ...................................................................83 Table 11 Category of Services ................................................................................................104 Table 12 Average Electronic Volume for OHCA per month .....................................................108 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 1 1 EXECUTIVE OVERVIEW The section provides a high-level executive summary for how the SoonerCare Electronic Health Record (EHR) Incentive Program will be administered by the Oklahoma Health Care Authority (OHCA), and how the OHCA programs will leverage the clinical data made available through electronic health record technology to achieve their goals and vision for improving population health outcomes and quality of care for Oklahomans. The approach taken by Oklahoma Health Care Authority (OHCA) in preparing this State Medicaid Health Information Technology (HIT) Plan (SMHP) was to begin planning early with the intent to implement the SoonerCare Electronic Health Record (EHR) Incentive Program in January 2011. This allows Oklahoma SoonerCare eligible providers the opportunity to review EHR products, find a match to meet the needs of their offices and hospital settings, and maximize payments available under the federal Provider Incentive Program. The basis for developing the SMHP was the Final Rule, published July 13, 2010, that provides incentive payments for the meaningful use of certified EHR technology. The Oklahoma Health Information Exchange (OKHIE) is moving forward to plan the statewide approach and develop their Strategic and Operational Plans simultaneously to the work taking place on the SMHP. The OHCA Chief Information Officer (CIO) co-chairs the Statewide Oversight Committee and OHCA staff participates on OKHIE domain work groups to ensure efficiency and effectiveness of planning efforts. Emphasis was placed on collaboration and coordination of activities among stakeholders. The planning efforts were developed in collaboration with OKHIE, the Health Information Infrastructure Advisory Board (HIIAB), the Oklahoma Foundation for Medical Quality Health Information Technology (OFMQHIT), and key stakeholders throughout the State of Oklahoma. Outreach to educate providers on the SoonerCare EHR Incentive Program was coordinated with professional associations and the OFMQHIT. Education materials were made available through operational provider workshops and quarterly meetings to minimize duplication of efforts. Professional associations collaborating on workshops include the Oklahoma State Medical Association (OSMA); Oklahoma Hospital Association (OHA); Oklahoma Primary Care Association (OPCA); Federally Qualified Health Centers (FQHCs); and Rural Health Clinics (RHCs). OHCA completed its Medicaid Information Technology Architecture (MITA) State Self- Assessment (SS-A) in 2009. A gap analysis of As Is MITA business processes and To Be vision were completed and a MITA Roadmap and Transition Plan developed as part of the planning activities for the Medicaid Management Information System (MMIS) Takeover and Fiscal Agent Re-procurement. HIT/HIE requirements were developed for the request for proposal (RFP) and a placeholder added to the MITA Roadmap and Transition Plan. The Statewide HIE Strategic and Operational Plans are not complete at this time. OHCA anticipates potential amendments to the RFP and identified HIT/HIE projects integrated as the statewide and SMHP planning efforts move forward. The approach taken during planning for SoonerCare EHR Incentive Program administration was to review OHCA MITA business processes, and where feasible, integrate the SoonerCare EHR Incentive Program into the standard MITA business processes and OHCA day-to-day operations. OHCA would only develop state-specific business processes where a MITA business or organizational process was not identified. Examples of these processes would include SoonerCare EHR Incentive Program eligibility, verification of SoonerCare member volume, attestation receipt and validation, and provider registration and query to the National Level Registry (NLR). State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 2 Oklahoma’s SMHP will provide readers with an understanding of activities OHCA will employ over the next five years to implement section 4201 Medicaid provision of the American Recovery and Reinvestment Act of 2009 (ARRA). Subsequent sections of the SMHP provide a detailed description of the plan to implement and administer the SoonerCare EHR Incentive Program, including OHCA’s plans to: Establish, administer, and oversee the program Obtain stakeholder input to assist with development and implementation of meaningful use definitions for the SoonerCare EHR Incentive Program Capture attestations and reporting data electronically Monitor and report clinical quality measures to the Centers for Medicare & Medicaid Services (CMS) Disburse and monitor incentive payments Update the State’s electronic systems to improve functionality and interoperability Pursue incentives to encourage adoption, implementation, or upgrade of certified EHRs and meaningful use by eligible professionals (EPs) within their practices and by eligible hospitals (EHs) throughout the state Ensure Privacy and Security of electronic Protected Health Information (ePHI) Prevent fraud and abuse The ultimate goals for the State of Oklahoma are to improve population health and quality of healthcare for Oklahomans, using clinical information obtained through adoption, implementation, or upgrade of certified EHR technology to measure the health outcomes and to reduce cost of healthcare by eliminating duplicate services. OHCA will assist with the achievement of these goals through planning and implementation of the SoonerCare EHR Incentive Program, which will exemplify the benefits of EHR adoption to all providers in Oklahoma. 1.1 Background The SMHP will focus on Medicaid’s role in the overall State strategic plan for HIE and will be reviewed by CMS and ONC to ensure a coordinated, integrated strategy for planning activities. In addition, CMS and ONC are working together internally and with CMS regional offices to ensure a consistent and coordinated strategy for overall State HIT planning activities. This section will include background on ARRA, program requirements, and goals for transformation of healthcare systems. The CMS has implemented through provisions of the ARRA that provide incentive payments to EPs, EHs, and critical access hospitals (CAHs) participating in Medicare and Medicaid programs that are meaningful users of certified EHR technology. The incentive payments are not a reimbursement, but are made to incent EPs and EHs to adopt, implement, or upgrade certified EHR technology. EPs and EHs participating in the Medicaid Provider Incentive Program may qualify in their first year of participation for an incentive payment by demonstrating any of the following: meaningful use in the first year of participation, or that they have adopted (that is, acquired and installed), implemented (that is, trained staff, deployed tools, exchanged data) or upgraded (that is, expanded functionality or interoperability) a certified EHR. Incentive State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 3 payments may also be disbursed to providers who demonstrate meaningful use for an additional five years culminating in 2021.1 The Office of the National Coordinator for Health Information Technology (ONC) has issued a closely related Final Rule that specifies the Secretary’s adoption of an initial set of standards, implementation specifications, and certification criteria for EHRs. Additionally, ONC will issue a separate notice of proposed rulemaking related to the certification of HIT. Goals for the national program include: 1) enhance care coordination and patient safety; 2) reduce paperwork and improve efficiencies; 3) facilitate electronic information sharing across providers, payers, and state lines; and 4) enable data sharing using state HIE and the National Health Information Network (NHIN). Achieving these goals will improve health outcomes, facilitate access, simplify care, and reduce costs of healthcare nationwide. OHCA will work closely with federal and state partners to ensure the SoonerCare EHR Incentive Program fits into the overall strategic plan for the OKHIE, thereby advancing national goals for HIE. 1.1.1 Current HIT Landscape in Oklahoma This section includes a high-level overview of results of HIT Landscape Assessment. Oklahoma is involved in a number of HIT activities that do and will continue to impact SoonerCare members, providers, other state agencies, and partners across the state. The OHCA plans to leverage these existing resources to extend the HIT infrastructure to SoonerCare providers who adopt, implement or upgrade to certified EHR technology and choose access through these networks as their mechanism to participate in HIE. There were a number of initiatives identified that impact SoonerCare members, including several quality improvement initiatives; use of telemedicine to improve access to care for members in rural or underserved areas; electronic eligibility and claims transactions; ePrescribe capabilities, clinical lab ordering and results delivery; and public health reporting. For example, OHCA’s Health Management Program (HMP) contains business processes that have a common purpose to identify clients with special needs, collect information, assess needs, develop treatment plans, monitor and manage the plan, and report outcomes. Utilizing a web-based clinical care management software system for tracking members’ activities meets the needs of many throughout the OHCA organization, but there is a concern that this system is not accessible by all parties responsible for overseeing the management of care (e.g., vendors), nor is it integrated with other systems. Lack of integration between the various software and applications used across the agency impedes the ability to access comprehensive care management information through a single inquiry. In addition, a non-standardized and paper-based referral process is not timely and can be prone to data entry errors. Other HIT activities identified during the As Is assessment will also have a direct impact on the SoonerCare EHR Incentive Program. Broadband penetration across Oklahoma is similar to that in all states, with greater access in more urban areas than in small and rural parts of the State. While any provider can implement an EHR system locally, the ability to participate in an 1 CMS Office of Public Affairs: 202-690-6145. CMS Proposed Requirements for the Electronic Health Records (EHR) Medicaid Incentive Payment Program. December 30, 2009. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 4 exchange network is limited or impossible if broadband access is unavailable or unreliable. Oklahoma stakeholders have applied for and received grants to improve broadband access under several funding sources as identified in Section 2.2.1 of this SMHP. A Beacon Communities grant in excess of $12 million was recently awarded to the Community Services Council of Tulsa to build a community-wide information system. The grant is to leverage broad community partnerships with hospitals, providers, payers, and government agencies to expand a community-wide care coordination and health information system, to increase appropriate referrals for cancer screenings, decrease unnecessary specialist visits, and (with telemedicine) increase access to care for patients with diabetes. The OKHIE was formed to involve public and private sector stakeholders in planning and coordinating statewide HIT activities to promote HIE following receipt of ARRA Section 3013 cooperative grant from the ONC. Additionally, there are a number of Oklahoma Exchange Networks currently operating within the State. The OHCA has an HIT/HIE relationship with other State agencies participating in the HIIAB. The advisory board was created through State legislation to develop a strategy for the adoption and use of EHRs/electronic medical records (EMRs) and health information technologies that would be consistent with emerging national standards and promote interoperability of health information systems between state agencies in Oklahoma. 1.1.1.1 Use of MITA Principles and Methodology In 2009, Oklahoma completed a MITA SS-A and Technical Assessment using MITA Framework 2.0 and developed the MITA Roadmap and Transition Plan for moving the MMIS forward to its envisioned To Be state. This work will be leveraged and integrated into the statewide HIT Landscape to promote statewide cost-effective and efficient use of HIT, where feasible. The same iterative MITA planning process was used, beginning with an environmental scan to assess the As Is readiness of SoonerCare providers and identify gaps. During the planning phase, OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. The work groups then reviewed each SMHP business process to determine if the standard MITA business process would apply to develop a concept of operations for the SoonerCare EHR Incentive Program. As shown in Figure 1, all MITA business processes were reviewed and where feasible the approach adopted was to integrate the SoonerCare EHR Incentive Program business process into OHCA’s corresponding standard MITA business process. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 5 2/25/2010 © 2010 Cognosante PRIVATE AND CONFIDENTIAL MITA SS-A Elements Facilitating Inputs SMHP Requirements MITA State Self-Assessment: As Is and To Be MITA State Self-Assessment: Gap Analysis MITA State Self-Assessment: Executive Visioning MITA Roadmap and Transition Plan MITA Technical Assessment Activities Current Landscape Assessment and To Be Environment Current Landscape Assessment and To Be Environment Specific Steps Necessary to Implement the EHR Program HIT Roadmap and Incremental Approach to Implementation Current Environment, To Be Environment, and HIT Roadmap Develop MITA Technical Assessment Develop MITA Roadmap & Transition Plan Current MITA SS-A Capability Levels based on MITA 2.01 Framework Review information and conduct interviews Figure 1 MITA SS-A to SMHP Alignment The 2009 MITA Technical Assessment will be reviewed following the identification of the Business and Technology gaps and functionality needs to fill the gaps. The Technology Assessment will be updated as necessary and SoonerCare EHR Incentive Program HIT projects integrated into the MITA Roadmap. 1.1.1.2 As Is Environmental Scan The OHCA conducted an environmental scan of the SoonerCare providers to gather information to describe the current state of HIT adoption and use of EHRs in provider offices and hospitals across the State. OHCA elected to scan all currently contracted SoonerCare providers that were of the types considered eligible for the SoonerCare EHR Incentive Program under the proposed rule: Physician, Pediatrician, Nurse Practitioner, Certified Nurse Midwife, and Dentist, and all EHs in the state. OHCA identified 6,199 individual and group providers and 130 hospitals (which included six Indian Health Service (IHS) hospital facilities). Ninety-three FQHCs/RHCs were also identified. As Oklahoma is largely a rural state, extra efforts were made to ensure that scans reached and were responded to by small and rural providers. Focus of the scans remained on in-state providers. During the process of developing the scans, it became apparent that collecting similar information from the FQHCs and RHCs would provide a better understanding of the environment. It was determined that the survey developed for EPs would serve this purpose. To ensure Oklahoma’s large Native American population was also represented, the EP and EH State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 6 scans were administered to the Indian Health Services/Tribal facilities/Urban Indian Clinics (I/T/U) healthcare providers. Eligible Professionals (EPs) were notified of the preliminary scan via the OHCA public SoonerCare EHR Incentive Program web site, fax, and/or email blasts, and through a global banner on the SoonerCare claims billing site. The initial EP scan was also available on the OHCA public web site for providers that may not have been targeted. The preliminary scan was used to identify potential EPs (those who reported meeting the patient threshold but do not currently use an EHR) that expressed an interest in the SoonerCare EHR Provider Incentive Program. An EP follow-up scan was conducted by telephone interview with those who reported use of an EHR/EMR to collect more detailed information to ascertain whether the EHR product used contains any or all required meaningful use data as published in the Final Rule. Results of the follow-up scans related to meaningful use criteria are not available at the time of this SMHP submission. The notice to EHs was sent by email with a link to the survey. The OHA assisted OHCA by notifying hospitals of this opportunity and encouraging their participation in the SoonerCare EHR Incentive Program to adopt or upgrade their systems to certified EHR technology. All hospitals were informed of the importance of the environmental As Is scan and their participation requested. OHCA also participated in several state conferences in the early months of 2010 (OSMA EMR Conference, Rural Health Association, 8th Annual Rural Hospital Conference), and OHCA used these opportunities to present the SoonerCare EHR Incentive Program, notify participants about the scans, and request participation. Oklahoma environmental scans included several questions on Internet access and all information obtained from the scans will be shared with the OKHIE stakeholders to ensure all statewide stakeholders are working from the same knowledge base. OFMQHIT, the State’s Regional Extension Center entity, will be notified of the respondents indicating they would like assistance with selecting and/or using certified EHR technology. 1.1.1.3 Environmental Scan Results Oklahoma’s SoonerCare providers are in various stages of adoption, with larger, more urban organizations generally more automated than smaller, rural practices. Mid-sized organizations, such as FQHCs/RHCs and provider groups are in various stages of using, adopting, and implementing EHR/EMR solutions. Many of Oklahoma’s smaller agencies and clinics have expressed interest in the SoonerCare EHR Provider Incentive Program, but will require assistance and support to adopt and implement EHR capability. Below in Figure 2 are the results of overall EHR adoption across the different provider groups targeted in the scans. “Presumed eligible” providers were those that self-reported meeting the patient volume requirements established in the proposed rule and were enrolled in an eligible provider type. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 7 Figure 2 Percentage of Providers Reporting EHR/EMR by Group OHCA initially targeted 6,199 health professionals; 505 were unable to be contacted, so a total of 5,694 were contacted to participate in the scan. OHCA received responses from 2,029, or 36 percent of the targeted health professionals. Of the 2,029 health professionals that responded to the initial survey, 65 percent are in urban areas, 35 percent are rural. Those indicating they had an EHR/EMR were 47 percent of the total number of respondents. Rural health professionals indicating they had an EHR/EMR were 46 percent of the total respondents; those without, 54 percent. Urban health professionals indicating an existing EHR/EMR were 47 percent of the total respondents; those without were 53 percent. Figure 3 depicts the responses for EPs by Provider Type. Figure 3 Non-Hospital Responses by Provider Type IHS and Tribes Response by Provider Type are shown in Figure 4 below. I/T/U providers have the highest rate of current EHR adoption of any provider category in Oklahoma, presumably because they have access to EHR capabilities through the federal Resource and Patient Management System (RPMS) system. Of the 475 I/T/U health professionals that responded, 88 percent indicated they had an EHR/EMR. Of all I/T/U provider respondents, 99 percent expressed an interest in participating in the SoonerCare EHR Incentive Program. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 8 Figure 4 Indian Health Service (IHS) and Tribal Providers Of the 80 hospitals that responded, 44 percent are in urban areas, 56 percent in rural. Figure 5 shows those indicating they had an EHR/EMR were 42 percent of the total number of respondents. Rural hospitals that indicated they had an EHR/EMR were 23 percent of the total rural respondents; those without, 35 percent (with 15 percent missing responses). Urban hospitals indicating an existing EHR/EMR were 54 percent of the total; those without were 26 percent (with 9 percent missing responses). Figure 5 Hospital EHR Environment As shown in Figure 6, 58 percent of the hospitals intend to install or make changes to an EHR/EMR system. Figure 6 Hospital Future EHR Plans State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 9 Of all hospital respondents shown in Figure 7, 61 percent intended to participate in both the Medicaid and Medicare Provider Incentive Programs. Overall, 80 percent of the respondents expressed an interest in participating in the SoonerCare EHR Incentive Program. Figure 7 Provider Participation Selection As shown in Figure 8, 64 percent of hospitals reported having access to broadband services. Figure 8 Hospital Broadband Access Figure 9 below identifies hospitals reporting EHR/EMR with capability to collect data as required for meaningful use reporting. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 10 Figure 9 Hospital Existence of Meaningful Use Criteria Figure 10 shows Smartnet at 21 percent is the HIE with the most hospital participation. Figure 10 Hospital Participation in HIE State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 11 1.1.2 Vision of HIT Future This section will include a description of vision of HIT future in Oklahoma. OHCA programs will leverage the clinical data made available through electronic health record technology to achieve their goals and vision for improving population health outcomes and quality of care for Oklahomans. OHCA programs plan to leverage the clinical data made available to OHCA through provider adoption and meaningful use of certified EHR technology to meet the federal goals to improve population health, reduce medical errors, improve health outcomes, and empower SoonerCare members to participate in their healthcare. OHCA vision for the future anticipates improvements in health outcomes, clinical quality, and efficiency in multiple physical and behavioral healthcare management environments with increased usage and interoperability of EHR systems. Best practices and trends in direct care and care coordination efforts can be identified by expanding reporting abilities and evaluating outcomes data. Potential and actual cost impact can be calculated to guide further program development. Utilization review endeavors can be enhanced from both pre-payment and post-payment perspectives. Through developments in data exchange through HIEs, provider access to data will further enhance care coordination opportunities, eliminate duplication of service, and foster identification of appropriate levels of care. Similarly, OHCA, on behalf of SoonerCare members, will be able to more effectively identify serious quality of care issues, gaps in care, member compliance issues, and member behavior trends in areas such as ER utilization. OHCA’s MMIS is poised to move forward to connect and provide services to providers attempting to achieve meaningful use. Additional functionality to become interoperable will be added as needed to provide the greatest benefit from the MMIS data. The MMIS will develop the capability to receive and interpret Health Level Seven (HL7) messaging structures. OHCA secure provider and member portals under development at this time will be completed, providing more timely exchange of data and reduced data processing errors that occur today due to time lag in getting information entered into the MMIS. The Electronic Provider Enrollment (EPE) system will be modified to accommodate registration and attestation data related to the SoonerCare EHR Incentive Program and interface with the NLR. The EPE system is used to allow providers to electronically attest and is not an enrollment into the SoonerCare EHR Incentive Program. This attestation is under secure electronic signature and in itself a contract modification. The providers will not be required to submit hard-copy attestation by mail. However, providers may submit supporting documentation using email or fax. Access to the clinical data from providers will be through direct input into the EPE system or the OKHIE. Security of clinical data will remain a priority for both OHCA MMIS and the OKHIE and individually identifiable health information will be exchanged only as permitted by Health Insurance Portability and Accountability Act (HIPAA) for purposes of treatment, payment, and health plan operations. Security of data will be maintained as required by HIPAA, required for federal systems, and to meet ARRA security requirements. Collaboration with Oklahoma Health Information Exchange Trust (OKHIET) participants and HIIAB members will continue to improve HIE and standardization of data formats and metadata descriptions will occur. National standards will be adopted and used by all participants in these exchanges as soon as available. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 12 A comprehensive vision for statewide HIT/HIE is not available at this time because OKHIE Strategic and Operational Plans are not yet complete and the statewide effort is still in the early stages. Thus, OHCA is submitting partial completion of this section of the SMHP, which will be updated after further collaboration with OKHIE and further development of statewide plans are available. OHCA plans to align its vision with the statewide vision once developed. During the implementation phase, OHCA will continue to have dialog and collaborate with OKHIE, HIIAB, and other stakeholders to define how the OHCA and OKHIE visions can become reality. 1.1.3 Provider Incentive Program Implementation This section will include a high-level overview of the Provider Incentive Program and actions taken to implement the program. A broad range of business and information technology (IT) staff from OHCA operations participated in the planning effort to ensure all impacts to program operations would be identified and a smooth plan for implementation put into place. The SoonerCare EHR Incentive Program will be integrated into the current organizational structure of the OHCA under the authority of the SoonerCare Operations Directorate. Upon program implementation, a core team of SoonerCare operations unit directors will perform operational control and monitoring processes for the program. Each unit director will leverage existing, well-established business processes (MITA and State-specific), to ensure successful implementation of the program. OHCA will utilize existing business processes and established infrastructure to comply with all CMS reporting requirements. Any new reporting requirements will be incorporated into the existing reporting responsibilities. Communications and outreach to the provider community are considered of utmost importance to the agency. The Outreach, Education, and Information Work group is responsible for developing a planned approach for internal and external communication to ensure all stakeholders are adequately informed on progress made toward the implementation of the SoonerCare EHR Incentive Program. A web page is currently available to inform providers of actions taken by OHCA to implement the program, as well as who is eligible and how to enroll. During the Planning Phase, OHCA Provider Relations staff participated in numerous meetings with associations and providers to explain the program and encourage providers to adopt, implement, or upgrade EHR technology within their practice settings and hospitals. A Communications Plan (Appendix A) was developed during the planning phase and will be further refined during implementation. During the implementation phase, a procedure manual will be developed to communicate program policy and procedures for eligibility, attestation, registration, patient volume, reporting meaningful use measures, requesting payment, recoupment, and to advise providers of the appeals process. Another important ongoing activity is the review of regulatory requirements, identification of policy and regulatory changes. A comprehensive review of new policy required to implement the SoonerCare EHR Incentive Program will occur after the Final Rule is released. OHCA anticipates a new section of policy dedicated solely to the governance of the program. Based on the assessment, areas that must be addressed include policy related to SoonerCare patient volume standards, the definition of pediatrician, Meaningful Use criteria, and payment to EPs. Where no specific written policy exists, OHCA will defer to the Final Rule issued by CMS. Relevant sections of OHCA Administrative Code (Title 317) Chapter 2 Grievance rules will be State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 13 revised to incorporate provider appeals processes related to EHR incentive payments. No changes to, or new state laws, are expected at this time. Plans are underway to enter into data exchange agreements with surrounding states in order to obtain member eligibility and patient volume data. OHCA will leverage the work currently underway by OKHIE and continue its participation in multi-state efforts to build on the results from Health Information Security and Privacy Collaborative (HISPC) and focus on the issues of interoperability agreements, privacy laws, rules, and regulations, security of systems and data and engaging providers, consumers, and OKHIE in discussions on privacy and security as it relates to interstate data exchange. All providers (individuals and hospitals) who receive incentive payments must have existing Provider Agreements with OHCA. Eligible professional types include those identified in the regulation. When ready to apply for incentive payment, the provider must execute a contract update through OHCA’s EPE system and supply the new information necessary to receive payment (e.g., patient volume, NLR registration, meaningful use measures, etc.). The provider must enter the required electronic attestation statements. When information is processed and verified the system will send an acceptance letter to the provider, making the contract update effective. OHCA plans to use its existing SoonerCare Call Center Operations at the Fiscal Agent to respond to questions from EPs and EHs about the SoonerCare EHR Incentive Program. OHCA will validate provider enrollment with the NLR for Medicare or other State enrollment, National Provider Identifier (NPI), Taxpayer Identification Number (TIN), as well as the State licensing board, and check CMS sanction list prior to annual payments being made. The EPs and EHs or CAHs must complete their respective attestation statements in the EPE system OHCA will review the provider attestation information and determine eligibility for payment. Provider expenditures/accounts payable (AP) will be entered manually into the MMIS and the SoonerCare EHR Incentive Program funding code applied. Providers determined to be eligible for incentive payments will be identified and payments made on a monthly basis (e.g., all providers identified as eligible in January 2011 would receive Year 1 payments in February 2011). OHCA will use the MMIS to validate professional and hospital eligibility, calculate appropriate payment amounts, and make payments through electronic funds transfer (EFT). OHCA will implement business processes and verification methods to assure appropriate payments are made to EPs. To ensure that no amounts higher than 100 percent of federal financial participation (FFP) will be claimed for reimbursement, the provider incentive payments will be reported on a separate line on the CMS 64 (MAR1060/1062 report). This report will be reviewed for accuracy and deficiencies. The State has no current plans to designate any entities for promoting the adoption of certified EHR technology. System controls will be implemented and tested in the MMIS Financial Sub-system to ensure appropriate payments and reporting. OHCA has participated in several workshops to encourage providers to adopt, implement, or upgrade certified EHRs. Coordination with the Oklahoma Foundation for Medical Care Regional Extension Center (OFMQHIT) is ongoing and OHCA provides leads and assists providers in contacting the OFMQHIT for assistance. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 14 OHCA will use the meaningful use measures identified in the Final Rule for the first year of the program. Annual review of meaningful use measures will occur and changes made through Oklahoma’s policy change process. OHCA is dependent upon the NLR database to support the registration of EPs and EHs into the SoonerCare EHR Incentive Program. In the event the NLR is not available on January 1, 2011, OHCA will compare the registration requests received prior to NLR availability to the data in the NLR when it becomes available. OHCA will utilize its existing internal process to validate the provider submission and for discrepancies recoup the EHR Incentive payment for any payments made in error. 1.1.4 MITA HIT Roadmap This section will include graphic depicting the planned HIT Roadmap. OHCA recently provided to CMS the MITA Roadmap and Transition Plan developed for the MMIS Re-procurement activities. The Roadmap is provided in Figure 11 below. This work can be leveraged and integrated into the statewide HIT Landscape to promote statewide cost-effective and efficient use of HIT, where feasible. OHCA has identified the MMIS changes needed to solution the immediate need to implement the SoonerCare EHR Incentive Program within the EPE and MMIS systems. An Implementation Advance Planning Document (IAPD) will accompany this SMHP for funding of these systems change requests. The MITA Roadmap contains a placeholder for immediately needed changes to the MMIS to support the SoonerCare EHR Incentive Program payments. This section of the MITA Roadmap will be updated to add the HIE/HIT projects arising from the SMHP planning activities. OHCA is deferring some of its longer-term planning and benchmark development for HIT/HIE since the OKHIE Strategic and Operational Plans are not complete at this time. OHCA dialog with the HIIAB, Broadband grantee, and Beacon Communities grantee is also underway. When details of these projects are fully understood, including a timeline for projects, this SMHP will be updated and a separate IAPD request for funding will be submitted. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 15 Figure 11 MITA Roadmap OHCA goals were aligned with the national goals to encourage adoption and meaningful use of certified EHR technology and promote healthcare quality and information exchange. OHCA goals promote exchange of individually identifiable health information between SoonerCare providers for care coordination of SoonerCare members. The program is most interested in exchange of the following types of clinical data: prescription drug information; office visit encounters; laboratory diagnostic tests to fill treatment gaps; personal health screening and records for population and patient health outcomes research; service data to link individuals to the Oklahoma Department of Mental Health and Substance Abuse Services (ODMH) system to coordinate care between medical treatment with mental health treatment; clinical data for precertification of services upon request; service data to identify duplicate diagnostic testing and medical errors; patient-centric data to assist SoonerCare patients in managing their health status; and electronic health information needed at point of care for treatment. OKHIE goals include exchange of clinical information to multiple healthcare providers while keeping personal health data safe and secure; making time-critical data available to providers in an ER, office, and/or hospital setting; data to reduce redundant testing by making lab results available; data that reduces patient hassle factors; service data to improve coordination of preventive services; and clinical quality of care data to improve quality and at the same time contain rising healthcare costs by reducing redundant testing. OHCA’s vision includes MMIS and related IT systems exposure of services through an interface to OKHIE. Initially, three types of services will be shared: State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 16 1. OHCA data exposed to payers to aid in administration of healthcare programs (e.g., electronic validation of health plan coverage and coordination of benefits (COBs). 2. OHCA access to shared services clinical data from EHRs. 3. OHCA administrative services necessary to administer the SoonerCare EHR Provider Incentive Program. OHCA is the State Medicaid Agency designated to administer the Provider Incentive Program in Oklahoma. Responsibilities of this role include identifying and tracking EPs and EHs attestations of meaningful use, SoonerCare patient volume threshold, NLR registration information, payments to providers, and receipt of meaningful use measures. OHCA must administer payments to EPs using an established set of rules and prepayment audit processes to verify payments are correct and accurately calculated, recoupment activities occur for any duplicate payments, and FFP drawdown is audited for appropriateness of monies received from the federal government for provider payments and administrative services. Modifications to the MMIS and EPE systems are required to support development of program operation policies and administrative procedures. During the implementation phase, OHCA must develop the policies and procedures necessary for accountability under ARRA. OHCA is charged with encouraging and assisting SoonerCare providers in adoption and conversion to certified EHR/EMR. Outreach to the providers is ongoing and OHCA is collaborating and coordinating these efforts with the OFMQHIT. OHCA is also studying any changes necessary to the current ePrescribe program and point-of-sale (POS) system to assist providers in using e-prescribing. OHCA will track provider participation in the incentive payment program in the Oklahoma MMIS. In addition, OHCA will submit program participation data to CMS including data for the number, type and practice location(s) of providers who qualified for an incentive payment on the basis of having adopted, implemented, or upgraded certified EHR technology, as well as for providers who qualified for an incentive payment on the basis of having meaningfully used such technology. OHCA will evaluate transactions from the NLR to determine if providers have already received Medicare payments or payments from other states that would make them ineligible for SoonerCare Incentive Payments. In the event that the NLR is not available January 2011, OHCA will compare the registration requests received prior to NLR availability to the data in the NLR. When discrepancies are found and investigated, OHCA will utilize its existing internal process to validate the provider submission and recoup the provider Incentive payment if necessary. The OHCA Program Integrity (PI) unit supports the investigation of potential misuse by providers and clients of the SoonerCare program and other programs administered by OHCA. PI staff will add review of provider incentive payments to current audit plans. To demonstrate meaningful use requirements and report measures, the certified EHR products adopted, updated, and implemented by clinicians will need to be able to capture data elements report measures identified for Stage 1, Stage 2, and Stage 3. The clinician must be able to review EHRs from other clinicians, download information into an EHR (e.g., lab results), and push EHR data from their systems to others if coordination of care goals are to be met. How this will occur in Oklahoma will be defined as the details of the OKHIE strategic and implementation plans become available. During implementation, OHCA will determine what information will be State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 17 included in an EHR, what data standards will be used until national meaningful use standards are finalized, and how Medicaid and ARRA funds can be leveraged to support a sustainable HIE infrastructure. The ARRA/HIE/EHR enhancement function must accept an interface with the following: NHIN, Private Insurer EHR systems, other State agency EHR systems; Facility EHR systems, and Clinician EHR systems. 1.1.5 Recommendations This section will include recommendations for implementation. OHCA makes the following recommendations for HIT/HIE implementation: 1. To more efficiently coordinate care for SoonerCare members, continue dialog with HIIAB state agencies and OKHIE on HIE. Promote standardized data formats and metadata for use in shared services and look for opportunities to leverage IT assets. 2. Consider cost efficiencies and sustainability of projects as well as funding sources available as an integral part of governance discussions for the statewide HIE. 3. SoonerCare providers who adopt, upgrade, or implement certified EHR technology will benefit from use of standardized data and metadata to make shared services interoperable with their EHR technologies. 4. Ensure privacy and security requirements for HIPAA and ARRA for ePHI information transmitted by OHCA and OKHIE are met. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 18 2 CURRENT HIT LANDSCAPE ASSESSMENT – THE “AS IS” ENVIRONMENT This section will describe existing resources available and how the state will leverage these existing resources already devoted to HIT. The HIT landscape will include an assessment of current rates of EHR adoption and establish a baseline for “As-Is” state of environment. The OHCA is one of only seven stand-alone Medicaid agencies in the country. OHCA was formed by legislation and is the primary entity in the State of Oklahoma charged with controlling costs of state-purchased healthcare. It currently handles federal funding for Medicaid and State Children’s Health Insurance Program (SCHIP) programs and is experienced in handling all required federal reporting for those programs as well as reports requested ad hoc by federal and state auditors. In addition, there is organizational knowledge as a Transformation Grant recipient and OHCA prepares regular progress reports and evaluations of the grant activities. The SoonerCare program covers over 650,000 lives with a variety of service delivery models, including Oklahoma’s public/private premium assistance program, Insure Oklahoma (IO). As the Medicaid agency, it has dedicated medical, care management, quality assurance, planning, and IT divisions, as well as provider and member services operational divisions. Oklahoma’s Medicaid program puts special emphasis on collaboration within the community of members, providers, and partner agencies to meet the many needs of Oklahomans. The technology division manages multiple large IT and consultant contracts as part of the MMIS and is skilled at the procurement process. Oklahoma’s MMIS is known for its innovation and ability to adapt quickly to new processes. The Oklahoma MMIS was the first MMIS to implement Internet-based claim, eligibility, and other administrative transactions all in real-time operation. The SoonerCare program is one of the first in the nation to implement the medical home model into its Medicaid delivery system. 2.1 Current HIT Activities and Impact on SoonerCare Members This section will describe current HIT activities underway in Oklahoma and their impact on Medicaid beneficiaries and any EHR technology adoption and relationships with other entities within the state. Oklahoma is involved in a number of HIT activities that do and will impact SoonerCare members, both within individual agencies and organizations and across multiple partners. A comprehensive list of statewide HIT/HIE projects is not available at this time because the SHIECAP Strategic and Operational Plans are not yet complete. Thus, OHCA is submitting partial completion of this section of the SMHP, which will be updated after further collaboration and SHIECAP and statewide plans are available. A short list of Oklahoma, OHCA, and public health HIT activities identified to-date include the following: Health Management Program (HMP). The SoonerCare HMP is an ongoing quality improvement initiative aimed at improving the lives of Oklahomans with chronic disease as well as reducing future incidence of chronic disease. This is accomplished through a program based on the Chronic Care Model2 where the main principle is to pair an informed and engaged patient with a prepared and proactive provider in order to create the best possible health outcome. A nurse case management strategy accomplishes creation of an informed and activated member. The other key component to the HMP is the necessary support to assist the provider in becoming more prepared and proactive. This component is commonly known as Practice Facilitation. Practice Facilitation involves specially trained nurses working as free consultants State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 19 who help providers improve their office efficiency and identify methods aimed at improving the quality of care. A portion of this assistance involves the implementation of an electronic health management information system (HMIS) or chronic disease patient registry. This web-based tool, which is property of our HMP vendor, Iowa Foundation for Medical Care, allows the practice to enter member data and track members over time so that members receive all the appropriate tests and treatment recommended for their chronic conditions. The HMIS/registry currently contains disease modules on coronary artery disease, hypertension, diabetes, heart failure, asthma, tobacco cessation, and preventative care. Practices are coached by the facilitators to learn the system and adapt their day-to-day processes to use of the registry.2 With the advent of the OFMQHIT practice advisors, there is a potential for overlap in primary care offices with the HMP practice facilitators. HMP staff is working closely with the OFMQHIT staff to coordinate programs in order to avoid duplication of services. OFMQHIT practice advisors, while focusing primarily on selection and implementation of EMRs, conduct similar workflow assessments to those of the HMP practice facilitator in order to help the practice assess their specific needs in regards to EMR. Also of note, the registry mentioned above is currently near the end of beta testing for an interface that has been built for connection to EMRs. Successful interface will avoid the need for duplication of data entry by providers. Upon implementation, the HMP practice facilitators will be assisting practices in connecting their EMRs to the registry in this manner. Since there are many common goals between the two services and the potential for the practice becoming overwhelmed with technical and process improvement assistance, OHCA will coordinate closely with OFMQHIT center staff to determine appropriate timing of our respective interventions with each common primary care office. OHCA HMP leadership, along with leadership of the HMP vendor has developed a new “collaborative” model of practice facilitation. In this model, instead of delivering service on a steady basis over a pre-determined period of time, primary functions of practice facilitation services have been isolated into core components or services that can be delivered on a customized basis according to the needs of the practice. OHCA has begun work with OFMQHIT leadership to initiate this collaborative practice model and with OPCA, which will serve as a subcontractor to OFMQHIT to fulfill OFMQHIT services to community health centers. Customization of the existing service delivery will allow practices to maximize their opportunity for technical assistance and quality improvement efforts. Telemedicine. OHCA has contracted with numerous SoonerCare providers who utilize telemedicine to provide healthcare services. Telemedicine service is a different way to provide members access to quality healthcare. These services provide communication between a medical specialist and a SoonerCare member by either audio, video, or data interaction. This communication, done with the member present, is in real-time or near real-time. The goal of this service is to expand specialty healthcare services to rural and underserved areas of Oklahoma and improve healthcare for all members. Approved SoonerCare telemedicine networks are identified at: http://www.okhca.org/providers.aspx?id=10253 Electronic Eligibility and Claims Transactions. OHCA is the State’s Medicaid agency and the largest payer in the State. OHCA processes a monthly average of 3.1 million claims, of which 96 2 Copyright 2010. The MacColl Institute. The Improving Chronic Illness Care program is supported by The Robert Wood Johnson Foundation, with direction and technical assistance provided by Group Health's MacColl Institute for Healthcare Innovation." www.improvingchroniccare.org State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 20 percent are submitted as electronic transactions or entered directly via the Internet. Claims are processed in real time and are paid weekly. Electronic Prescribing and Refill. Oklahoma participates in the SureScripts network to connect its providers to pharmacies. E-prescribing is an integral feature of Oklahoma’s recommended EHRs and EMRs. It is being implemented aggressively with each installation and as vendors make this functionality available at the hospital level. The SoonerCare formulary is provided to the ePrescribing vendor (Cerner) and Epocrates for participation in their services. Oklahoma providers have access to the formulary. A baseline for ePrescribe in Oklahoma was derived from comparison of SureScripts 2008 report findings for Oklahoma compared to 2009. The SureScripts national 2008 reports showed: 1. Request for Rx benefit – 6.18 percent of patient visits with a Prescription benefit request and 3.06 percent of patient visits with a Prescription benefit request response, Oklahoma ranked 31st in the country 2. Rx history request – n/a 3. Prescription routing showed 2.09 percent of all prescriptions were routed electronically. Looking at 2009 data SureScripts released on July, 14, 2010, Oklahoma jumped from 2 percent of eligible prescriptions being routed electronically in 2008 to 10 percent in 2009. This is a five-fold increase and with similar increases in 2010 and 2011, OHCA should be able to meet the 40 percent benchmark established in Table 6 of this SMHP. Electronic Clinical Laboratory Ordering and Results Delivery. Currently, the State has primarily point-to-point interfaces between hospitals, major private lab companies, and physician offices that have EHRs. There is a variety of interfaces that have gone live, some with results only coming into a provider’s practice uni-directionally; however, there are a few bi-directional interfaces that have gone live and permit clinical orders and receipts. Bi-directional interface is the preferred method for safety and efficiency. Within the hospital setting, lab order and receipt is typically electronic when Computerized Physician Order Entry (CPOE) is active. Some institutions are also exploring a spoke and hub model to connect interfaces to network hubs and reduce the overhead and maintenance issues associated with point-to-point interfaces. There are two tests performed exclusively by Oklahoma State Lab: PKU and lead screening. Through shared services planned through the HIIAB initiatives, Oklahoma will be able to exchange PKU and lead screening information with providers through the OKHIE. Oklahoma Public Health is working on a PKU detection and lead screening statewide initiative to upgrade systems information added to lab contracts and require labs to participate in HIE when it is available. Contract language includes: “Provider shall transfer test results electronically to a State-approved health information exchange in Oklahoma whenever such exchange is available and subject to federal and state law, results shall be provided in HL7.2.3.1 standard format or higher.” Electronic Public Health Reporting. The Oklahoma State Department of Health (OSDH) has an informal messaging group in the IT Service, which is comprised of OSDH IT personnel, as well as application specific contractors. This group has made significant advances over the past State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 21 three years in messaging electronic laboratory reports (ELR) as well as in messaging disease data to the Centers for Disease Control and Prevention (CDC). The group has additionally made progress in the development of data exchange mechanisms for the Oklahoma State Immunization Information System (OSIIS). The group is moving to a messaging infrastructure that is dependable, yet robust, dynamic, and capable of handling a multitude of emerging OSDH messaging needs. This team has established the use of HL7 as a standard and is committed to conforming to national and international standards as a best practice. The HIIAB has created three task forces to examine and recommend approaches for sharing data services for meaningful use data. The focus of these work groups is exchange of clinical laboratory, immunization, and insurance coverage information. The objective will be to share a single connection to the statewide HIE for each of these services. Through this connection, the OSDH will be able to communicate lab and immunization information with providers via their EHR systems and the HIE. Quality Reporting Capabilities. Through a number of organizations, Oklahoma is making progress toward enhanced quality reporting capabilities. Current models involve the usage of claims-based data, but it is clear this information is limited and attempts to modify quality improvements based on this data have had limited success at a high cost to the delivery of health care. Oklahoma has a significant amount of activity reporting Physician Quality Reporting Initiative (PQRI) information and hospital quality measures. As Oklahoma develops the “network of networks” model, more complete reports with a variety of data will be compiled at the local network level and submitted to appropriate governing bodies. One of the primary goals of the planning process will be to determine what type of reports with what type of data (identified and de-identified) will be permissible at the local and state network level to allow anticipated quality reporting to meet national requirements such as those endorsed by the CMS. On a public health level, the State immunization data are compiled via the OSIIS system, with good penetration in the SoonerCare population via public hospitals, but poor penetration into the private offices and hospitals across the State. OFMQ, Oklahoma’s Medicare Quality Improvement Organization (QIO), is assisting 60 primary care practices with reporting preventative quality indicator measure data (similar to PQRI) to CMS. Data measures for this project include mammography, colon-rectal cancer screening, and adult immunizations (specifically, influenza and pneumonia). This will be a key component of the model from the local EHR to the local network that will in turn help generate quality reports to reflect the overall public health of Oklahoma. 2.2 Current HIT Activities and Impact on SoonerCare EHR Incentive Program This section will describe what other activities are currently underway in OK that will likely influence the direction of the EHR Incentive Program over the next five years Oklahoma has become involved in a number of more recent HIT activities that will or have the potential to impact the SoonerCare EHR Incentive Program. Various entities in Oklahoma have received funding with possible HIT aspects, such as the Congressionally Mandated HIT Grant awarded to Norman Regional Health System in the amount of $377,190.00. This grant supports HIT projects such as telehealth, EHRs, and other HIT. As more information is gained, Oklahoma will work with the awardees to incorporate their efforts into the statewide HIE strategic plans. A comprehensive list of statewide HIT/HIE projects is not available at this time because the SHIECAP Strategic and Operational Plans are not yet complete. Thus, OHCA is submitting State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 22 partial completion of this section of the SMHP, which will be updated after further collaboration and SHIECAP statewide plans are available. 2.2.1 Broadband Internet Access in Oklahoma Broadband penetration across Oklahoma is similar to that in all states, with greater access in more urban areas than in small and rural parts of the State. While any individual provider can implement an EHR system internal to the organization, the ability to participate in an exchange network is limited or impossible if broadband access is unavailable or unreliable. Since there is little existing information on the extent of broadband access in Oklahoma, the environmental scans included several questions on Internet access, the results of which will be shared with OKHIE stakeholders. The proposed broadband Fiber Backbone for Oklahoma is shown in Figure 12. Figure 12 Oklahoma Proposed Broadband Fiber Backbone There are numerous federal funding agencies for broadband efforts and Oklahoma stakeholders have applied for and received grants under several funding sources. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 23 Funding for mapping and planning activities: The National Telecommunications and Information Administration (NTIA) Award Oklahoma Office of State Finance (OSF) has received approximately $1.6 million in funding for broadband data collection and mapping activities over a two-year period OSF has received nearly $500,000 for broadband planning activities over a five-year period in Oklahoma Funding for expanding infrastructure and services: Department of Commerce Broadband Technology Opportunities Program (BTOP) Awards Allegiance Communications: Allegiance Fiber to the Home Project; $28,619,485. Covers Arkansas, Kansas, Oklahoma, and Texas. Pine Telephone Company, Inc.: Broadband Grant for Isolated Southeastern Oklahoma/Choctaw Nation/Rural/Non-Remote Areas Project; $9,472,078 One Economy Corporation: 21st Century Information and Support Ecosystem: Make it Easy Where You Are; $28,519,482. Funding supports 32 states including Oklahoma. US Department of Agriculture Broadband Initiative Program (BIP) Awards Pioneer Long Distance, Inc.: The Western Oklahoma Wireless (WOW) Project; $1,819,349 loan and $1,783,322 grant. Provide wireless broadband service to unserved and underserved rural areas in western Oklahoma. Panhandle Telephone Cooperative, Inc.: The Western Oklahoma Broadband Infrastructure Development Project; $3,366,188 loan, $10,098,562 grant, and $23,297,597 of private investment. Provide a broadband infrastructure to rural areas within the western Oklahoma panhandle area. Pride Network, Inc.: $12,811,071 loan $6,309,931 grant. Construct a fiber-to-the-premises (FTTP) telecommunications infrastructure, with a WiMAX service-extension overlay, to bring advanced broadband services to rural communities in Texas. A small part of this network (less than 5 percent) will serve an area in Oklahoma. 2.2.2 Beacon Community Grant A Beacon Communities grant for $12,043,948 was recently awarded to the Community Services Council of Tulsa to build a community-wide information system. The grant is to leverage broad community partnerships with hospitals, providers, payers, and government agencies to expand a community-wide care coordination and health information system, to increase appropriate referrals for cancer screenings, decrease unnecessary specialist visits, and (with telemedicine) increase access to care for patients with diabetes. The Principal Investigator of the Beacon Community Grant is a key advisor to the OKHIE and representatives from Tulsa participate on the OKHIE domain work groups. The Beacon Community is just beginning its planning following the grant award. Collaboration with SHIECAP and OHCA will be important to ensure security and interoperability of clinical data as well as access to NHIN through OKHIE. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 24 2.2.3 Oklahoma Health Information Exchange (OKIE) Major HIT/HIE activity in Oklahoma is under an organization called the OKHIE, which involves public and private sector stakeholders in planning and coordinating statewide HIT activities. The Oklahoma State Health Information Exchange (HIE) Cooperative Agreement Program (known as SHIECAP) operates under the OKHIE. OKHIE provides program oversight and is creating HIE strategic and operational plans. OKHIE members represent many state interests: tribes, providers, insurance companies, patients/consumers, health care associations, HIT vendors, health care purchasers and employers, public health and other state agencies, professional health institutions, and clinical researchers. The planning effort is conducted through an open process and in communication with the larger health care community. OHCA has an HIT/HIE relationship with the other State agencies’ participating in the HIIAB. OHCA chairs this board which was created through State legislation to develop a strategy for the adoption and use of EHRs/EMRs and health information technologies that is consistent with emerging national standards and promotes interoperability of health information systems. The advisory board consists of 10 members who are appointed by directors of the following agencies: OHCA, OSDH, ODMH, Department of Human Services (ODHS), State and Education Employees Group Insurance Board, Insurance Department, Department of Corrections, State Department of Rehabilitative Services, and City-County Health Departments of Tulsa and Oklahoma City. 2.2.4 Federally Qualified Health Clinics and Rural Health Clinics OHCA works closely with the Oklahoma Primary Care Association, representing the FQHCs and RHCs. Currently no funding has been directed toward this group and they have not received any funding for health transformation technology or electronic health records from Health Resource and Services Administration (HRSA). OHCA will continue to look to engage the FQHCs/RHCs in HIT opportunities in the future. 2.2.5 Oklahoma Exchange Networks There are a number of exchange networks that currently operate within Oklahoma. These will be more fully documented in the network scan, which is under the direction of the State’s SHIECAP effort and is still under development. At this time, OHCA is not directly participating in an operational exchange network. Some information on current provider participation in an exchange network was collected via the 2010 environmental scans. More hospitals than health professionals currently participate in an existing exchange network; 21 percent of responding health professionals and 30 percent of responding hospitals indicated they are currently participating. Additional information on network participation is still being collected via ongoing environmental scans of SoonerCare providers. Networks currently in existence in Oklahoma are listed below. Results of the scan will be available mid to late July, 2010. This SMHP will be updated at that time. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 25 Table 1 Existing Regional Health Information Exchange (HIE) Efforts Regional Network Providers Covered Status Planning Support Duncan Network Hospital physician exchange Planning SMRTNET Greater Oklahoma City Hospital Council (GOCHC) Bordered by Norman, Edmond, Shawnee, and Yukon. Includes 13 hospitals and many other provider types Operational SMRTNET Greater Tulsa Health Access Network (GTHAN) Tulsa area Planning SMRTNET Health Alliance for the Uninsured 16 clinics in the OKC area Construction SMRTNET Heartland Healthnet 5 Hospitals and 20 Clinics Operational Internal to Organization Indian Health Service (IHS) using RPMS At I/T/U facilities Live at certain facilities and in planning at others IHS Norman Physician Hospital Organization Norman eClinicalworks providers 3 hospitals, 225 providers planned, 15 Clinics live Testing/Pilot/Live Planning NPHO/SMRTNET Northeast Oklahoma 14 counties Operational SMRTNET OPCA State community health centers Finalizing planning, awaiting federal funding SMRTNET OSMA OSMA physicians In early planning SMRTNET State Agency Network State agencies On hold after request for information (RFI) pending State planning issues State HIE Planning 2.2.6 Recommendations This section will present the Medicaid recommendations to the State HIT Coordinator on how OHCA will proceed with supporting Oklahoma’s HIE/HIT initiatives. As discussed throughout the SMHP, OHCA is an active participant in Oklahoma’s planning phase to develop statewide HIE. As well as serving as a standing member on the SHIECAP work group, OHCA chairs the HIIAB tasked with preparing State agencies to participate in the exchange. As the State’s Medicaid agency, OHCA is ready and willing to create any kind of data bridge that needs to exist in the MMIS to facilitate the exchange of health information. OHCA is working with other State agencies through the HIIAB to develop the networking necessary to share State agencies’ health information when the capability becomes available statewide. OHCA is also working with regional/community-based resources such as health access State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 26 networks (HANs), Value-added networks (VANs) and Regional Health Information Organizations (RHIOs) to develop and/or leverage resources already in place. OHCA's purpose is to ensure that SoonerCare providers are ready and able to participate in the HIE and to assist them in accessing federal and state opportunities for this endeavor. Through the SoonerCare EHR Incentive Program, OHCA has the ability to reduce the financial burden on specified providers who choose to obtain and meaningfully use certified EHR technology. With its MMIS capabilities, the SoonerCare EHR Incentive Program and our connection to the medical community, OHCA has the capability, functionality and aspiration to play a vital role in Oklahoma’s efforts to develop and implement the infrastructure for HIE. 2.3 State Medicaid HIT Plan Development This section will describe how the SMHP will be planned, designed, developed and implemented, including how it will be implemented in accordance with the Medicaid Information Technology Architecture (MITA) principles as described in the Medicaid Information Technology Framework 2.0. In 2009, Oklahoma completed a MITA SS-A and Technical Assessment and developed the MITA Transition Plan and Roadmap for moving the MMIS forward to its envisioned To Be state. This Roadmap was submitted to CMS with the IAPD requesting funding for a RFP that will result in a competitive procurement of SoonerCare Operations and MMIS maintenance responsibilities during the new contract period. This work will be leveraged and integrated into the statewide HIT landscape to promote statewide cost-effective and efficient use of HIT, where feasible. OHCA will identify the interdependencies within the current Oklahoma HIT projects, as well as new ones that develop during strategic and operational planning of the OKHIE. The same iterative MITA planning process will be used, beginning with an environmental scan to assess the As Is readiness of SoonerCare providers and identify gaps. OHCA will also use the environmental scan to identify other collaborative efforts and initiatives in which providers are involved in to enable the planning process to identify economies and efficiencies that may be achieved through shared State IT assets. During the planning phase, OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. The work groups then reviewed each business process that has been and will continue to be implemented to develop a concept of operations for the SoonerCare EHR Incentive Program. Where feasible the approach adopted was to integrate the SoonerCare EHR Incentive Program business process into OHCA’s corresponding standard MITA business process. Throughout this SMHP document, OHCA has placed a reference to the applicable standard MITA business process within the discussion of the SoonerCare EHR Incentive Program business process. This ensures reviewers of the SMHP can quickly ascertain how new business processes will be implemented in accordance with the MITA principles as described in MITA Framework 2.0. A description of OHCA work groups and collaborative efforts are provided in Section 4.1 through 4.1.9 below. OHCA has also collaborated and will continue to coordinate with the interim State HIT Coordinator, SHIECAP, HIIAB, the Broadband Grant Awardee, the Beacon Community Grant Awardee, and the OFMQHIT on this important national health care initiative. OHCA has recently opened a dialog with these entities to identify projects of interest to the multiple stakeholders. When identified through collaboration, OHCA prioritized the projects taking into consideration State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 27 the MITA Roadmap already developed for MMIS Re-procurement and integrated projects as appropriate into the MITA/HIT Roadmap five-year timeline as shown in Section 5.1. 2/25/2010 © 2010 Cognosante PRIVATE AND CONFIDENTIAL MITA SS-A Elements Facilitating Inputs SMHP Requirements MITA State Self-Assessment: As Is and To Be MITA State Self-Assessment: Gap Analysis MITA State Self-Assessment: Executive Visioning MITA Roadmap and Transition Plan MITA Technical Assessment Activities Current Landscape Assessment and To Be Environment Current Landscape Assessment and To Be Environment Specific Steps Necessary to Implement the EHR Program HIT Roadmap and Incremental Approach to Implementation Current Environment, To Be Environment, and HIT Roadmap Develop MITA Technical Assessment Develop MITA Roadmap & Transition Plan Current MITA SS-A Capability Levels based on MITA 2.01 Framework Review information and conduct interviews Figure 13 MITA SS-A to SMHP Alignment The 2009 MITA Technical Assessment will be reviewed following the identification of the Business and Technology gaps and functionality needs to fill the gaps. The Technology Assessment will be updated as necessary and SoonerCare EHR Incentive Program projects integrated into the HIT Roadmap. Figure 14 identifies key MITA Framework components that will be assessed as OHCA continues into the implementation phase. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 28 MITA Framework Components © 2010 Cognosante PRIVATE AND CONFIDENTIAL Figure 14 MITA Framework Components 2.4 HIT Landscape Assessment This section will contain an overview of the how the HIT Survey will be conducted; who will participate; when the assessment will occur; and the methodology for analyzing data received on the environmental scans. The OHCA has conducted As Is HIT Landscape Assessments for professionals, hospitals, FQHCs/RHCs, and I/T/U. Results were shared with OKHIE, OFMQHIT, the OHA, the OFMQ, OSF, and Oklahoma State University Center for Rural Health (OSUCRH). OKHIE is currently conducting an environmental scan for networks and these results will be shared with OHCA when available. The methodology, survey questions, participants, timeline, and results are available in Section 2.5 below. 2.4.1 Existing HIT and Data Resources This section will provide an inventory of the existing Medicaid resources devoted to HIT and describe how the state will leverage these resources in the most efficient and economical way to assist in implementation and operation of Provider Incentive Program and EHR health information exchange. Resources to be leveraged include: MMIS and/or DSS/DW capabilities or functionalities to participate in health care data exchanges today.; Public Health Systems; DHS Eligibility System; Data availability and usability; Others?; A description of current interoperability status of the State Immunization Registry and Public Health Surveillance reporting databases There are a number of systems that support Oklahoma’s SoonerCare and related public health functions. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 29 Electronic Provider Enrollment (EPE). OHCA will leverage EPE for EP and EH enrollment and eligibility in Oklahoma’s SoonerCare EHR Incentive Program. The financial expenditure functionality will be used to appropriately track automated payment of incentives to EPs and EHs. Current MMIS financial and management processes will be leveraged to ensure applicable federal, state, and local operations and reporting requirements are met. Electronic Eligibility and Claims Transactions. The OHCA is the State’s Medicaid agency and the largest payer in the State. OHCA processes a monthly average of 3.1 million claims, of which 96 percent are submitted as electronic transactions or entered directly via the Internet. Claims are processed in real time and are paid weekly. Oklahoma State Immunization Information System (OSIIS). OSIIS is a statewide immunization registry that Oklahoma began using in 1995. It is designed to collect and maintain accurate, complete, and current immunization records for the entire population of Oklahoma, but the main emphasis has been children’s records. Any physician or clinic that provides immunization through the Vaccines for Children (VFC) program may access OSIIS to determine what vaccines are needed and record any vaccines given. Because not all providers participate on OSIIS, immunization records are not always complete. Participating providers have free local or long distance access to OSIIS 7 days a week. OSIIS currently receives data from providers in HL7 2.3.1 standard format. The Oklahoma OSDH is applying for a grant through the CDC to increase the systems interoperability functionality (Funding Opportunity Number CDC-RFA-IP10-1002ARRA10). There is no electronic exchange between OSIIS and any of OHCA’s systems at this time. OSIIS is an antique system and not capable of data exchange with IHS and Tribal systems at this time. OSIIS is maintained by Oklahoma State Department of Health (OSDH). OSDH has applied for a CDC grant and depending on funding, OSIIS capabilities will be updated or the system replaced to allow interoperability with I/T/U systems. The HIIAB has established a task force to review exchange of immunization data statewide and investigate shared services approach. The objective will be to share a single connection to the statewide HIE for each of these services. Through this connection, the OSDH will be able to communicate lab and immunization information with providers, including I/T/U systems, via their EHR systems and the HIE. OHCA is currently investigating the feasibility of a variety of data transfer mechanisms for use with I/T/U systems, including automated basic File Transfer Protocol (FTP) and HTTP. Public Health Investigation and Disease Detection of Oklahoma (PHIDDO): The preferred method of reporting diseases or conditions to the OSDH is through the PHIDDO system. PHIDDO receives automated files from two laboratories: LabCorp and Diagnostic Labs of Oklahoma in HL7 format. PHIDDO is a real-time, secure, internet-based application that provides a centralized place for reporting diseases and conditions in Oklahoma. All data is secure and accessible only to registered users. The benefits of PHIDDO include secure disease reporting, accurate report submission, decreasing the time of report, decrease in the time to begin and complete investigations and control efforts, and elimination of paperwork, faxing and mailing of reports to OSDH. PHIDDO users include physicians, physician assistants, nurse practitioners, infection control practitioners, laboratorians, and other personnel in a clinic or health care setting who submit cases of reportable diseases and conditions. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 30 The HIIAB is tasked with determining how these assets can be shared. The HIIAB meets monthly and has established work groups to begin working together on the following initiatives: Expose SoonerCare eligibility as a service to HIE Share and expose Immunization Registry data as a service to HIE Expose and share state-administered lab tests to HIE 2.4.2 MITA State Self-Assessment (SS-A) This section will include a summary of the State of Oklahoma Medicaid Information Technology Architecture (MITA) State Self- Assessment (SS-A) vision, goals, 5 and 10 year MITA roadmap. In 2009, a visioning session was held with executive leadership of the Oklahoma SoonerCare program. The thoughts and ideas expressed within that meeting, as well as the Oklahoma 5- to 10-year Strategic Plan, were captured as Guiding Principles to track through the MITA SS-A process. The Guiding Principles were matched to the MITA goals and are demonstrated by objectives and actions to clarify the intent. As with the MITA SS-A process, goals and objectives are dynamic and must respond to the ever-changing healthcare environment and legislative requirements. The OHCA Guiding Principles are provided in Table 2 below. Table 2 Executive Guiding Principles and Objectives MITA Goal OHCA Guiding Principle Objective/Actions Integration and Interoperability Promote efficient and effective data sharing to meet stakeholder needs. Integrated Call Center – This will provide enhanced call routing capabilities and the integration and availability of call center data to provide operational efficiency and flexibility across all OHCA call centers. Document Management – Integration of the COLD imaging system with the MMIS for improved access to information and operational efficiency. Enhance and introduce up-to-date management information and communication systems through the MMIS Re-procurement project. Letter Generation – Implement a flexible and configurable system component to improve operational efficiency and enhance member and provider communication. Medical Care Management (Atlantes) – Enhancement of the Atlantes Case Management system and further integration with the MMIS will allow a broader spectrum of OHCA staff to utilize the system more effectively. Promote reusable components and modularity. Claims Processing – Implementation and integration of the existing Business Rules Engine into the MMIS for enhanced claims processing. Promote efficient and effective data sharing to meet stakeholder needs. Secure Provider Portal – This enhancement will allow providers real-time online access to view and change their account information, saving OHCA significant staff time in data entry and phone inquiries. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 31 MITA Goal OHCA Guiding Principle Objective/Actions General System Functionality – Enhancement of Data Warehouse capabilities (Data Cubes) for analyzing and reporting of data. It will also include the creation of Dashboards for management decision-making and access to data by the public. Integration and Interoperability Promote efficient and effective data sharing to meet stakeholder needs. Drug Rebate – Automate the process and provide online access for invoices and payments to suppliers. Drug Utilization Review – Reference data file enhancement. Asset Verification – Electronic data exchange with financial institutions for asset verification of Dual Eligibles. Provide a beneficiary-centric focus. No Wrong Door (NWD) – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide enhanced accessibility and eligibility and benefit determination for members. Flexibility to respond rapidly to change Identify, qualify, and manage a cost-effective, efficient, and flexible SoonerCare program. Oklahoma Health Information Organization – Through participation in this statewide initiative, the OHCA commits to promote a comprehensive approach to accelerating the exchange of health information by involving providers and consumers, establishing State agency trust, developing sustainable funding sources, providing capable business services and operations, developing technical capabilities and consulting with State officials. No Wrong Door (NWD) – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide flexibility in response to SoonerCare program and policy changes. Adopt data and industry standards. HIPAA 5010 and International Classification of Diseases (ICD)-10 – The system enhancements to comply with these federally mandated data formats will be included in the MMIS Re-procurement project. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 32 MITA Goal OHCA Guiding Principle Objective/Actions Support integration of clinical and administrative data. Medical Artificial Intelligence (MEDai) Health Management – The integration of MEDai with the SoonerCare Secure Site will allow providers access to information about the illness burden of the SoonerCare members they treat. This information is critical to providers at the point of care to improve health outcomes for SoonerCare members. Promote secure data exchange. Health Information Exchange (HIE) – Implementation of the initial infrastructure to provide the capability to exchange health information between State entities and the public. Flexibility to respond rapidly to change Promote secure data exchange. Secure Member Portal – Implement a portal to provide members the ability to view and manage their information and eventually the capability for Personal Health Records. Electronic Provider Referral – Online access to information for providers to refer members to a specialist. Enterprise view to align technology and business needs Sustain and maximize available funds. Program Integrity (PI) – The PI system will integrate new technologies with fraud detection and case tracking systems to improve the effectiveness and efficiency of fraud and abuse investigations. Ongoing review of reimbursement rates and methodologies to ensure that provider payments are consistent with efficiency, economy, and quality of care. Simplify the claim process, through collaboration with providers. Claims Resolution – Implementation of automated workflow for MMIS claims resolution. Claims Processing – Implementation and integration of the Business Rules Engine into the MMIS to provide efficiency and flexibility in the processing of claims. Break down artificial boundaries between systems, geography, and funding. Insure OK and Insure Tulsa – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured. Data that supports analysis and decision-making Seek to greatly improve the status of health care across the State Insure Oklahoma (IO) – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured. SoonerCare – Expansion of the SoonerCare program for 19 and 20 year olds. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 33 MITA Goal OHCA Guiding Principle Objective/Actions Ensure accuracy and correctness of payments Program Integrity (PI) – Implement a comprehensive PI system consisting of a Fraud and Abuse Component, a Medical Surveillance Utilization Review System (SURS) Component, a Case Tracking System, and Data Management for the OHCA Program Integrity and Accountability Unit. Data that supports analysis and decision-making Ensure accuracy and correctness of payments The Insure Oklahoma premium assistance system enhancement will include an electronic management system for financial transactions to and from multiple sources, such as premium receipts, invoices, accounts receivable, accounts payable, State and Federal, donations, and commissions. Claim Check – Enhancement of the edit and audit functions for MMIS claims processing. Finance – Enhancements to the Financial system for management of payments and adjustments and reporting. Performance measurement for accountability and planning Improve the effectiveness and efficiency of the delivery of medical services. The Emergency Room (ER) Diversion Grant will help OHCA develop a program to access a full array of primary and preventative health care for Oklahoma County SoonerCare members. Specifically, this project addresses the overuse of hospital ER use. Maximize revenue by containing costs, eliminating duplication, and using all sources of funds. The OHCA plans to explore the opportunities that exist to better serve Oklahoma’s Dual Eligible population and to capitalize on the expertise of other States, as well as utilize other resources, such as the Center for Health Care Strategies that may assist the OHCA to develop a care coordination plan for Oklahoma’s Dual Eligibles. Provide continuous improvement/utilization review by evaluating service outcomes, program costs, and provider participation to maximize and effectively manage resources. Plans to review and make recommendations and/or implement changes in payment methodologies and reimbursements in order to ensure fair compensation to providers. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 34 MITA Goal OHCA Guiding Principle Objective/Actions Coordinate with Public Health and other partners to improve overall health Attract and maintain a strong network of service providers by continuously evaluating and implementing programs that strengthen the reimbursement process. Self-Directed Services – The Opportunities for Living Life (OLL) action plans continue to describe the OHCA’s many partnerships with other agencies, providers, and advocates to develop collaborates to improve access to long-term support services, and provide for better choice and control for the OHCA’s aging population. Coordinate with Public Health and other partners to improve overall health OHCA is committed to developing a health care partnership with policy makers, beneficiaries, providers, and stakeholders from the community to provide maximum health care benefits to qualified individuals through innovative and cost effective programs. Research in the Health Care Infrastructure in local communities within the State of Oklahoma is intended to allow various stakeholders including, but not limited to: local community leaders, etc., to see both the small- and large-scale pictures of the existing health care infrastructure within their communities. It is hoped that this research may help community leaders make informed decisions about future planning. It is expected that at the conclusion of the research a final report will be prepared and distributed to stakeholders across the State. The OHCA has implemented a system called the Health Management Program (HMP) that targets members with chronic conditions who have been identified by predictive modeling to have a high risk of incurring significant medical cost. The HMP provides patient education and care management services to participants. The HMP also develops provider collaboration focused on holistic health management and evidence-based guidelines, and one-on-one practice facilitation for some primary care providers (PCP) provided by the OHCA’s contractor, the Iowa Foundation for Medical Care. The MITA SS-A conducted in the summer of 2009 specifically anticipated healthcare-related change arising from the impact of healthcare reform. As healthcare reform passed only recently (May 23, 2010), OHCA has not yet analyzed the full impacts of the new law on Medicaid programs, but potential program changes could include any or all of the following: Possible expansions in Medicaid and/or SCHIP eligibility levels and benefits Creation of an insurance gateway or exchange through which Medicaid and/or SCHIP enrollees may seek insurance Changes in program funding with 100 percent federal financing for expansion populations for some time period Increased use of employer-sponsored insurance Changes to Medicaid long-term care programs OHCA will review and analyze the impacts of this new legislation and stands ready to accommodate all new requirements. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 35 The updated MITA SS-A HIT Roadmap is included in Section 5.1. The Roadmap has been updated to add the HIT projects arising from the SMHP planning activities. Since the OKHIE Strategic and Operational Plans are not complete, it is anticipated that HIE/HIT projects will be added to ensure SoonerCare IT assets are leveraged and integrated into the overall statewide HIE efforts. 2.4.3 MMIS HIT/HIE Environment This section will include a description of the role of the MMIS in OHCA’s current HIT/HIE environment. Oklahoma’s MMIS is a highly scalable system with much excess processing capacity. During peak processing times, it operates at less than 15 percent of the system’s available central processing unit (CPU) capacity. The Oklahoma MMIS system provides sub-second response time for real-time transactions, including eligibility queries and point of service claims adjudication transactions. The system’s Sun Unix operating system allows OHCA to add a new CPU or expand the data storage matrix array easily, with users on the system, as needed. For real-time eligibility inquiries and claims submissions, the system currently communicates with VANs. EMRs/ EHRs attached to a VAN have the ability to check SoonerCare eligibility from our MMIS system. Currently it takes about a week to configure, test, and move a new VAN into production. Sharing these services to the OKHIE for a wider audience would be a similar process. Real-time claims adjudication capability exists for point of service pharmacy claims and for our online direct data entry provider users. If needed, these processes could be leveraged for real-time adjudication of non-pharmacy claims. Network traffic studies are conducted twice a year and as needed. When the connection to OKHIE is planned and implemented, internet bandwidth and network traffic will be evaluated and monitored, and appropriate adjustments made as needed. The Oklahoma MMIS system is in preparation to connect to an HIE when it becomes available. In the future, OHCA is planning to incorporate an EHR to enhance and/or streamline many functions currently performed for SoonerCare members including care management and prior authorizations. OHCA will share services in a standard agreed upon format when the data is used to promote care coordination for SoonerCare members and/or transmitted to achieve EP or EH Meaningful Use requirements. Maintenance of the Health Insurance Portability and Accountability Act (HIPAA) and the ARRA security standards for receipt and transmission of the health information is a priority for OHCA, OKHIE, and stakeholders participating in the statewide HIE. 2.5 Environmental As Is Scan Discuss the State’s plan for conducting the required environmental scan to determine the “As Is” state of adoption of certified EHR technology by Medicaid eligible providers in Oklahoma. The overview will include the environmental scan process, identify any associations or organizations that participated and/or assisted OHCA; dates environmental scan distributed; percentage response; any follow up contact attempts, etc. The OHCA conducted an environmental scan of the SoonerCare provider population to gather information to describe the current state of HIT adoption and use of EHRs in provider offices and hospitals across the State. Two types of scans were originally developed to communicate with specific provider groups: one for health professionals (individual and group practitioners) and one for hospitals. Refer to Appendix B for scan questions. During the process of developing the scans, it became apparent that collecting similar information from the FQHCs and RHCs State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 36 would provide a better understanding of the environment. It was determined that the survey developed for EPs would serve this purpose. To ensure Oklahoma’s large Native American population was also represented, the EPs and EH scans were administered to the IHS and tribal health care providers. Existing State health information networks, including integrated delivery networks (IDN) or integrated delivery systems (IDS), were also targeted for environmental scan. Although OKHIE and OHCA planned to conduct a joint environmental scan of the State networks that would provide input for both SHIECAP’s Strategic Plan and OHCA’s SMHP, the timelines for the two efforts diverged and responsibility for the network scan was transferred to OKHIE. Approximately 10 entities were considered to qualify under a broad umbrella definition of HIE networks. Scans were initially developed by members of the Planning, Development and Implementation work group (PDI – See Section 4.1.2 for description), and then reviewed and revised internally by the oversight work group. The EH and Network scans were also reviewed by external parties. The scans were all provided in various formats as described in the following sections. EPs were notified of the preliminary scan via the OHCA public SoonerCare EHR Incentive Program web site, fax, and/or email blasts, and through a global banner on the SoonerCare claims billing site. An introductory letter and a fact sheet (shown in Appendix C), were developed to inform providers of this opportunity. The initial EP scan was also available on the OHCA public web site for providers that may not have been targeted. The EP follow-up assessment was also offered as a phone interview and the EH scan was sent by email with a link to the survey. The OHA assisted OHCA by notifying hospitals of this opportunity and encouraging their participation in the SoonerCare EHR Incentive Program to adopt or upgrade their systems to certified EHR technology. All hospitals were informed of the importance of the environmental As Is scan and their participation requested. OHCA also participated in several state conferences in the early months of 2010 (OSMA EMR Conference, Rural Health Association, 8th Annual Rural Hospital Conference) and used those opportunities to present the SoonerCare EHR Incentive Program, notify participants about the scan, and request participation. All information obtained from the scans will be shared with the OKHIE to ensure all statewide stakeholders are working from the same knowledge base. OFMQHIT, the State’s regional extension center entity, will be notified of the respondents indicating they would like assistance with selecting and/or using certified EHR technology. 2.5.1 Professional Providers (individual and group providers) Scan This group was targeted first with a short seven-question preliminary scan designed to collect baseline information, determine which providers had previously implemented any components of an electronic EHR system, estimate potential eligibility based upon provider type and patient volume, and gauge EP interest in participation in the SoonerCare EHR Incentive Program. Those providers who indicated they had any EHR capabilities were called and given a more detailed (10-question) follow-up scan to document the systems and capabilities currently in place. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 37 The health professional scans were initially administered online using Survey Monkey and provided on paper by mail to ensure that rural providers who do not all have Internet access were contacted and given the opportunity to participate in the survey process. Due to the short timeframe and minimal response, OHCA also began to call health professionals and offer them the opportunity to take the scan by phone, as well as online or on paper upon request. Provider responses were accepted in all three formats, with paper and phone responses entered into the online survey tool and accumulated into the scan data. A notification about the scan effort including the location of the online survey was mailed to potentially EPs, along with a paper copy of the scan. Additional reminders were sent via email and fax, which included notification that providers would also be able to participate in the scan by phone. Phone calls were made to all providers whose initial U.S. mail notification was returned. All EP follow-up scans were administered by telephone. The timeline for the professional providers is shown in Table 3. Table 3 Professional Provider Scan Timeline Date Activity April 1, 2010 Notification and preliminary scan sent via US mail April 5, 2010 Preliminary scan posted on the public web site April 15, 2010 Begin offering preliminary scan by telephone April 26, 2010 Begin calls to providers whose initial US mail notification letter was returned May 13, 2010 Follow-up scan phone calls begin May 28, 2010 Close Scan 2.5.2 Hospital Scan The hospitals were targeted with a single 15-question scan to collect baseline information and document the EHR systems and capabilities currently in place. Each hospital was contacted via email to obtain the appropriate person to whom the technical scan should be sent. Through SurveyGizmo, the contact was then sent a link to an online survey. The link was not made publicly available. SurveyGizmo also sent automatic reminders to non-responders via email at regular intervals. Contact was made to the OHA to coordinate and collaborate on efforts with hopes that 50percent participation in the scan could be achieved from hospitals statewide. The timeline for the hospital scan is shown in Table 4. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 38 Table 4 Hospital Scan Timeline Date Activity April 19, 2010 OHA contacted for assistance April 27, 2010 Notification sent via email. May 5, 2010 Scan available to hospitals May 7, 2010 Begin emails to hospitals that have not responded May 21, 2010 Close Scan 2.5.3 Federally Qualified Health Clinics (FQHCs)/Rural Health Clinics (RHCs) Scan The OPCA assisted OHCA in identifying the State’s FQHCs and RHCs and obtaining contact information for potentially eligible FQHCs/ RHCs. They completed the same 10-question EP scan to collect baseline information and document the EHR systems and capabilities currently in place. The scan was provided online using SurveyMonkey. The timeline for the FQHCs/RHCs Scan is shown below in Table 5. Table 5 FQHCs/RHCs Scan Timeline Date Activity May 5, 2010 OHCA begins administering preliminary scan by telephone May 28, 2010 Close Scan 2.5.4 Indian Health Service (IHS)/Tribal facilities/Urban Indian Clinic Providers Early on OHCA explored with I/T/U partners whether their providers would be eligible for participation in the federal Provider Incentive Program. Once it was clear that they could, the OHCA Indian Health Unit targeted these providers with the 10-question EP follow-up scan. IHS and tribal hospitals were provided the EH scan. The Indian Health Unit worked directly with the OHCA planning and development committees to ensure consultation and inclusion of Indian Health Service, Tribal facilities and Urban Indian Clinics in Oklahoma. The efforts included giving a presentation to Oklahoma City Area Inter- Tribal Health Board, providing a written summary of the SoonerCare EHR Incentive Program and contacting each contracted Indian health facility by telephone or email, including Tribal facilities, Urban Indian facilities, Indian Health Service facilities, and the Oklahoma City Area Indian Health Service Administrative Office. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 39 Each contracted site was personally contacted by one of the staff of OHCA Indian Health Unit to educate, get input, and obtain lists of their potentially eligible providers and later to survey the provider about their practice and their use of electronic health records. OHCA Indian Health Unit worked with I/T/U facilities one-on-one to inform them of the initiative and how it might impact them. I/T/U staff was given the opportunity to ask questions, identify contacts within their tribe and arrange follow-up meetings or conference calls, etc., with OHCA if they had additional questions. 2.5.5 Selection of Environmental Scan Participants This section will describe how the environmental scan population was selected and demographics about the selected providers (statewide, eligible providers, hospitals, HIE networks) and provider specialties, etc. OHCA elected to scan all currently contracted SoonerCare providers that were of the type considered eligible for the SoonerCare EHR Incentive Program under the proposed rule: Physician, Pediatrician, Nurse Practitioner, Certified Nurse Midwife, and Dentist, and all EHs in the State. OHCA identified 6,199 individual and group providers and 130 hospitals, (which included six IHS hospital facilities). Ninety-three FQHCs/RHCs were also identified. As Oklahoma is largely a rural state, extra efforts were made to ensure that scans reached and were responded to by small and rural providers. Focus of the scans remained on in-state providers. Oklahoma has the second largest Native American population in the US. OHCA therefore made special efforts to confirm that I/T/U providers were eligible to participate. The Indian Health Unit at OHCA worked closely with the Native American medical community to administer the scans and ensure their input into the program. OHCA targeted 677 IHS health professionals for the scan. Both the EP and EH scans were utilized for these providers. 2.5.6 Environmental Scan Questions This section will include a description of process used to develop and vet the environmental scan and provide readers with a copy of environmental scan tools used. The OHCA developed three tools for use in gathering responses to questions on the current As Is environment and use of EHR technology in Oklahoma. Types of scans and their objectives include: 1. Eligible Professional (EP) Preliminary Environmental scan – Obtain a landscape of potential SoonerCare EHR Incentive Program eligibility and extent of EHR/EMR adoption. 2. Eligible Professional (EP) Follow-up Assessment – Identify the specific EHR/EMR functionalities in place for those providers who indicated they had an EHR/EMR in the preliminary scan. 3. Eligible Hospital (EH) Environmental scan – Obtain a landscape of potential SoonerCare EHR Incentive Program eligibility, extent of EHR/EMR adoption, and the specific EHR/EMR capabilities in place. The initial drafts of the provider and hospital scans were developed by reviewing existing HIE and EHR scans from other sources through Internet research. Preference was given to State HIE and SoonerCare EHR Incentive Program scans specifically developed for both Medicare and Medicaid programs; but since few of these were available at the time, other state scans and State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 40 some surveys from associations were also evaluated. Relevant questions were pulled from a number of these surveys into a single rough draft for review by OHCA to identify the questions most useful for assessing the As Is state of EHR adoption by Oklahoma SoonerCare providers. A shorter list of questions was then reviewed and revised by several OHCA EHR work groups and further refined into the three individual scans eventually used. All scan results were provided to OHA, OFMQ, OSF, and OSUCRH. The preliminary professional scan was developed first; then the follow-up professional scan, and finally the hospital scan. IHS providers were targeted using the appropriate EP or EH scan. The FQHCs/RHCs were targeted using the longer EP follow-up scan. Each survey includes questions that cover potential eligibility (provider type, patient volume); whether the respondent currently has any EHR/EMR components in place (and if so, vendors used, functions available); meaningful use capabilities currently in place; any current connections to an exchange network; and interest in program participation. The hospital scan was developed in collaboration with several external groups including OHA, OFMQHIT, OSF, and OSUCRH. By doing so, all collaborators sought to develop a single, comprehensive survey that obtained the information needed by a variety of stakeholders and with as little disruption as possible to the hospitals. The initial draft network scan was developed in a similar fashion but then underwent review by OKHIE work groups to further develop the scan for SHIECAP purposes. The intent is to administer the scan in face-to-face interviews with network representatives to provide an opportunity to discuss and clarify questions and responses as part of the interview process. To eliminate duplicate efforts it was decided that OHCA would utilize the results from the SHIECAP Network HIT Scan in assessing current As Is state of networks for placement in the SMHP. As of the first draft of the SMHP, network survey results are not yet available. OHCA set up an informational web site for providers titled SoonerCare EHR Program at www.okhca.org/EHR-incentive that describes the SoonerCare EHR Incentive Program and provides responses to frequently asked questions. The preliminary EP survey was accessible from this site. The questions developed and loaded into the SurveyMonkey tool for the HIT environmental scans are provided in Appendix B of this document. 2.5.7 Environmental Scan Analysis This section will examine methodology used for environmental scan analysis and contain environmental scan results .Include: survey Analysis and examination of survey results to assess current rates of EHR adoption in Oklahoma for Medicaid and non- Medicaid providers; Pros and Cons of capabilities and functionalities currently in place in Oklahoma, and Identified Interoperability Opportunities and Barriers. OHCA’s environmental scans collected primary source data directly from providers and were administered in April/May 2010. The scans were conducted with current contracted SoonerCare providers only; non-SoonerCare providers will be scanned as part of the State’s HIE effort. OHCA does not currently provide or have statewide use of EHRs. IHS facilities were included in the scan; it is assumed that IHS facilities have access to the EHR capabilities in the RPMS, the federal system that supports IHS health functions. The State Veterans Affairs (VA) facilities were not included in the scan, but it is presumed that these facilities are supported by the Veterans Health Information Systems and Technology Architecture (VistA), an enterprise-wide information system built around an EHR and used nationwide in the VA medical system. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 41 Each scan includes questions that cover potential eligibility (provider type, patient volume); whether the respondent currently has any EHR/EMR components in place (and if so, vendors used, functions available); meaningful use capabilities currently in place; any current connections to an exchange network; and interest in program participation. The data collected provides some information on vendors and products utilized but a limited amount of information on capabilities for each. Scan data was collected and consolidated into an Excel format and was analyzed via Excel and Access. Responses to the follow-up surveys for EPs, IHS, and FQHCs/RHCS to date have been much lower than expected; OHCA will keep these surveys open and continue to collect data but these statistics are not included in the SMHP at this time. Survey Oklahoma’s SoonerCare providers are in various stages of automation, with larger, more urban organizations generally more automated than smaller, rural practices. Mid-sized organizations, such as FQHCs/RHCs and provider groups are in various stages of using, adopti
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Title | Oklahoma SMHP FINAL-07-26-10 |
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Full text | STATE OF OKLAHOMA OKLAHOMA HEALTH CARE AUTHORITY STATE MEDICAID HIT PLAN (SMHP) VERSION 1.0 July 26, 2010 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page i Prepared by OHCA with assistance from: 6263 North Scottsdale Road, Suite 200 Scottsdale, AZ 85250 (480) 423-8184 www.foxsys.com State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page ii TABLE OF CONTENTS 1 EXECUTIVE OVERVIEW...................................................................................................1 1.1 Background .....................................................................................................................2 1.1.1 Current HIT Landscape in Oklahoma............................................................................3 1.1.2 Vision of HIT Future....................................................................................................11 1.1.3 Provider Incentive Program Implementation ...............................................................12 1.1.4 MITA HIT Roadmap....................................................................................................14 1.1.5 Recommendations......................................................................................................17 2 CURRENT HIT LANDSCAPE ASSESSMENT – THE “AS IS” ENVIRONMENT.............18 2.1 Current HIT Activities and Impact on SoonerCare Members..........................................18 2.2 Current HIT Activities and Impact on SoonerCare EHR Incentive Program ...................21 2.2.1 Broadband Internet Access in Oklahoma....................................................................22 2.2.2 Beacon Community Grant ..........................................................................................23 2.2.3 Oklahoma Health Information Exchange (OKIE).........................................................24 2.2.4 Federally Qualified Health Clinics and Rural Health Clinics ........................................24 2.2.5 Oklahoma Exchange Networks...................................................................................24 2.2.6 Recommendations......................................................................................................25 2.3 State Medicaid HIT Plan Development ..........................................................................26 2.4 HIT Landscape Assessment..........................................................................................28 2.4.1 Existing HIT and Data Resources...............................................................................28 2.4.2 MITA State Self-Assessment (SS-A) ..........................................................................30 2.4.3 MMIS HIT/HIE Environment........................................................................................35 2.5 Environmental As Is Scan..............................................................................................35 2.5.1 Professional Providers (individual and group providers) Scan ....................................36 2.5.2 Hospital Scan .............................................................................................................37 2.5.3 Federally Qualified Health Clinics (FQHCs)/Rural Health Clinics (RHCs) Scan ..........38 2.5.4 Indian Health Service (IHS)/Tribal facilities/Urban Indian Clinic Providers ..................38 2.5.5 Selection of Environmental Scan Participants.............................................................39 2.5.6 Environmental Scan Questions...................................................................................39 2.5.7 Environmental Scan Analysis .....................................................................................40 2.5.8 Key EHR Characteristics ............................................................................................43 3 THE VISION OF HIT FUTURE – “TO BE” ENVIRONMENT............................................45 3.1 Participating Entities......................................................................................................45 3.2 Vision for HIT Environment............................................................................................46 4 SPECIFIC ACTIONS NECESSARY TO IMPLEMENT THE SOONERCARE EHR INCENTIVE PROGRAM ..................................................................................................52 4.1 Program Organization ...................................................................................................52 4.1.1 HIT Oversight Work Group .........................................................................................53 4.1.2 Planning Development and Implementation (PDI) Work Group ..................................54 4.1.3 Clinical Work Group and Statewide Meaningful Use Task Force ................................56 4.1.4 Finance Work Group ..................................................................................................58 4.1.5 Provider and Business Operations Work Group..........................................................60 4.1.6 Legal-Policy Work Group............................................................................................61 4.1.7 Technical – Information Systems Work Group............................................................62 4.1.8 Outreach, Education, and Information Work Group ....................................................64 4.1.9 Consumer Work Group...............................................................................................66 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page iii 4.1.10 Concept of Operations................................................................................................68 4.2 Communication Plan .....................................................................................................69 4.3 Policy and Regulatory Changes.....................................................................................70 4.3.1 Policy Changes...........................................................................................................70 4.3.2 Privacy Regulatory Changes ......................................................................................72 4.3.3 Other Regulatory Changes .........................................................................................72 4.4 OHCA Contract Changes ..............................................................................................72 4.5 Provider Eligibility for Incentive Payments .....................................................................73 4.5.1 Provider Eligibility Determination ................................................................................74 4.5.2 Eligible Providers........................................................................................................79 4.5.3 Provider Registration Process ....................................................................................79 4.6 Processing Payments to Providers ................................................................................80 4.6.1 Provider Registration and Payment Request ..............................................................81 4.6.2 Provider Payment Calculations...................................................................................85 4.6.3 Provider Payment Monitoring......................................................................................86 4.6.4 Provider National Provider Identifier (NPI) ..................................................................88 4.6.5 Role of Contractors in the SoonerCare EHR Incentive Program Implementation........88 4.7 Reporting Requirements................................................................................................88 4.8 Coordination with Medicare to Prevent Duplicate Payments..........................................89 4.9 Program Integrity (PI) Monitoring...................................................................................89 4.9.1 Incentive Payment Recoupment .................................................................................90 4.9.2 Fraud and Abuse Prevention ......................................................................................90 4.9.3 Provider Appeals ........................................................................................................91 4.10 Coordination with OFMQHIT .........................................................................................92 4.11 OHCA SoonerCare EHR Incentive Program Administration ..........................................93 4.11.1 Federal Financial Participation (FFP)..........................................................................93 4.12 Clinical Quality Data ......................................................................................................94 4.13 OHCA EHR Outcome Evaluation...................................................................................95 4.13.1 EHR Quality Assurance/Quality Improvement Outcome .............................................95 4.13.2 EHR Child Health Outcome Evaluation.......................................................................96 4.13.3 EHR Performance and Reporting Outcome Evaluation .................................................96 4.13.4 EHR Health Management Program (HMP) (Chronic Disease) Outcome Evaluation ...97 4.13.5 EHR Pharmacy Outcome Evaluation.............................................................................97 4.13.6 EHR Use – Care Management Outcome Evaluation .....................................................98 4.14 State Alternative Methods..............................................................................................98 4.14.1 Meaningful Use Criteria ..............................................................................................99 4.15 Dependence upon Federal Initiatives ..........................................................................100 5 HIT ROADMAP..............................................................................................................101 5.1 Oklahoma Vision for Moving from “As Is” to “To Be” HIT Landscape ...........................101 5.1.1 OHCA Programs “To Be” Vision ...............................................................................102 5.1.2 OHCA Role in the SoonerCare EHR Incentive Program...........................................104 5.2 OHCA Participation in Health Information Exchange (HIE) ..........................................113 5.2.1 Participation in Federal National Health Information Network (NHIN) .......................113 5.2.2 Participation in Statewide, Regional, and/or Local HIE Initiatives..............................114 APPENDIX A: COMMUNICATIONS PLAN............................................................................119 APPENDIX B: ENVIRONMENTAL SCAN QUESTIONS ........................................................124 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page iv APPENDIX C: PROGRAM INTRODUCTION .........................................................................130 APPENDIX D: OHCA ORGANIZATION STRUCTURE & DESCRIPTION..............................134 APPENDIX E: QUALIFYING PATIENT VOLUME TABLE .....................................................145 APPENDIX F: LETTERS OF SUPPORT ................................................................................146 APPENDIX G: ACRONYMS...................................................................................................149 APPENDIX H: GLOSSARY....................................................................................................152 LIST OF FIGURES AND TABLES Figure 1 MITA SS-A to SMHP Alignment ................................................................................... 5 Figure 2 Percentage of Providers Reporting EHR/EMR by Group.............................................. 7 Figure 3 Non-Hospital Responses by Provider Type.................................................................. 7 Figure 4 Indian Health Service (IHS) and Tribal Providers ......................................................... 8 Figure 5 Hospital EHR Environment........................................................................................... 8 Figure 6 Hospital Future EHR Plans .......................................................................................... 8 Figure 7 Provider Participation Selection.................................................................................... 9 Figure 8 Hospital Broadband Access ......................................................................................... 9 Figure 9 Hospital Existence of Meaningful Use Criteria.............................................................10 Figure 10 Hospital Participation in HIE......................................................................................10 Figure 11 MITA Roadmap.........................................................................................................15 Figure 12 Oklahoma Proposed Broadband Fiber Backbone .....................................................22 Figure 13 MITA SS-A to SMHP Alignment ................................................................................27 Figure 14 MITA Framework Components..................................................................................28 Figure 15 Percentage Having EHR/EMR by Group...................................................................41 Figure 16 HIT Oversight Work Group Organizational Structure.................................................52 Figure 17 Health Care Authority Board .....................................................................................68 Figure 18 MITA Roadmap.......................................................................................................102 Table 1 Existing Regional Health Information Exchange (HIE) Efforts.......................................25 Table 2 Executive Guiding Principles and Objectives................................................................30 Table 3 Professional Provider Scan Timeline............................................................................37 Table 4 Hospital Scan Timeline.................................................................................................38 Table 5 FQHCs/RHCs Scan Timeline .......................................................................................38 Table 6 Performance Measures for SoonerCare Provider HIE Participation..............................49 Table 7 Work Group Members and Positions............................................................................54 Table 8 SoonerCare Patient Volumes .......................................................................................77 Table 9 Eligible Professional Attestations..................................................................................81 Table 10 Eligible Hospitals and CAHs Attestations ...................................................................83 Table 11 Category of Services ................................................................................................104 Table 12 Average Electronic Volume for OHCA per month .....................................................108 State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 1 1 EXECUTIVE OVERVIEW The section provides a high-level executive summary for how the SoonerCare Electronic Health Record (EHR) Incentive Program will be administered by the Oklahoma Health Care Authority (OHCA), and how the OHCA programs will leverage the clinical data made available through electronic health record technology to achieve their goals and vision for improving population health outcomes and quality of care for Oklahomans. The approach taken by Oklahoma Health Care Authority (OHCA) in preparing this State Medicaid Health Information Technology (HIT) Plan (SMHP) was to begin planning early with the intent to implement the SoonerCare Electronic Health Record (EHR) Incentive Program in January 2011. This allows Oklahoma SoonerCare eligible providers the opportunity to review EHR products, find a match to meet the needs of their offices and hospital settings, and maximize payments available under the federal Provider Incentive Program. The basis for developing the SMHP was the Final Rule, published July 13, 2010, that provides incentive payments for the meaningful use of certified EHR technology. The Oklahoma Health Information Exchange (OKHIE) is moving forward to plan the statewide approach and develop their Strategic and Operational Plans simultaneously to the work taking place on the SMHP. The OHCA Chief Information Officer (CIO) co-chairs the Statewide Oversight Committee and OHCA staff participates on OKHIE domain work groups to ensure efficiency and effectiveness of planning efforts. Emphasis was placed on collaboration and coordination of activities among stakeholders. The planning efforts were developed in collaboration with OKHIE, the Health Information Infrastructure Advisory Board (HIIAB), the Oklahoma Foundation for Medical Quality Health Information Technology (OFMQHIT), and key stakeholders throughout the State of Oklahoma. Outreach to educate providers on the SoonerCare EHR Incentive Program was coordinated with professional associations and the OFMQHIT. Education materials were made available through operational provider workshops and quarterly meetings to minimize duplication of efforts. Professional associations collaborating on workshops include the Oklahoma State Medical Association (OSMA); Oklahoma Hospital Association (OHA); Oklahoma Primary Care Association (OPCA); Federally Qualified Health Centers (FQHCs); and Rural Health Clinics (RHCs). OHCA completed its Medicaid Information Technology Architecture (MITA) State Self- Assessment (SS-A) in 2009. A gap analysis of As Is MITA business processes and To Be vision were completed and a MITA Roadmap and Transition Plan developed as part of the planning activities for the Medicaid Management Information System (MMIS) Takeover and Fiscal Agent Re-procurement. HIT/HIE requirements were developed for the request for proposal (RFP) and a placeholder added to the MITA Roadmap and Transition Plan. The Statewide HIE Strategic and Operational Plans are not complete at this time. OHCA anticipates potential amendments to the RFP and identified HIT/HIE projects integrated as the statewide and SMHP planning efforts move forward. The approach taken during planning for SoonerCare EHR Incentive Program administration was to review OHCA MITA business processes, and where feasible, integrate the SoonerCare EHR Incentive Program into the standard MITA business processes and OHCA day-to-day operations. OHCA would only develop state-specific business processes where a MITA business or organizational process was not identified. Examples of these processes would include SoonerCare EHR Incentive Program eligibility, verification of SoonerCare member volume, attestation receipt and validation, and provider registration and query to the National Level Registry (NLR). State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 2 Oklahoma’s SMHP will provide readers with an understanding of activities OHCA will employ over the next five years to implement section 4201 Medicaid provision of the American Recovery and Reinvestment Act of 2009 (ARRA). Subsequent sections of the SMHP provide a detailed description of the plan to implement and administer the SoonerCare EHR Incentive Program, including OHCA’s plans to: Establish, administer, and oversee the program Obtain stakeholder input to assist with development and implementation of meaningful use definitions for the SoonerCare EHR Incentive Program Capture attestations and reporting data electronically Monitor and report clinical quality measures to the Centers for Medicare & Medicaid Services (CMS) Disburse and monitor incentive payments Update the State’s electronic systems to improve functionality and interoperability Pursue incentives to encourage adoption, implementation, or upgrade of certified EHRs and meaningful use by eligible professionals (EPs) within their practices and by eligible hospitals (EHs) throughout the state Ensure Privacy and Security of electronic Protected Health Information (ePHI) Prevent fraud and abuse The ultimate goals for the State of Oklahoma are to improve population health and quality of healthcare for Oklahomans, using clinical information obtained through adoption, implementation, or upgrade of certified EHR technology to measure the health outcomes and to reduce cost of healthcare by eliminating duplicate services. OHCA will assist with the achievement of these goals through planning and implementation of the SoonerCare EHR Incentive Program, which will exemplify the benefits of EHR adoption to all providers in Oklahoma. 1.1 Background The SMHP will focus on Medicaid’s role in the overall State strategic plan for HIE and will be reviewed by CMS and ONC to ensure a coordinated, integrated strategy for planning activities. In addition, CMS and ONC are working together internally and with CMS regional offices to ensure a consistent and coordinated strategy for overall State HIT planning activities. This section will include background on ARRA, program requirements, and goals for transformation of healthcare systems. The CMS has implemented through provisions of the ARRA that provide incentive payments to EPs, EHs, and critical access hospitals (CAHs) participating in Medicare and Medicaid programs that are meaningful users of certified EHR technology. The incentive payments are not a reimbursement, but are made to incent EPs and EHs to adopt, implement, or upgrade certified EHR technology. EPs and EHs participating in the Medicaid Provider Incentive Program may qualify in their first year of participation for an incentive payment by demonstrating any of the following: meaningful use in the first year of participation, or that they have adopted (that is, acquired and installed), implemented (that is, trained staff, deployed tools, exchanged data) or upgraded (that is, expanded functionality or interoperability) a certified EHR. Incentive State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 3 payments may also be disbursed to providers who demonstrate meaningful use for an additional five years culminating in 2021.1 The Office of the National Coordinator for Health Information Technology (ONC) has issued a closely related Final Rule that specifies the Secretary’s adoption of an initial set of standards, implementation specifications, and certification criteria for EHRs. Additionally, ONC will issue a separate notice of proposed rulemaking related to the certification of HIT. Goals for the national program include: 1) enhance care coordination and patient safety; 2) reduce paperwork and improve efficiencies; 3) facilitate electronic information sharing across providers, payers, and state lines; and 4) enable data sharing using state HIE and the National Health Information Network (NHIN). Achieving these goals will improve health outcomes, facilitate access, simplify care, and reduce costs of healthcare nationwide. OHCA will work closely with federal and state partners to ensure the SoonerCare EHR Incentive Program fits into the overall strategic plan for the OKHIE, thereby advancing national goals for HIE. 1.1.1 Current HIT Landscape in Oklahoma This section includes a high-level overview of results of HIT Landscape Assessment. Oklahoma is involved in a number of HIT activities that do and will continue to impact SoonerCare members, providers, other state agencies, and partners across the state. The OHCA plans to leverage these existing resources to extend the HIT infrastructure to SoonerCare providers who adopt, implement or upgrade to certified EHR technology and choose access through these networks as their mechanism to participate in HIE. There were a number of initiatives identified that impact SoonerCare members, including several quality improvement initiatives; use of telemedicine to improve access to care for members in rural or underserved areas; electronic eligibility and claims transactions; ePrescribe capabilities, clinical lab ordering and results delivery; and public health reporting. For example, OHCA’s Health Management Program (HMP) contains business processes that have a common purpose to identify clients with special needs, collect information, assess needs, develop treatment plans, monitor and manage the plan, and report outcomes. Utilizing a web-based clinical care management software system for tracking members’ activities meets the needs of many throughout the OHCA organization, but there is a concern that this system is not accessible by all parties responsible for overseeing the management of care (e.g., vendors), nor is it integrated with other systems. Lack of integration between the various software and applications used across the agency impedes the ability to access comprehensive care management information through a single inquiry. In addition, a non-standardized and paper-based referral process is not timely and can be prone to data entry errors. Other HIT activities identified during the As Is assessment will also have a direct impact on the SoonerCare EHR Incentive Program. Broadband penetration across Oklahoma is similar to that in all states, with greater access in more urban areas than in small and rural parts of the State. While any provider can implement an EHR system locally, the ability to participate in an 1 CMS Office of Public Affairs: 202-690-6145. CMS Proposed Requirements for the Electronic Health Records (EHR) Medicaid Incentive Payment Program. December 30, 2009. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 4 exchange network is limited or impossible if broadband access is unavailable or unreliable. Oklahoma stakeholders have applied for and received grants to improve broadband access under several funding sources as identified in Section 2.2.1 of this SMHP. A Beacon Communities grant in excess of $12 million was recently awarded to the Community Services Council of Tulsa to build a community-wide information system. The grant is to leverage broad community partnerships with hospitals, providers, payers, and government agencies to expand a community-wide care coordination and health information system, to increase appropriate referrals for cancer screenings, decrease unnecessary specialist visits, and (with telemedicine) increase access to care for patients with diabetes. The OKHIE was formed to involve public and private sector stakeholders in planning and coordinating statewide HIT activities to promote HIE following receipt of ARRA Section 3013 cooperative grant from the ONC. Additionally, there are a number of Oklahoma Exchange Networks currently operating within the State. The OHCA has an HIT/HIE relationship with other State agencies participating in the HIIAB. The advisory board was created through State legislation to develop a strategy for the adoption and use of EHRs/electronic medical records (EMRs) and health information technologies that would be consistent with emerging national standards and promote interoperability of health information systems between state agencies in Oklahoma. 1.1.1.1 Use of MITA Principles and Methodology In 2009, Oklahoma completed a MITA SS-A and Technical Assessment using MITA Framework 2.0 and developed the MITA Roadmap and Transition Plan for moving the MMIS forward to its envisioned To Be state. This work will be leveraged and integrated into the statewide HIT Landscape to promote statewide cost-effective and efficient use of HIT, where feasible. The same iterative MITA planning process was used, beginning with an environmental scan to assess the As Is readiness of SoonerCare providers and identify gaps. During the planning phase, OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. The work groups then reviewed each SMHP business process to determine if the standard MITA business process would apply to develop a concept of operations for the SoonerCare EHR Incentive Program. As shown in Figure 1, all MITA business processes were reviewed and where feasible the approach adopted was to integrate the SoonerCare EHR Incentive Program business process into OHCA’s corresponding standard MITA business process. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 5 2/25/2010 © 2010 Cognosante PRIVATE AND CONFIDENTIAL MITA SS-A Elements Facilitating Inputs SMHP Requirements MITA State Self-Assessment: As Is and To Be MITA State Self-Assessment: Gap Analysis MITA State Self-Assessment: Executive Visioning MITA Roadmap and Transition Plan MITA Technical Assessment Activities Current Landscape Assessment and To Be Environment Current Landscape Assessment and To Be Environment Specific Steps Necessary to Implement the EHR Program HIT Roadmap and Incremental Approach to Implementation Current Environment, To Be Environment, and HIT Roadmap Develop MITA Technical Assessment Develop MITA Roadmap & Transition Plan Current MITA SS-A Capability Levels based on MITA 2.01 Framework Review information and conduct interviews Figure 1 MITA SS-A to SMHP Alignment The 2009 MITA Technical Assessment will be reviewed following the identification of the Business and Technology gaps and functionality needs to fill the gaps. The Technology Assessment will be updated as necessary and SoonerCare EHR Incentive Program HIT projects integrated into the MITA Roadmap. 1.1.1.2 As Is Environmental Scan The OHCA conducted an environmental scan of the SoonerCare providers to gather information to describe the current state of HIT adoption and use of EHRs in provider offices and hospitals across the State. OHCA elected to scan all currently contracted SoonerCare providers that were of the types considered eligible for the SoonerCare EHR Incentive Program under the proposed rule: Physician, Pediatrician, Nurse Practitioner, Certified Nurse Midwife, and Dentist, and all EHs in the state. OHCA identified 6,199 individual and group providers and 130 hospitals (which included six Indian Health Service (IHS) hospital facilities). Ninety-three FQHCs/RHCs were also identified. As Oklahoma is largely a rural state, extra efforts were made to ensure that scans reached and were responded to by small and rural providers. Focus of the scans remained on in-state providers. During the process of developing the scans, it became apparent that collecting similar information from the FQHCs and RHCs would provide a better understanding of the environment. It was determined that the survey developed for EPs would serve this purpose. To ensure Oklahoma’s large Native American population was also represented, the EP and EH State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 6 scans were administered to the Indian Health Services/Tribal facilities/Urban Indian Clinics (I/T/U) healthcare providers. Eligible Professionals (EPs) were notified of the preliminary scan via the OHCA public SoonerCare EHR Incentive Program web site, fax, and/or email blasts, and through a global banner on the SoonerCare claims billing site. The initial EP scan was also available on the OHCA public web site for providers that may not have been targeted. The preliminary scan was used to identify potential EPs (those who reported meeting the patient threshold but do not currently use an EHR) that expressed an interest in the SoonerCare EHR Provider Incentive Program. An EP follow-up scan was conducted by telephone interview with those who reported use of an EHR/EMR to collect more detailed information to ascertain whether the EHR product used contains any or all required meaningful use data as published in the Final Rule. Results of the follow-up scans related to meaningful use criteria are not available at the time of this SMHP submission. The notice to EHs was sent by email with a link to the survey. The OHA assisted OHCA by notifying hospitals of this opportunity and encouraging their participation in the SoonerCare EHR Incentive Program to adopt or upgrade their systems to certified EHR technology. All hospitals were informed of the importance of the environmental As Is scan and their participation requested. OHCA also participated in several state conferences in the early months of 2010 (OSMA EMR Conference, Rural Health Association, 8th Annual Rural Hospital Conference), and OHCA used these opportunities to present the SoonerCare EHR Incentive Program, notify participants about the scans, and request participation. Oklahoma environmental scans included several questions on Internet access and all information obtained from the scans will be shared with the OKHIE stakeholders to ensure all statewide stakeholders are working from the same knowledge base. OFMQHIT, the State’s Regional Extension Center entity, will be notified of the respondents indicating they would like assistance with selecting and/or using certified EHR technology. 1.1.1.3 Environmental Scan Results Oklahoma’s SoonerCare providers are in various stages of adoption, with larger, more urban organizations generally more automated than smaller, rural practices. Mid-sized organizations, such as FQHCs/RHCs and provider groups are in various stages of using, adopting, and implementing EHR/EMR solutions. Many of Oklahoma’s smaller agencies and clinics have expressed interest in the SoonerCare EHR Provider Incentive Program, but will require assistance and support to adopt and implement EHR capability. Below in Figure 2 are the results of overall EHR adoption across the different provider groups targeted in the scans. “Presumed eligible” providers were those that self-reported meeting the patient volume requirements established in the proposed rule and were enrolled in an eligible provider type. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 7 Figure 2 Percentage of Providers Reporting EHR/EMR by Group OHCA initially targeted 6,199 health professionals; 505 were unable to be contacted, so a total of 5,694 were contacted to participate in the scan. OHCA received responses from 2,029, or 36 percent of the targeted health professionals. Of the 2,029 health professionals that responded to the initial survey, 65 percent are in urban areas, 35 percent are rural. Those indicating they had an EHR/EMR were 47 percent of the total number of respondents. Rural health professionals indicating they had an EHR/EMR were 46 percent of the total respondents; those without, 54 percent. Urban health professionals indicating an existing EHR/EMR were 47 percent of the total respondents; those without were 53 percent. Figure 3 depicts the responses for EPs by Provider Type. Figure 3 Non-Hospital Responses by Provider Type IHS and Tribes Response by Provider Type are shown in Figure 4 below. I/T/U providers have the highest rate of current EHR adoption of any provider category in Oklahoma, presumably because they have access to EHR capabilities through the federal Resource and Patient Management System (RPMS) system. Of the 475 I/T/U health professionals that responded, 88 percent indicated they had an EHR/EMR. Of all I/T/U provider respondents, 99 percent expressed an interest in participating in the SoonerCare EHR Incentive Program. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 8 Figure 4 Indian Health Service (IHS) and Tribal Providers Of the 80 hospitals that responded, 44 percent are in urban areas, 56 percent in rural. Figure 5 shows those indicating they had an EHR/EMR were 42 percent of the total number of respondents. Rural hospitals that indicated they had an EHR/EMR were 23 percent of the total rural respondents; those without, 35 percent (with 15 percent missing responses). Urban hospitals indicating an existing EHR/EMR were 54 percent of the total; those without were 26 percent (with 9 percent missing responses). Figure 5 Hospital EHR Environment As shown in Figure 6, 58 percent of the hospitals intend to install or make changes to an EHR/EMR system. Figure 6 Hospital Future EHR Plans State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 9 Of all hospital respondents shown in Figure 7, 61 percent intended to participate in both the Medicaid and Medicare Provider Incentive Programs. Overall, 80 percent of the respondents expressed an interest in participating in the SoonerCare EHR Incentive Program. Figure 7 Provider Participation Selection As shown in Figure 8, 64 percent of hospitals reported having access to broadband services. Figure 8 Hospital Broadband Access Figure 9 below identifies hospitals reporting EHR/EMR with capability to collect data as required for meaningful use reporting. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 10 Figure 9 Hospital Existence of Meaningful Use Criteria Figure 10 shows Smartnet at 21 percent is the HIE with the most hospital participation. Figure 10 Hospital Participation in HIE State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 11 1.1.2 Vision of HIT Future This section will include a description of vision of HIT future in Oklahoma. OHCA programs will leverage the clinical data made available through electronic health record technology to achieve their goals and vision for improving population health outcomes and quality of care for Oklahomans. OHCA programs plan to leverage the clinical data made available to OHCA through provider adoption and meaningful use of certified EHR technology to meet the federal goals to improve population health, reduce medical errors, improve health outcomes, and empower SoonerCare members to participate in their healthcare. OHCA vision for the future anticipates improvements in health outcomes, clinical quality, and efficiency in multiple physical and behavioral healthcare management environments with increased usage and interoperability of EHR systems. Best practices and trends in direct care and care coordination efforts can be identified by expanding reporting abilities and evaluating outcomes data. Potential and actual cost impact can be calculated to guide further program development. Utilization review endeavors can be enhanced from both pre-payment and post-payment perspectives. Through developments in data exchange through HIEs, provider access to data will further enhance care coordination opportunities, eliminate duplication of service, and foster identification of appropriate levels of care. Similarly, OHCA, on behalf of SoonerCare members, will be able to more effectively identify serious quality of care issues, gaps in care, member compliance issues, and member behavior trends in areas such as ER utilization. OHCA’s MMIS is poised to move forward to connect and provide services to providers attempting to achieve meaningful use. Additional functionality to become interoperable will be added as needed to provide the greatest benefit from the MMIS data. The MMIS will develop the capability to receive and interpret Health Level Seven (HL7) messaging structures. OHCA secure provider and member portals under development at this time will be completed, providing more timely exchange of data and reduced data processing errors that occur today due to time lag in getting information entered into the MMIS. The Electronic Provider Enrollment (EPE) system will be modified to accommodate registration and attestation data related to the SoonerCare EHR Incentive Program and interface with the NLR. The EPE system is used to allow providers to electronically attest and is not an enrollment into the SoonerCare EHR Incentive Program. This attestation is under secure electronic signature and in itself a contract modification. The providers will not be required to submit hard-copy attestation by mail. However, providers may submit supporting documentation using email or fax. Access to the clinical data from providers will be through direct input into the EPE system or the OKHIE. Security of clinical data will remain a priority for both OHCA MMIS and the OKHIE and individually identifiable health information will be exchanged only as permitted by Health Insurance Portability and Accountability Act (HIPAA) for purposes of treatment, payment, and health plan operations. Security of data will be maintained as required by HIPAA, required for federal systems, and to meet ARRA security requirements. Collaboration with Oklahoma Health Information Exchange Trust (OKHIET) participants and HIIAB members will continue to improve HIE and standardization of data formats and metadata descriptions will occur. National standards will be adopted and used by all participants in these exchanges as soon as available. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 12 A comprehensive vision for statewide HIT/HIE is not available at this time because OKHIE Strategic and Operational Plans are not yet complete and the statewide effort is still in the early stages. Thus, OHCA is submitting partial completion of this section of the SMHP, which will be updated after further collaboration with OKHIE and further development of statewide plans are available. OHCA plans to align its vision with the statewide vision once developed. During the implementation phase, OHCA will continue to have dialog and collaborate with OKHIE, HIIAB, and other stakeholders to define how the OHCA and OKHIE visions can become reality. 1.1.3 Provider Incentive Program Implementation This section will include a high-level overview of the Provider Incentive Program and actions taken to implement the program. A broad range of business and information technology (IT) staff from OHCA operations participated in the planning effort to ensure all impacts to program operations would be identified and a smooth plan for implementation put into place. The SoonerCare EHR Incentive Program will be integrated into the current organizational structure of the OHCA under the authority of the SoonerCare Operations Directorate. Upon program implementation, a core team of SoonerCare operations unit directors will perform operational control and monitoring processes for the program. Each unit director will leverage existing, well-established business processes (MITA and State-specific), to ensure successful implementation of the program. OHCA will utilize existing business processes and established infrastructure to comply with all CMS reporting requirements. Any new reporting requirements will be incorporated into the existing reporting responsibilities. Communications and outreach to the provider community are considered of utmost importance to the agency. The Outreach, Education, and Information Work group is responsible for developing a planned approach for internal and external communication to ensure all stakeholders are adequately informed on progress made toward the implementation of the SoonerCare EHR Incentive Program. A web page is currently available to inform providers of actions taken by OHCA to implement the program, as well as who is eligible and how to enroll. During the Planning Phase, OHCA Provider Relations staff participated in numerous meetings with associations and providers to explain the program and encourage providers to adopt, implement, or upgrade EHR technology within their practice settings and hospitals. A Communications Plan (Appendix A) was developed during the planning phase and will be further refined during implementation. During the implementation phase, a procedure manual will be developed to communicate program policy and procedures for eligibility, attestation, registration, patient volume, reporting meaningful use measures, requesting payment, recoupment, and to advise providers of the appeals process. Another important ongoing activity is the review of regulatory requirements, identification of policy and regulatory changes. A comprehensive review of new policy required to implement the SoonerCare EHR Incentive Program will occur after the Final Rule is released. OHCA anticipates a new section of policy dedicated solely to the governance of the program. Based on the assessment, areas that must be addressed include policy related to SoonerCare patient volume standards, the definition of pediatrician, Meaningful Use criteria, and payment to EPs. Where no specific written policy exists, OHCA will defer to the Final Rule issued by CMS. Relevant sections of OHCA Administrative Code (Title 317) Chapter 2 Grievance rules will be State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 13 revised to incorporate provider appeals processes related to EHR incentive payments. No changes to, or new state laws, are expected at this time. Plans are underway to enter into data exchange agreements with surrounding states in order to obtain member eligibility and patient volume data. OHCA will leverage the work currently underway by OKHIE and continue its participation in multi-state efforts to build on the results from Health Information Security and Privacy Collaborative (HISPC) and focus on the issues of interoperability agreements, privacy laws, rules, and regulations, security of systems and data and engaging providers, consumers, and OKHIE in discussions on privacy and security as it relates to interstate data exchange. All providers (individuals and hospitals) who receive incentive payments must have existing Provider Agreements with OHCA. Eligible professional types include those identified in the regulation. When ready to apply for incentive payment, the provider must execute a contract update through OHCA’s EPE system and supply the new information necessary to receive payment (e.g., patient volume, NLR registration, meaningful use measures, etc.). The provider must enter the required electronic attestation statements. When information is processed and verified the system will send an acceptance letter to the provider, making the contract update effective. OHCA plans to use its existing SoonerCare Call Center Operations at the Fiscal Agent to respond to questions from EPs and EHs about the SoonerCare EHR Incentive Program. OHCA will validate provider enrollment with the NLR for Medicare or other State enrollment, National Provider Identifier (NPI), Taxpayer Identification Number (TIN), as well as the State licensing board, and check CMS sanction list prior to annual payments being made. The EPs and EHs or CAHs must complete their respective attestation statements in the EPE system OHCA will review the provider attestation information and determine eligibility for payment. Provider expenditures/accounts payable (AP) will be entered manually into the MMIS and the SoonerCare EHR Incentive Program funding code applied. Providers determined to be eligible for incentive payments will be identified and payments made on a monthly basis (e.g., all providers identified as eligible in January 2011 would receive Year 1 payments in February 2011). OHCA will use the MMIS to validate professional and hospital eligibility, calculate appropriate payment amounts, and make payments through electronic funds transfer (EFT). OHCA will implement business processes and verification methods to assure appropriate payments are made to EPs. To ensure that no amounts higher than 100 percent of federal financial participation (FFP) will be claimed for reimbursement, the provider incentive payments will be reported on a separate line on the CMS 64 (MAR1060/1062 report). This report will be reviewed for accuracy and deficiencies. The State has no current plans to designate any entities for promoting the adoption of certified EHR technology. System controls will be implemented and tested in the MMIS Financial Sub-system to ensure appropriate payments and reporting. OHCA has participated in several workshops to encourage providers to adopt, implement, or upgrade certified EHRs. Coordination with the Oklahoma Foundation for Medical Care Regional Extension Center (OFMQHIT) is ongoing and OHCA provides leads and assists providers in contacting the OFMQHIT for assistance. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 14 OHCA will use the meaningful use measures identified in the Final Rule for the first year of the program. Annual review of meaningful use measures will occur and changes made through Oklahoma’s policy change process. OHCA is dependent upon the NLR database to support the registration of EPs and EHs into the SoonerCare EHR Incentive Program. In the event the NLR is not available on January 1, 2011, OHCA will compare the registration requests received prior to NLR availability to the data in the NLR when it becomes available. OHCA will utilize its existing internal process to validate the provider submission and for discrepancies recoup the EHR Incentive payment for any payments made in error. 1.1.4 MITA HIT Roadmap This section will include graphic depicting the planned HIT Roadmap. OHCA recently provided to CMS the MITA Roadmap and Transition Plan developed for the MMIS Re-procurement activities. The Roadmap is provided in Figure 11 below. This work can be leveraged and integrated into the statewide HIT Landscape to promote statewide cost-effective and efficient use of HIT, where feasible. OHCA has identified the MMIS changes needed to solution the immediate need to implement the SoonerCare EHR Incentive Program within the EPE and MMIS systems. An Implementation Advance Planning Document (IAPD) will accompany this SMHP for funding of these systems change requests. The MITA Roadmap contains a placeholder for immediately needed changes to the MMIS to support the SoonerCare EHR Incentive Program payments. This section of the MITA Roadmap will be updated to add the HIE/HIT projects arising from the SMHP planning activities. OHCA is deferring some of its longer-term planning and benchmark development for HIT/HIE since the OKHIE Strategic and Operational Plans are not complete at this time. OHCA dialog with the HIIAB, Broadband grantee, and Beacon Communities grantee is also underway. When details of these projects are fully understood, including a timeline for projects, this SMHP will be updated and a separate IAPD request for funding will be submitted. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 15 Figure 11 MITA Roadmap OHCA goals were aligned with the national goals to encourage adoption and meaningful use of certified EHR technology and promote healthcare quality and information exchange. OHCA goals promote exchange of individually identifiable health information between SoonerCare providers for care coordination of SoonerCare members. The program is most interested in exchange of the following types of clinical data: prescription drug information; office visit encounters; laboratory diagnostic tests to fill treatment gaps; personal health screening and records for population and patient health outcomes research; service data to link individuals to the Oklahoma Department of Mental Health and Substance Abuse Services (ODMH) system to coordinate care between medical treatment with mental health treatment; clinical data for precertification of services upon request; service data to identify duplicate diagnostic testing and medical errors; patient-centric data to assist SoonerCare patients in managing their health status; and electronic health information needed at point of care for treatment. OKHIE goals include exchange of clinical information to multiple healthcare providers while keeping personal health data safe and secure; making time-critical data available to providers in an ER, office, and/or hospital setting; data to reduce redundant testing by making lab results available; data that reduces patient hassle factors; service data to improve coordination of preventive services; and clinical quality of care data to improve quality and at the same time contain rising healthcare costs by reducing redundant testing. OHCA’s vision includes MMIS and related IT systems exposure of services through an interface to OKHIE. Initially, three types of services will be shared: State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 16 1. OHCA data exposed to payers to aid in administration of healthcare programs (e.g., electronic validation of health plan coverage and coordination of benefits (COBs). 2. OHCA access to shared services clinical data from EHRs. 3. OHCA administrative services necessary to administer the SoonerCare EHR Provider Incentive Program. OHCA is the State Medicaid Agency designated to administer the Provider Incentive Program in Oklahoma. Responsibilities of this role include identifying and tracking EPs and EHs attestations of meaningful use, SoonerCare patient volume threshold, NLR registration information, payments to providers, and receipt of meaningful use measures. OHCA must administer payments to EPs using an established set of rules and prepayment audit processes to verify payments are correct and accurately calculated, recoupment activities occur for any duplicate payments, and FFP drawdown is audited for appropriateness of monies received from the federal government for provider payments and administrative services. Modifications to the MMIS and EPE systems are required to support development of program operation policies and administrative procedures. During the implementation phase, OHCA must develop the policies and procedures necessary for accountability under ARRA. OHCA is charged with encouraging and assisting SoonerCare providers in adoption and conversion to certified EHR/EMR. Outreach to the providers is ongoing and OHCA is collaborating and coordinating these efforts with the OFMQHIT. OHCA is also studying any changes necessary to the current ePrescribe program and point-of-sale (POS) system to assist providers in using e-prescribing. OHCA will track provider participation in the incentive payment program in the Oklahoma MMIS. In addition, OHCA will submit program participation data to CMS including data for the number, type and practice location(s) of providers who qualified for an incentive payment on the basis of having adopted, implemented, or upgraded certified EHR technology, as well as for providers who qualified for an incentive payment on the basis of having meaningfully used such technology. OHCA will evaluate transactions from the NLR to determine if providers have already received Medicare payments or payments from other states that would make them ineligible for SoonerCare Incentive Payments. In the event that the NLR is not available January 2011, OHCA will compare the registration requests received prior to NLR availability to the data in the NLR. When discrepancies are found and investigated, OHCA will utilize its existing internal process to validate the provider submission and recoup the provider Incentive payment if necessary. The OHCA Program Integrity (PI) unit supports the investigation of potential misuse by providers and clients of the SoonerCare program and other programs administered by OHCA. PI staff will add review of provider incentive payments to current audit plans. To demonstrate meaningful use requirements and report measures, the certified EHR products adopted, updated, and implemented by clinicians will need to be able to capture data elements report measures identified for Stage 1, Stage 2, and Stage 3. The clinician must be able to review EHRs from other clinicians, download information into an EHR (e.g., lab results), and push EHR data from their systems to others if coordination of care goals are to be met. How this will occur in Oklahoma will be defined as the details of the OKHIE strategic and implementation plans become available. During implementation, OHCA will determine what information will be State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 17 included in an EHR, what data standards will be used until national meaningful use standards are finalized, and how Medicaid and ARRA funds can be leveraged to support a sustainable HIE infrastructure. The ARRA/HIE/EHR enhancement function must accept an interface with the following: NHIN, Private Insurer EHR systems, other State agency EHR systems; Facility EHR systems, and Clinician EHR systems. 1.1.5 Recommendations This section will include recommendations for implementation. OHCA makes the following recommendations for HIT/HIE implementation: 1. To more efficiently coordinate care for SoonerCare members, continue dialog with HIIAB state agencies and OKHIE on HIE. Promote standardized data formats and metadata for use in shared services and look for opportunities to leverage IT assets. 2. Consider cost efficiencies and sustainability of projects as well as funding sources available as an integral part of governance discussions for the statewide HIE. 3. SoonerCare providers who adopt, upgrade, or implement certified EHR technology will benefit from use of standardized data and metadata to make shared services interoperable with their EHR technologies. 4. Ensure privacy and security requirements for HIPAA and ARRA for ePHI information transmitted by OHCA and OKHIE are met. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 18 2 CURRENT HIT LANDSCAPE ASSESSMENT – THE “AS IS” ENVIRONMENT This section will describe existing resources available and how the state will leverage these existing resources already devoted to HIT. The HIT landscape will include an assessment of current rates of EHR adoption and establish a baseline for “As-Is” state of environment. The OHCA is one of only seven stand-alone Medicaid agencies in the country. OHCA was formed by legislation and is the primary entity in the State of Oklahoma charged with controlling costs of state-purchased healthcare. It currently handles federal funding for Medicaid and State Children’s Health Insurance Program (SCHIP) programs and is experienced in handling all required federal reporting for those programs as well as reports requested ad hoc by federal and state auditors. In addition, there is organizational knowledge as a Transformation Grant recipient and OHCA prepares regular progress reports and evaluations of the grant activities. The SoonerCare program covers over 650,000 lives with a variety of service delivery models, including Oklahoma’s public/private premium assistance program, Insure Oklahoma (IO). As the Medicaid agency, it has dedicated medical, care management, quality assurance, planning, and IT divisions, as well as provider and member services operational divisions. Oklahoma’s Medicaid program puts special emphasis on collaboration within the community of members, providers, and partner agencies to meet the many needs of Oklahomans. The technology division manages multiple large IT and consultant contracts as part of the MMIS and is skilled at the procurement process. Oklahoma’s MMIS is known for its innovation and ability to adapt quickly to new processes. The Oklahoma MMIS was the first MMIS to implement Internet-based claim, eligibility, and other administrative transactions all in real-time operation. The SoonerCare program is one of the first in the nation to implement the medical home model into its Medicaid delivery system. 2.1 Current HIT Activities and Impact on SoonerCare Members This section will describe current HIT activities underway in Oklahoma and their impact on Medicaid beneficiaries and any EHR technology adoption and relationships with other entities within the state. Oklahoma is involved in a number of HIT activities that do and will impact SoonerCare members, both within individual agencies and organizations and across multiple partners. A comprehensive list of statewide HIT/HIE projects is not available at this time because the SHIECAP Strategic and Operational Plans are not yet complete. Thus, OHCA is submitting partial completion of this section of the SMHP, which will be updated after further collaboration and SHIECAP and statewide plans are available. A short list of Oklahoma, OHCA, and public health HIT activities identified to-date include the following: Health Management Program (HMP). The SoonerCare HMP is an ongoing quality improvement initiative aimed at improving the lives of Oklahomans with chronic disease as well as reducing future incidence of chronic disease. This is accomplished through a program based on the Chronic Care Model2 where the main principle is to pair an informed and engaged patient with a prepared and proactive provider in order to create the best possible health outcome. A nurse case management strategy accomplishes creation of an informed and activated member. The other key component to the HMP is the necessary support to assist the provider in becoming more prepared and proactive. This component is commonly known as Practice Facilitation. Practice Facilitation involves specially trained nurses working as free consultants State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 19 who help providers improve their office efficiency and identify methods aimed at improving the quality of care. A portion of this assistance involves the implementation of an electronic health management information system (HMIS) or chronic disease patient registry. This web-based tool, which is property of our HMP vendor, Iowa Foundation for Medical Care, allows the practice to enter member data and track members over time so that members receive all the appropriate tests and treatment recommended for their chronic conditions. The HMIS/registry currently contains disease modules on coronary artery disease, hypertension, diabetes, heart failure, asthma, tobacco cessation, and preventative care. Practices are coached by the facilitators to learn the system and adapt their day-to-day processes to use of the registry.2 With the advent of the OFMQHIT practice advisors, there is a potential for overlap in primary care offices with the HMP practice facilitators. HMP staff is working closely with the OFMQHIT staff to coordinate programs in order to avoid duplication of services. OFMQHIT practice advisors, while focusing primarily on selection and implementation of EMRs, conduct similar workflow assessments to those of the HMP practice facilitator in order to help the practice assess their specific needs in regards to EMR. Also of note, the registry mentioned above is currently near the end of beta testing for an interface that has been built for connection to EMRs. Successful interface will avoid the need for duplication of data entry by providers. Upon implementation, the HMP practice facilitators will be assisting practices in connecting their EMRs to the registry in this manner. Since there are many common goals between the two services and the potential for the practice becoming overwhelmed with technical and process improvement assistance, OHCA will coordinate closely with OFMQHIT center staff to determine appropriate timing of our respective interventions with each common primary care office. OHCA HMP leadership, along with leadership of the HMP vendor has developed a new “collaborative” model of practice facilitation. In this model, instead of delivering service on a steady basis over a pre-determined period of time, primary functions of practice facilitation services have been isolated into core components or services that can be delivered on a customized basis according to the needs of the practice. OHCA has begun work with OFMQHIT leadership to initiate this collaborative practice model and with OPCA, which will serve as a subcontractor to OFMQHIT to fulfill OFMQHIT services to community health centers. Customization of the existing service delivery will allow practices to maximize their opportunity for technical assistance and quality improvement efforts. Telemedicine. OHCA has contracted with numerous SoonerCare providers who utilize telemedicine to provide healthcare services. Telemedicine service is a different way to provide members access to quality healthcare. These services provide communication between a medical specialist and a SoonerCare member by either audio, video, or data interaction. This communication, done with the member present, is in real-time or near real-time. The goal of this service is to expand specialty healthcare services to rural and underserved areas of Oklahoma and improve healthcare for all members. Approved SoonerCare telemedicine networks are identified at: http://www.okhca.org/providers.aspx?id=10253 Electronic Eligibility and Claims Transactions. OHCA is the State’s Medicaid agency and the largest payer in the State. OHCA processes a monthly average of 3.1 million claims, of which 96 2 Copyright 2010. The MacColl Institute. The Improving Chronic Illness Care program is supported by The Robert Wood Johnson Foundation, with direction and technical assistance provided by Group Health's MacColl Institute for Healthcare Innovation." www.improvingchroniccare.org State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 20 percent are submitted as electronic transactions or entered directly via the Internet. Claims are processed in real time and are paid weekly. Electronic Prescribing and Refill. Oklahoma participates in the SureScripts network to connect its providers to pharmacies. E-prescribing is an integral feature of Oklahoma’s recommended EHRs and EMRs. It is being implemented aggressively with each installation and as vendors make this functionality available at the hospital level. The SoonerCare formulary is provided to the ePrescribing vendor (Cerner) and Epocrates for participation in their services. Oklahoma providers have access to the formulary. A baseline for ePrescribe in Oklahoma was derived from comparison of SureScripts 2008 report findings for Oklahoma compared to 2009. The SureScripts national 2008 reports showed: 1. Request for Rx benefit – 6.18 percent of patient visits with a Prescription benefit request and 3.06 percent of patient visits with a Prescription benefit request response, Oklahoma ranked 31st in the country 2. Rx history request – n/a 3. Prescription routing showed 2.09 percent of all prescriptions were routed electronically. Looking at 2009 data SureScripts released on July, 14, 2010, Oklahoma jumped from 2 percent of eligible prescriptions being routed electronically in 2008 to 10 percent in 2009. This is a five-fold increase and with similar increases in 2010 and 2011, OHCA should be able to meet the 40 percent benchmark established in Table 6 of this SMHP. Electronic Clinical Laboratory Ordering and Results Delivery. Currently, the State has primarily point-to-point interfaces between hospitals, major private lab companies, and physician offices that have EHRs. There is a variety of interfaces that have gone live, some with results only coming into a provider’s practice uni-directionally; however, there are a few bi-directional interfaces that have gone live and permit clinical orders and receipts. Bi-directional interface is the preferred method for safety and efficiency. Within the hospital setting, lab order and receipt is typically electronic when Computerized Physician Order Entry (CPOE) is active. Some institutions are also exploring a spoke and hub model to connect interfaces to network hubs and reduce the overhead and maintenance issues associated with point-to-point interfaces. There are two tests performed exclusively by Oklahoma State Lab: PKU and lead screening. Through shared services planned through the HIIAB initiatives, Oklahoma will be able to exchange PKU and lead screening information with providers through the OKHIE. Oklahoma Public Health is working on a PKU detection and lead screening statewide initiative to upgrade systems information added to lab contracts and require labs to participate in HIE when it is available. Contract language includes: “Provider shall transfer test results electronically to a State-approved health information exchange in Oklahoma whenever such exchange is available and subject to federal and state law, results shall be provided in HL7.2.3.1 standard format or higher.” Electronic Public Health Reporting. The Oklahoma State Department of Health (OSDH) has an informal messaging group in the IT Service, which is comprised of OSDH IT personnel, as well as application specific contractors. This group has made significant advances over the past State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 21 three years in messaging electronic laboratory reports (ELR) as well as in messaging disease data to the Centers for Disease Control and Prevention (CDC). The group has additionally made progress in the development of data exchange mechanisms for the Oklahoma State Immunization Information System (OSIIS). The group is moving to a messaging infrastructure that is dependable, yet robust, dynamic, and capable of handling a multitude of emerging OSDH messaging needs. This team has established the use of HL7 as a standard and is committed to conforming to national and international standards as a best practice. The HIIAB has created three task forces to examine and recommend approaches for sharing data services for meaningful use data. The focus of these work groups is exchange of clinical laboratory, immunization, and insurance coverage information. The objective will be to share a single connection to the statewide HIE for each of these services. Through this connection, the OSDH will be able to communicate lab and immunization information with providers via their EHR systems and the HIE. Quality Reporting Capabilities. Through a number of organizations, Oklahoma is making progress toward enhanced quality reporting capabilities. Current models involve the usage of claims-based data, but it is clear this information is limited and attempts to modify quality improvements based on this data have had limited success at a high cost to the delivery of health care. Oklahoma has a significant amount of activity reporting Physician Quality Reporting Initiative (PQRI) information and hospital quality measures. As Oklahoma develops the “network of networks” model, more complete reports with a variety of data will be compiled at the local network level and submitted to appropriate governing bodies. One of the primary goals of the planning process will be to determine what type of reports with what type of data (identified and de-identified) will be permissible at the local and state network level to allow anticipated quality reporting to meet national requirements such as those endorsed by the CMS. On a public health level, the State immunization data are compiled via the OSIIS system, with good penetration in the SoonerCare population via public hospitals, but poor penetration into the private offices and hospitals across the State. OFMQ, Oklahoma’s Medicare Quality Improvement Organization (QIO), is assisting 60 primary care practices with reporting preventative quality indicator measure data (similar to PQRI) to CMS. Data measures for this project include mammography, colon-rectal cancer screening, and adult immunizations (specifically, influenza and pneumonia). This will be a key component of the model from the local EHR to the local network that will in turn help generate quality reports to reflect the overall public health of Oklahoma. 2.2 Current HIT Activities and Impact on SoonerCare EHR Incentive Program This section will describe what other activities are currently underway in OK that will likely influence the direction of the EHR Incentive Program over the next five years Oklahoma has become involved in a number of more recent HIT activities that will or have the potential to impact the SoonerCare EHR Incentive Program. Various entities in Oklahoma have received funding with possible HIT aspects, such as the Congressionally Mandated HIT Grant awarded to Norman Regional Health System in the amount of $377,190.00. This grant supports HIT projects such as telehealth, EHRs, and other HIT. As more information is gained, Oklahoma will work with the awardees to incorporate their efforts into the statewide HIE strategic plans. A comprehensive list of statewide HIT/HIE projects is not available at this time because the SHIECAP Strategic and Operational Plans are not yet complete. Thus, OHCA is submitting State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 22 partial completion of this section of the SMHP, which will be updated after further collaboration and SHIECAP statewide plans are available. 2.2.1 Broadband Internet Access in Oklahoma Broadband penetration across Oklahoma is similar to that in all states, with greater access in more urban areas than in small and rural parts of the State. While any individual provider can implement an EHR system internal to the organization, the ability to participate in an exchange network is limited or impossible if broadband access is unavailable or unreliable. Since there is little existing information on the extent of broadband access in Oklahoma, the environmental scans included several questions on Internet access, the results of which will be shared with OKHIE stakeholders. The proposed broadband Fiber Backbone for Oklahoma is shown in Figure 12. Figure 12 Oklahoma Proposed Broadband Fiber Backbone There are numerous federal funding agencies for broadband efforts and Oklahoma stakeholders have applied for and received grants under several funding sources. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 23 Funding for mapping and planning activities: The National Telecommunications and Information Administration (NTIA) Award Oklahoma Office of State Finance (OSF) has received approximately $1.6 million in funding for broadband data collection and mapping activities over a two-year period OSF has received nearly $500,000 for broadband planning activities over a five-year period in Oklahoma Funding for expanding infrastructure and services: Department of Commerce Broadband Technology Opportunities Program (BTOP) Awards Allegiance Communications: Allegiance Fiber to the Home Project; $28,619,485. Covers Arkansas, Kansas, Oklahoma, and Texas. Pine Telephone Company, Inc.: Broadband Grant for Isolated Southeastern Oklahoma/Choctaw Nation/Rural/Non-Remote Areas Project; $9,472,078 One Economy Corporation: 21st Century Information and Support Ecosystem: Make it Easy Where You Are; $28,519,482. Funding supports 32 states including Oklahoma. US Department of Agriculture Broadband Initiative Program (BIP) Awards Pioneer Long Distance, Inc.: The Western Oklahoma Wireless (WOW) Project; $1,819,349 loan and $1,783,322 grant. Provide wireless broadband service to unserved and underserved rural areas in western Oklahoma. Panhandle Telephone Cooperative, Inc.: The Western Oklahoma Broadband Infrastructure Development Project; $3,366,188 loan, $10,098,562 grant, and $23,297,597 of private investment. Provide a broadband infrastructure to rural areas within the western Oklahoma panhandle area. Pride Network, Inc.: $12,811,071 loan $6,309,931 grant. Construct a fiber-to-the-premises (FTTP) telecommunications infrastructure, with a WiMAX service-extension overlay, to bring advanced broadband services to rural communities in Texas. A small part of this network (less than 5 percent) will serve an area in Oklahoma. 2.2.2 Beacon Community Grant A Beacon Communities grant for $12,043,948 was recently awarded to the Community Services Council of Tulsa to build a community-wide information system. The grant is to leverage broad community partnerships with hospitals, providers, payers, and government agencies to expand a community-wide care coordination and health information system, to increase appropriate referrals for cancer screenings, decrease unnecessary specialist visits, and (with telemedicine) increase access to care for patients with diabetes. The Principal Investigator of the Beacon Community Grant is a key advisor to the OKHIE and representatives from Tulsa participate on the OKHIE domain work groups. The Beacon Community is just beginning its planning following the grant award. Collaboration with SHIECAP and OHCA will be important to ensure security and interoperability of clinical data as well as access to NHIN through OKHIE. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 24 2.2.3 Oklahoma Health Information Exchange (OKIE) Major HIT/HIE activity in Oklahoma is under an organization called the OKHIE, which involves public and private sector stakeholders in planning and coordinating statewide HIT activities. The Oklahoma State Health Information Exchange (HIE) Cooperative Agreement Program (known as SHIECAP) operates under the OKHIE. OKHIE provides program oversight and is creating HIE strategic and operational plans. OKHIE members represent many state interests: tribes, providers, insurance companies, patients/consumers, health care associations, HIT vendors, health care purchasers and employers, public health and other state agencies, professional health institutions, and clinical researchers. The planning effort is conducted through an open process and in communication with the larger health care community. OHCA has an HIT/HIE relationship with the other State agencies’ participating in the HIIAB. OHCA chairs this board which was created through State legislation to develop a strategy for the adoption and use of EHRs/EMRs and health information technologies that is consistent with emerging national standards and promotes interoperability of health information systems. The advisory board consists of 10 members who are appointed by directors of the following agencies: OHCA, OSDH, ODMH, Department of Human Services (ODHS), State and Education Employees Group Insurance Board, Insurance Department, Department of Corrections, State Department of Rehabilitative Services, and City-County Health Departments of Tulsa and Oklahoma City. 2.2.4 Federally Qualified Health Clinics and Rural Health Clinics OHCA works closely with the Oklahoma Primary Care Association, representing the FQHCs and RHCs. Currently no funding has been directed toward this group and they have not received any funding for health transformation technology or electronic health records from Health Resource and Services Administration (HRSA). OHCA will continue to look to engage the FQHCs/RHCs in HIT opportunities in the future. 2.2.5 Oklahoma Exchange Networks There are a number of exchange networks that currently operate within Oklahoma. These will be more fully documented in the network scan, which is under the direction of the State’s SHIECAP effort and is still under development. At this time, OHCA is not directly participating in an operational exchange network. Some information on current provider participation in an exchange network was collected via the 2010 environmental scans. More hospitals than health professionals currently participate in an existing exchange network; 21 percent of responding health professionals and 30 percent of responding hospitals indicated they are currently participating. Additional information on network participation is still being collected via ongoing environmental scans of SoonerCare providers. Networks currently in existence in Oklahoma are listed below. Results of the scan will be available mid to late July, 2010. This SMHP will be updated at that time. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 25 Table 1 Existing Regional Health Information Exchange (HIE) Efforts Regional Network Providers Covered Status Planning Support Duncan Network Hospital physician exchange Planning SMRTNET Greater Oklahoma City Hospital Council (GOCHC) Bordered by Norman, Edmond, Shawnee, and Yukon. Includes 13 hospitals and many other provider types Operational SMRTNET Greater Tulsa Health Access Network (GTHAN) Tulsa area Planning SMRTNET Health Alliance for the Uninsured 16 clinics in the OKC area Construction SMRTNET Heartland Healthnet 5 Hospitals and 20 Clinics Operational Internal to Organization Indian Health Service (IHS) using RPMS At I/T/U facilities Live at certain facilities and in planning at others IHS Norman Physician Hospital Organization Norman eClinicalworks providers 3 hospitals, 225 providers planned, 15 Clinics live Testing/Pilot/Live Planning NPHO/SMRTNET Northeast Oklahoma 14 counties Operational SMRTNET OPCA State community health centers Finalizing planning, awaiting federal funding SMRTNET OSMA OSMA physicians In early planning SMRTNET State Agency Network State agencies On hold after request for information (RFI) pending State planning issues State HIE Planning 2.2.6 Recommendations This section will present the Medicaid recommendations to the State HIT Coordinator on how OHCA will proceed with supporting Oklahoma’s HIE/HIT initiatives. As discussed throughout the SMHP, OHCA is an active participant in Oklahoma’s planning phase to develop statewide HIE. As well as serving as a standing member on the SHIECAP work group, OHCA chairs the HIIAB tasked with preparing State agencies to participate in the exchange. As the State’s Medicaid agency, OHCA is ready and willing to create any kind of data bridge that needs to exist in the MMIS to facilitate the exchange of health information. OHCA is working with other State agencies through the HIIAB to develop the networking necessary to share State agencies’ health information when the capability becomes available statewide. OHCA is also working with regional/community-based resources such as health access State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 26 networks (HANs), Value-added networks (VANs) and Regional Health Information Organizations (RHIOs) to develop and/or leverage resources already in place. OHCA's purpose is to ensure that SoonerCare providers are ready and able to participate in the HIE and to assist them in accessing federal and state opportunities for this endeavor. Through the SoonerCare EHR Incentive Program, OHCA has the ability to reduce the financial burden on specified providers who choose to obtain and meaningfully use certified EHR technology. With its MMIS capabilities, the SoonerCare EHR Incentive Program and our connection to the medical community, OHCA has the capability, functionality and aspiration to play a vital role in Oklahoma’s efforts to develop and implement the infrastructure for HIE. 2.3 State Medicaid HIT Plan Development This section will describe how the SMHP will be planned, designed, developed and implemented, including how it will be implemented in accordance with the Medicaid Information Technology Architecture (MITA) principles as described in the Medicaid Information Technology Framework 2.0. In 2009, Oklahoma completed a MITA SS-A and Technical Assessment and developed the MITA Transition Plan and Roadmap for moving the MMIS forward to its envisioned To Be state. This Roadmap was submitted to CMS with the IAPD requesting funding for a RFP that will result in a competitive procurement of SoonerCare Operations and MMIS maintenance responsibilities during the new contract period. This work will be leveraged and integrated into the statewide HIT landscape to promote statewide cost-effective and efficient use of HIT, where feasible. OHCA will identify the interdependencies within the current Oklahoma HIT projects, as well as new ones that develop during strategic and operational planning of the OKHIE. The same iterative MITA planning process will be used, beginning with an environmental scan to assess the As Is readiness of SoonerCare providers and identify gaps. OHCA will also use the environmental scan to identify other collaborative efforts and initiatives in which providers are involved in to enable the planning process to identify economies and efficiencies that may be achieved through shared State IT assets. During the planning phase, OHCA business areas reviewed the regulatory requirements for submission of the SMHP published in the Final Rule at §495.332 and in CMS guidance for developing the SMHP published on April 29, 2010. The work groups then reviewed each business process that has been and will continue to be implemented to develop a concept of operations for the SoonerCare EHR Incentive Program. Where feasible the approach adopted was to integrate the SoonerCare EHR Incentive Program business process into OHCA’s corresponding standard MITA business process. Throughout this SMHP document, OHCA has placed a reference to the applicable standard MITA business process within the discussion of the SoonerCare EHR Incentive Program business process. This ensures reviewers of the SMHP can quickly ascertain how new business processes will be implemented in accordance with the MITA principles as described in MITA Framework 2.0. A description of OHCA work groups and collaborative efforts are provided in Section 4.1 through 4.1.9 below. OHCA has also collaborated and will continue to coordinate with the interim State HIT Coordinator, SHIECAP, HIIAB, the Broadband Grant Awardee, the Beacon Community Grant Awardee, and the OFMQHIT on this important national health care initiative. OHCA has recently opened a dialog with these entities to identify projects of interest to the multiple stakeholders. When identified through collaboration, OHCA prioritized the projects taking into consideration State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 27 the MITA Roadmap already developed for MMIS Re-procurement and integrated projects as appropriate into the MITA/HIT Roadmap five-year timeline as shown in Section 5.1. 2/25/2010 © 2010 Cognosante PRIVATE AND CONFIDENTIAL MITA SS-A Elements Facilitating Inputs SMHP Requirements MITA State Self-Assessment: As Is and To Be MITA State Self-Assessment: Gap Analysis MITA State Self-Assessment: Executive Visioning MITA Roadmap and Transition Plan MITA Technical Assessment Activities Current Landscape Assessment and To Be Environment Current Landscape Assessment and To Be Environment Specific Steps Necessary to Implement the EHR Program HIT Roadmap and Incremental Approach to Implementation Current Environment, To Be Environment, and HIT Roadmap Develop MITA Technical Assessment Develop MITA Roadmap & Transition Plan Current MITA SS-A Capability Levels based on MITA 2.01 Framework Review information and conduct interviews Figure 13 MITA SS-A to SMHP Alignment The 2009 MITA Technical Assessment will be reviewed following the identification of the Business and Technology gaps and functionality needs to fill the gaps. The Technology Assessment will be updated as necessary and SoonerCare EHR Incentive Program projects integrated into the HIT Roadmap. Figure 14 identifies key MITA Framework components that will be assessed as OHCA continues into the implementation phase. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 28 MITA Framework Components © 2010 Cognosante PRIVATE AND CONFIDENTIAL Figure 14 MITA Framework Components 2.4 HIT Landscape Assessment This section will contain an overview of the how the HIT Survey will be conducted; who will participate; when the assessment will occur; and the methodology for analyzing data received on the environmental scans. The OHCA has conducted As Is HIT Landscape Assessments for professionals, hospitals, FQHCs/RHCs, and I/T/U. Results were shared with OKHIE, OFMQHIT, the OHA, the OFMQ, OSF, and Oklahoma State University Center for Rural Health (OSUCRH). OKHIE is currently conducting an environmental scan for networks and these results will be shared with OHCA when available. The methodology, survey questions, participants, timeline, and results are available in Section 2.5 below. 2.4.1 Existing HIT and Data Resources This section will provide an inventory of the existing Medicaid resources devoted to HIT and describe how the state will leverage these resources in the most efficient and economical way to assist in implementation and operation of Provider Incentive Program and EHR health information exchange. Resources to be leveraged include: MMIS and/or DSS/DW capabilities or functionalities to participate in health care data exchanges today.; Public Health Systems; DHS Eligibility System; Data availability and usability; Others?; A description of current interoperability status of the State Immunization Registry and Public Health Surveillance reporting databases There are a number of systems that support Oklahoma’s SoonerCare and related public health functions. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 29 Electronic Provider Enrollment (EPE). OHCA will leverage EPE for EP and EH enrollment and eligibility in Oklahoma’s SoonerCare EHR Incentive Program. The financial expenditure functionality will be used to appropriately track automated payment of incentives to EPs and EHs. Current MMIS financial and management processes will be leveraged to ensure applicable federal, state, and local operations and reporting requirements are met. Electronic Eligibility and Claims Transactions. The OHCA is the State’s Medicaid agency and the largest payer in the State. OHCA processes a monthly average of 3.1 million claims, of which 96 percent are submitted as electronic transactions or entered directly via the Internet. Claims are processed in real time and are paid weekly. Oklahoma State Immunization Information System (OSIIS). OSIIS is a statewide immunization registry that Oklahoma began using in 1995. It is designed to collect and maintain accurate, complete, and current immunization records for the entire population of Oklahoma, but the main emphasis has been children’s records. Any physician or clinic that provides immunization through the Vaccines for Children (VFC) program may access OSIIS to determine what vaccines are needed and record any vaccines given. Because not all providers participate on OSIIS, immunization records are not always complete. Participating providers have free local or long distance access to OSIIS 7 days a week. OSIIS currently receives data from providers in HL7 2.3.1 standard format. The Oklahoma OSDH is applying for a grant through the CDC to increase the systems interoperability functionality (Funding Opportunity Number CDC-RFA-IP10-1002ARRA10). There is no electronic exchange between OSIIS and any of OHCA’s systems at this time. OSIIS is an antique system and not capable of data exchange with IHS and Tribal systems at this time. OSIIS is maintained by Oklahoma State Department of Health (OSDH). OSDH has applied for a CDC grant and depending on funding, OSIIS capabilities will be updated or the system replaced to allow interoperability with I/T/U systems. The HIIAB has established a task force to review exchange of immunization data statewide and investigate shared services approach. The objective will be to share a single connection to the statewide HIE for each of these services. Through this connection, the OSDH will be able to communicate lab and immunization information with providers, including I/T/U systems, via their EHR systems and the HIE. OHCA is currently investigating the feasibility of a variety of data transfer mechanisms for use with I/T/U systems, including automated basic File Transfer Protocol (FTP) and HTTP. Public Health Investigation and Disease Detection of Oklahoma (PHIDDO): The preferred method of reporting diseases or conditions to the OSDH is through the PHIDDO system. PHIDDO receives automated files from two laboratories: LabCorp and Diagnostic Labs of Oklahoma in HL7 format. PHIDDO is a real-time, secure, internet-based application that provides a centralized place for reporting diseases and conditions in Oklahoma. All data is secure and accessible only to registered users. The benefits of PHIDDO include secure disease reporting, accurate report submission, decreasing the time of report, decrease in the time to begin and complete investigations and control efforts, and elimination of paperwork, faxing and mailing of reports to OSDH. PHIDDO users include physicians, physician assistants, nurse practitioners, infection control practitioners, laboratorians, and other personnel in a clinic or health care setting who submit cases of reportable diseases and conditions. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 30 The HIIAB is tasked with determining how these assets can be shared. The HIIAB meets monthly and has established work groups to begin working together on the following initiatives: Expose SoonerCare eligibility as a service to HIE Share and expose Immunization Registry data as a service to HIE Expose and share state-administered lab tests to HIE 2.4.2 MITA State Self-Assessment (SS-A) This section will include a summary of the State of Oklahoma Medicaid Information Technology Architecture (MITA) State Self- Assessment (SS-A) vision, goals, 5 and 10 year MITA roadmap. In 2009, a visioning session was held with executive leadership of the Oklahoma SoonerCare program. The thoughts and ideas expressed within that meeting, as well as the Oklahoma 5- to 10-year Strategic Plan, were captured as Guiding Principles to track through the MITA SS-A process. The Guiding Principles were matched to the MITA goals and are demonstrated by objectives and actions to clarify the intent. As with the MITA SS-A process, goals and objectives are dynamic and must respond to the ever-changing healthcare environment and legislative requirements. The OHCA Guiding Principles are provided in Table 2 below. Table 2 Executive Guiding Principles and Objectives MITA Goal OHCA Guiding Principle Objective/Actions Integration and Interoperability Promote efficient and effective data sharing to meet stakeholder needs. Integrated Call Center – This will provide enhanced call routing capabilities and the integration and availability of call center data to provide operational efficiency and flexibility across all OHCA call centers. Document Management – Integration of the COLD imaging system with the MMIS for improved access to information and operational efficiency. Enhance and introduce up-to-date management information and communication systems through the MMIS Re-procurement project. Letter Generation – Implement a flexible and configurable system component to improve operational efficiency and enhance member and provider communication. Medical Care Management (Atlantes) – Enhancement of the Atlantes Case Management system and further integration with the MMIS will allow a broader spectrum of OHCA staff to utilize the system more effectively. Promote reusable components and modularity. Claims Processing – Implementation and integration of the existing Business Rules Engine into the MMIS for enhanced claims processing. Promote efficient and effective data sharing to meet stakeholder needs. Secure Provider Portal – This enhancement will allow providers real-time online access to view and change their account information, saving OHCA significant staff time in data entry and phone inquiries. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 31 MITA Goal OHCA Guiding Principle Objective/Actions General System Functionality – Enhancement of Data Warehouse capabilities (Data Cubes) for analyzing and reporting of data. It will also include the creation of Dashboards for management decision-making and access to data by the public. Integration and Interoperability Promote efficient and effective data sharing to meet stakeholder needs. Drug Rebate – Automate the process and provide online access for invoices and payments to suppliers. Drug Utilization Review – Reference data file enhancement. Asset Verification – Electronic data exchange with financial institutions for asset verification of Dual Eligibles. Provide a beneficiary-centric focus. No Wrong Door (NWD) – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide enhanced accessibility and eligibility and benefit determination for members. Flexibility to respond rapidly to change Identify, qualify, and manage a cost-effective, efficient, and flexible SoonerCare program. Oklahoma Health Information Organization – Through participation in this statewide initiative, the OHCA commits to promote a comprehensive approach to accelerating the exchange of health information by involving providers and consumers, establishing State agency trust, developing sustainable funding sources, providing capable business services and operations, developing technical capabilities and consulting with State officials. No Wrong Door (NWD) – Implement an online enrollment and eligibility system that will integrate with the MMIS to provide flexibility in response to SoonerCare program and policy changes. Adopt data and industry standards. HIPAA 5010 and International Classification of Diseases (ICD)-10 – The system enhancements to comply with these federally mandated data formats will be included in the MMIS Re-procurement project. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 32 MITA Goal OHCA Guiding Principle Objective/Actions Support integration of clinical and administrative data. Medical Artificial Intelligence (MEDai) Health Management – The integration of MEDai with the SoonerCare Secure Site will allow providers access to information about the illness burden of the SoonerCare members they treat. This information is critical to providers at the point of care to improve health outcomes for SoonerCare members. Promote secure data exchange. Health Information Exchange (HIE) – Implementation of the initial infrastructure to provide the capability to exchange health information between State entities and the public. Flexibility to respond rapidly to change Promote secure data exchange. Secure Member Portal – Implement a portal to provide members the ability to view and manage their information and eventually the capability for Personal Health Records. Electronic Provider Referral – Online access to information for providers to refer members to a specialist. Enterprise view to align technology and business needs Sustain and maximize available funds. Program Integrity (PI) – The PI system will integrate new technologies with fraud detection and case tracking systems to improve the effectiveness and efficiency of fraud and abuse investigations. Ongoing review of reimbursement rates and methodologies to ensure that provider payments are consistent with efficiency, economy, and quality of care. Simplify the claim process, through collaboration with providers. Claims Resolution – Implementation of automated workflow for MMIS claims resolution. Claims Processing – Implementation and integration of the Business Rules Engine into the MMIS to provide efficiency and flexibility in the processing of claims. Break down artificial boundaries between systems, geography, and funding. Insure OK and Insure Tulsa – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured. Data that supports analysis and decision-making Seek to greatly improve the status of health care across the State Insure Oklahoma (IO) – Expansion of the Insure Oklahoma premium assistance program to provide insurance coverage for the uninsured. SoonerCare – Expansion of the SoonerCare program for 19 and 20 year olds. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 33 MITA Goal OHCA Guiding Principle Objective/Actions Ensure accuracy and correctness of payments Program Integrity (PI) – Implement a comprehensive PI system consisting of a Fraud and Abuse Component, a Medical Surveillance Utilization Review System (SURS) Component, a Case Tracking System, and Data Management for the OHCA Program Integrity and Accountability Unit. Data that supports analysis and decision-making Ensure accuracy and correctness of payments The Insure Oklahoma premium assistance system enhancement will include an electronic management system for financial transactions to and from multiple sources, such as premium receipts, invoices, accounts receivable, accounts payable, State and Federal, donations, and commissions. Claim Check – Enhancement of the edit and audit functions for MMIS claims processing. Finance – Enhancements to the Financial system for management of payments and adjustments and reporting. Performance measurement for accountability and planning Improve the effectiveness and efficiency of the delivery of medical services. The Emergency Room (ER) Diversion Grant will help OHCA develop a program to access a full array of primary and preventative health care for Oklahoma County SoonerCare members. Specifically, this project addresses the overuse of hospital ER use. Maximize revenue by containing costs, eliminating duplication, and using all sources of funds. The OHCA plans to explore the opportunities that exist to better serve Oklahoma’s Dual Eligible population and to capitalize on the expertise of other States, as well as utilize other resources, such as the Center for Health Care Strategies that may assist the OHCA to develop a care coordination plan for Oklahoma’s Dual Eligibles. Provide continuous improvement/utilization review by evaluating service outcomes, program costs, and provider participation to maximize and effectively manage resources. Plans to review and make recommendations and/or implement changes in payment methodologies and reimbursements in order to ensure fair compensation to providers. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 34 MITA Goal OHCA Guiding Principle Objective/Actions Coordinate with Public Health and other partners to improve overall health Attract and maintain a strong network of service providers by continuously evaluating and implementing programs that strengthen the reimbursement process. Self-Directed Services – The Opportunities for Living Life (OLL) action plans continue to describe the OHCA’s many partnerships with other agencies, providers, and advocates to develop collaborates to improve access to long-term support services, and provide for better choice and control for the OHCA’s aging population. Coordinate with Public Health and other partners to improve overall health OHCA is committed to developing a health care partnership with policy makers, beneficiaries, providers, and stakeholders from the community to provide maximum health care benefits to qualified individuals through innovative and cost effective programs. Research in the Health Care Infrastructure in local communities within the State of Oklahoma is intended to allow various stakeholders including, but not limited to: local community leaders, etc., to see both the small- and large-scale pictures of the existing health care infrastructure within their communities. It is hoped that this research may help community leaders make informed decisions about future planning. It is expected that at the conclusion of the research a final report will be prepared and distributed to stakeholders across the State. The OHCA has implemented a system called the Health Management Program (HMP) that targets members with chronic conditions who have been identified by predictive modeling to have a high risk of incurring significant medical cost. The HMP provides patient education and care management services to participants. The HMP also develops provider collaboration focused on holistic health management and evidence-based guidelines, and one-on-one practice facilitation for some primary care providers (PCP) provided by the OHCA’s contractor, the Iowa Foundation for Medical Care. The MITA SS-A conducted in the summer of 2009 specifically anticipated healthcare-related change arising from the impact of healthcare reform. As healthcare reform passed only recently (May 23, 2010), OHCA has not yet analyzed the full impacts of the new law on Medicaid programs, but potential program changes could include any or all of the following: Possible expansions in Medicaid and/or SCHIP eligibility levels and benefits Creation of an insurance gateway or exchange through which Medicaid and/or SCHIP enrollees may seek insurance Changes in program funding with 100 percent federal financing for expansion populations for some time period Increased use of employer-sponsored insurance Changes to Medicaid long-term care programs OHCA will review and analyze the impacts of this new legislation and stands ready to accommodate all new requirements. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 35 The updated MITA SS-A HIT Roadmap is included in Section 5.1. The Roadmap has been updated to add the HIT projects arising from the SMHP planning activities. Since the OKHIE Strategic and Operational Plans are not complete, it is anticipated that HIE/HIT projects will be added to ensure SoonerCare IT assets are leveraged and integrated into the overall statewide HIE efforts. 2.4.3 MMIS HIT/HIE Environment This section will include a description of the role of the MMIS in OHCA’s current HIT/HIE environment. Oklahoma’s MMIS is a highly scalable system with much excess processing capacity. During peak processing times, it operates at less than 15 percent of the system’s available central processing unit (CPU) capacity. The Oklahoma MMIS system provides sub-second response time for real-time transactions, including eligibility queries and point of service claims adjudication transactions. The system’s Sun Unix operating system allows OHCA to add a new CPU or expand the data storage matrix array easily, with users on the system, as needed. For real-time eligibility inquiries and claims submissions, the system currently communicates with VANs. EMRs/ EHRs attached to a VAN have the ability to check SoonerCare eligibility from our MMIS system. Currently it takes about a week to configure, test, and move a new VAN into production. Sharing these services to the OKHIE for a wider audience would be a similar process. Real-time claims adjudication capability exists for point of service pharmacy claims and for our online direct data entry provider users. If needed, these processes could be leveraged for real-time adjudication of non-pharmacy claims. Network traffic studies are conducted twice a year and as needed. When the connection to OKHIE is planned and implemented, internet bandwidth and network traffic will be evaluated and monitored, and appropriate adjustments made as needed. The Oklahoma MMIS system is in preparation to connect to an HIE when it becomes available. In the future, OHCA is planning to incorporate an EHR to enhance and/or streamline many functions currently performed for SoonerCare members including care management and prior authorizations. OHCA will share services in a standard agreed upon format when the data is used to promote care coordination for SoonerCare members and/or transmitted to achieve EP or EH Meaningful Use requirements. Maintenance of the Health Insurance Portability and Accountability Act (HIPAA) and the ARRA security standards for receipt and transmission of the health information is a priority for OHCA, OKHIE, and stakeholders participating in the statewide HIE. 2.5 Environmental As Is Scan Discuss the State’s plan for conducting the required environmental scan to determine the “As Is” state of adoption of certified EHR technology by Medicaid eligible providers in Oklahoma. The overview will include the environmental scan process, identify any associations or organizations that participated and/or assisted OHCA; dates environmental scan distributed; percentage response; any follow up contact attempts, etc. The OHCA conducted an environmental scan of the SoonerCare provider population to gather information to describe the current state of HIT adoption and use of EHRs in provider offices and hospitals across the State. Two types of scans were originally developed to communicate with specific provider groups: one for health professionals (individual and group practitioners) and one for hospitals. Refer to Appendix B for scan questions. During the process of developing the scans, it became apparent that collecting similar information from the FQHCs and RHCs State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 36 would provide a better understanding of the environment. It was determined that the survey developed for EPs would serve this purpose. To ensure Oklahoma’s large Native American population was also represented, the EPs and EH scans were administered to the IHS and tribal health care providers. Existing State health information networks, including integrated delivery networks (IDN) or integrated delivery systems (IDS), were also targeted for environmental scan. Although OKHIE and OHCA planned to conduct a joint environmental scan of the State networks that would provide input for both SHIECAP’s Strategic Plan and OHCA’s SMHP, the timelines for the two efforts diverged and responsibility for the network scan was transferred to OKHIE. Approximately 10 entities were considered to qualify under a broad umbrella definition of HIE networks. Scans were initially developed by members of the Planning, Development and Implementation work group (PDI – See Section 4.1.2 for description), and then reviewed and revised internally by the oversight work group. The EH and Network scans were also reviewed by external parties. The scans were all provided in various formats as described in the following sections. EPs were notified of the preliminary scan via the OHCA public SoonerCare EHR Incentive Program web site, fax, and/or email blasts, and through a global banner on the SoonerCare claims billing site. An introductory letter and a fact sheet (shown in Appendix C), were developed to inform providers of this opportunity. The initial EP scan was also available on the OHCA public web site for providers that may not have been targeted. The EP follow-up assessment was also offered as a phone interview and the EH scan was sent by email with a link to the survey. The OHA assisted OHCA by notifying hospitals of this opportunity and encouraging their participation in the SoonerCare EHR Incentive Program to adopt or upgrade their systems to certified EHR technology. All hospitals were informed of the importance of the environmental As Is scan and their participation requested. OHCA also participated in several state conferences in the early months of 2010 (OSMA EMR Conference, Rural Health Association, 8th Annual Rural Hospital Conference) and used those opportunities to present the SoonerCare EHR Incentive Program, notify participants about the scan, and request participation. All information obtained from the scans will be shared with the OKHIE to ensure all statewide stakeholders are working from the same knowledge base. OFMQHIT, the State’s regional extension center entity, will be notified of the respondents indicating they would like assistance with selecting and/or using certified EHR technology. 2.5.1 Professional Providers (individual and group providers) Scan This group was targeted first with a short seven-question preliminary scan designed to collect baseline information, determine which providers had previously implemented any components of an electronic EHR system, estimate potential eligibility based upon provider type and patient volume, and gauge EP interest in participation in the SoonerCare EHR Incentive Program. Those providers who indicated they had any EHR capabilities were called and given a more detailed (10-question) follow-up scan to document the systems and capabilities currently in place. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 37 The health professional scans were initially administered online using Survey Monkey and provided on paper by mail to ensure that rural providers who do not all have Internet access were contacted and given the opportunity to participate in the survey process. Due to the short timeframe and minimal response, OHCA also began to call health professionals and offer them the opportunity to take the scan by phone, as well as online or on paper upon request. Provider responses were accepted in all three formats, with paper and phone responses entered into the online survey tool and accumulated into the scan data. A notification about the scan effort including the location of the online survey was mailed to potentially EPs, along with a paper copy of the scan. Additional reminders were sent via email and fax, which included notification that providers would also be able to participate in the scan by phone. Phone calls were made to all providers whose initial U.S. mail notification was returned. All EP follow-up scans were administered by telephone. The timeline for the professional providers is shown in Table 3. Table 3 Professional Provider Scan Timeline Date Activity April 1, 2010 Notification and preliminary scan sent via US mail April 5, 2010 Preliminary scan posted on the public web site April 15, 2010 Begin offering preliminary scan by telephone April 26, 2010 Begin calls to providers whose initial US mail notification letter was returned May 13, 2010 Follow-up scan phone calls begin May 28, 2010 Close Scan 2.5.2 Hospital Scan The hospitals were targeted with a single 15-question scan to collect baseline information and document the EHR systems and capabilities currently in place. Each hospital was contacted via email to obtain the appropriate person to whom the technical scan should be sent. Through SurveyGizmo, the contact was then sent a link to an online survey. The link was not made publicly available. SurveyGizmo also sent automatic reminders to non-responders via email at regular intervals. Contact was made to the OHA to coordinate and collaborate on efforts with hopes that 50percent participation in the scan could be achieved from hospitals statewide. The timeline for the hospital scan is shown in Table 4. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 38 Table 4 Hospital Scan Timeline Date Activity April 19, 2010 OHA contacted for assistance April 27, 2010 Notification sent via email. May 5, 2010 Scan available to hospitals May 7, 2010 Begin emails to hospitals that have not responded May 21, 2010 Close Scan 2.5.3 Federally Qualified Health Clinics (FQHCs)/Rural Health Clinics (RHCs) Scan The OPCA assisted OHCA in identifying the State’s FQHCs and RHCs and obtaining contact information for potentially eligible FQHCs/ RHCs. They completed the same 10-question EP scan to collect baseline information and document the EHR systems and capabilities currently in place. The scan was provided online using SurveyMonkey. The timeline for the FQHCs/RHCs Scan is shown below in Table 5. Table 5 FQHCs/RHCs Scan Timeline Date Activity May 5, 2010 OHCA begins administering preliminary scan by telephone May 28, 2010 Close Scan 2.5.4 Indian Health Service (IHS)/Tribal facilities/Urban Indian Clinic Providers Early on OHCA explored with I/T/U partners whether their providers would be eligible for participation in the federal Provider Incentive Program. Once it was clear that they could, the OHCA Indian Health Unit targeted these providers with the 10-question EP follow-up scan. IHS and tribal hospitals were provided the EH scan. The Indian Health Unit worked directly with the OHCA planning and development committees to ensure consultation and inclusion of Indian Health Service, Tribal facilities and Urban Indian Clinics in Oklahoma. The efforts included giving a presentation to Oklahoma City Area Inter- Tribal Health Board, providing a written summary of the SoonerCare EHR Incentive Program and contacting each contracted Indian health facility by telephone or email, including Tribal facilities, Urban Indian facilities, Indian Health Service facilities, and the Oklahoma City Area Indian Health Service Administrative Office. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 39 Each contracted site was personally contacted by one of the staff of OHCA Indian Health Unit to educate, get input, and obtain lists of their potentially eligible providers and later to survey the provider about their practice and their use of electronic health records. OHCA Indian Health Unit worked with I/T/U facilities one-on-one to inform them of the initiative and how it might impact them. I/T/U staff was given the opportunity to ask questions, identify contacts within their tribe and arrange follow-up meetings or conference calls, etc., with OHCA if they had additional questions. 2.5.5 Selection of Environmental Scan Participants This section will describe how the environmental scan population was selected and demographics about the selected providers (statewide, eligible providers, hospitals, HIE networks) and provider specialties, etc. OHCA elected to scan all currently contracted SoonerCare providers that were of the type considered eligible for the SoonerCare EHR Incentive Program under the proposed rule: Physician, Pediatrician, Nurse Practitioner, Certified Nurse Midwife, and Dentist, and all EHs in the State. OHCA identified 6,199 individual and group providers and 130 hospitals, (which included six IHS hospital facilities). Ninety-three FQHCs/RHCs were also identified. As Oklahoma is largely a rural state, extra efforts were made to ensure that scans reached and were responded to by small and rural providers. Focus of the scans remained on in-state providers. Oklahoma has the second largest Native American population in the US. OHCA therefore made special efforts to confirm that I/T/U providers were eligible to participate. The Indian Health Unit at OHCA worked closely with the Native American medical community to administer the scans and ensure their input into the program. OHCA targeted 677 IHS health professionals for the scan. Both the EP and EH scans were utilized for these providers. 2.5.6 Environmental Scan Questions This section will include a description of process used to develop and vet the environmental scan and provide readers with a copy of environmental scan tools used. The OHCA developed three tools for use in gathering responses to questions on the current As Is environment and use of EHR technology in Oklahoma. Types of scans and their objectives include: 1. Eligible Professional (EP) Preliminary Environmental scan – Obtain a landscape of potential SoonerCare EHR Incentive Program eligibility and extent of EHR/EMR adoption. 2. Eligible Professional (EP) Follow-up Assessment – Identify the specific EHR/EMR functionalities in place for those providers who indicated they had an EHR/EMR in the preliminary scan. 3. Eligible Hospital (EH) Environmental scan – Obtain a landscape of potential SoonerCare EHR Incentive Program eligibility, extent of EHR/EMR adoption, and the specific EHR/EMR capabilities in place. The initial drafts of the provider and hospital scans were developed by reviewing existing HIE and EHR scans from other sources through Internet research. Preference was given to State HIE and SoonerCare EHR Incentive Program scans specifically developed for both Medicare and Medicaid programs; but since few of these were available at the time, other state scans and State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 40 some surveys from associations were also evaluated. Relevant questions were pulled from a number of these surveys into a single rough draft for review by OHCA to identify the questions most useful for assessing the As Is state of EHR adoption by Oklahoma SoonerCare providers. A shorter list of questions was then reviewed and revised by several OHCA EHR work groups and further refined into the three individual scans eventually used. All scan results were provided to OHA, OFMQ, OSF, and OSUCRH. The preliminary professional scan was developed first; then the follow-up professional scan, and finally the hospital scan. IHS providers were targeted using the appropriate EP or EH scan. The FQHCs/RHCs were targeted using the longer EP follow-up scan. Each survey includes questions that cover potential eligibility (provider type, patient volume); whether the respondent currently has any EHR/EMR components in place (and if so, vendors used, functions available); meaningful use capabilities currently in place; any current connections to an exchange network; and interest in program participation. The hospital scan was developed in collaboration with several external groups including OHA, OFMQHIT, OSF, and OSUCRH. By doing so, all collaborators sought to develop a single, comprehensive survey that obtained the information needed by a variety of stakeholders and with as little disruption as possible to the hospitals. The initial draft network scan was developed in a similar fashion but then underwent review by OKHIE work groups to further develop the scan for SHIECAP purposes. The intent is to administer the scan in face-to-face interviews with network representatives to provide an opportunity to discuss and clarify questions and responses as part of the interview process. To eliminate duplicate efforts it was decided that OHCA would utilize the results from the SHIECAP Network HIT Scan in assessing current As Is state of networks for placement in the SMHP. As of the first draft of the SMHP, network survey results are not yet available. OHCA set up an informational web site for providers titled SoonerCare EHR Program at www.okhca.org/EHR-incentive that describes the SoonerCare EHR Incentive Program and provides responses to frequently asked questions. The preliminary EP survey was accessible from this site. The questions developed and loaded into the SurveyMonkey tool for the HIT environmental scans are provided in Appendix B of this document. 2.5.7 Environmental Scan Analysis This section will examine methodology used for environmental scan analysis and contain environmental scan results .Include: survey Analysis and examination of survey results to assess current rates of EHR adoption in Oklahoma for Medicaid and non- Medicaid providers; Pros and Cons of capabilities and functionalities currently in place in Oklahoma, and Identified Interoperability Opportunities and Barriers. OHCA’s environmental scans collected primary source data directly from providers and were administered in April/May 2010. The scans were conducted with current contracted SoonerCare providers only; non-SoonerCare providers will be scanned as part of the State’s HIE effort. OHCA does not currently provide or have statewide use of EHRs. IHS facilities were included in the scan; it is assumed that IHS facilities have access to the EHR capabilities in the RPMS, the federal system that supports IHS health functions. The State Veterans Affairs (VA) facilities were not included in the scan, but it is presumed that these facilities are supported by the Veterans Health Information Systems and Technology Architecture (VistA), an enterprise-wide information system built around an EHR and used nationwide in the VA medical system. State of Oklahoma Oklahoma Health Care Authority State Medicaid HIT Plan (SMHP) July 26, 2010 Page 41 Each scan includes questions that cover potential eligibility (provider type, patient volume); whether the respondent currently has any EHR/EMR components in place (and if so, vendors used, functions available); meaningful use capabilities currently in place; any current connections to an exchange network; and interest in program participation. The data collected provides some information on vendors and products utilized but a limited amount of information on capabilities for each. Scan data was collected and consolidated into an Excel format and was analyzed via Excel and Access. Responses to the follow-up surveys for EPs, IHS, and FQHCs/RHCS to date have been much lower than expected; OHCA will keep these surveys open and continue to collect data but these statistics are not included in the SMHP at this time. Survey Oklahoma’s SoonerCare providers are in various stages of automation, with larger, more urban organizations generally more automated than smaller, rural practices. Mid-sized organizations, such as FQHCs/RHCs and provider groups are in various stages of using, adopti |
Date created | 2011-07-07 |
Date modified | 2011-07-07 |