rhp10txwaiver.comrhp10txwaiver.com/images/region_10_cat_3_ta_call_q… · web viewin order to...

Region 10 Category 3 Technical Assistance Call

Tuesday July 22, 2014 1:00 pm – 3:00 pm CST

In order to assist HHSC in the execution of the Category 3 technical assistance call, and to provide the most benefit to each of you and your questions, we ask that you submit as many of your questions as possible to the Anchor email [email protected] by 12:00 noon on Monday July 21st 2014 so we may compile them and provide them to the HHSC team prior to the call. After all pre-posed questions have been reviewed, we will open up the line for Q&A to all providers on the call. We will proceed in order of TPI number, which is the order you answer roll call on for other calls. Please utilize this template to submit questions prior to the call. Please add more question boxes as needed for your organization.

Not approved as currently described – does not mean it’s not approvable – it just means HHSC doesn’t understand it. This is a dialogue – not a demand. In most cases HHSC just needs you to connect the dots more which are the crux of the feedback. Goal – having measures finalized by August 15th – so providers can move forward with baselines and to have the data set up in the reporting system online.

General recommendation: These are recommendations only when it comes to additional measures that HHSC suggested. You are open to picking which ones you like, however, HHSC needs to understand why and needs you to provide extra support as to why you selected that. This will help CMS understand why you have selected the rates you did.

General recommendation: If you don’t have the data capacity to do measure certain outcomes or can’t for your project based on additional recommendations that HHSC has made in terms out outcome selection, let HHSC know why you aren’t able to do this.

Question 1:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 081599501 MHMR of Tarrant

County [email protected] 081599501.3.2(UPI: 081599501.2.1)

Cat 1,2 Project ID Category 3 Outcome Selected

Cat 1, 2 Project Area Cat 1,2 Project Setting

Highlight which area of feedback you have question(s) on: (could be

more than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther

Question: We have been recommended to switch from a patient satisfaction measure to a quality of life measure (the RAND SF-36 or SF-12) for our Detox program. Due to the late recommendation, we do not currently have a baseline on this measure. Can we collect a baseline between now and September 30th? We expect that we

mailto:[email protected]


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST could still collect data on at least 75-100 clients, but it would not be spread out over a 6 or 12 month.

Notes from HHSC Comments/ Responses:

Baseline reporting methodology which is going to be put out in the field in the next few weeks by HHSC.

HHSC does prefer that you do a 6 month reporting period – but please email the box on a case by case basis to see if you can use a proxy population to establish a baseline outside of your project.

Specific subject headline: Baseline for TA for Cat 3

Other option: shorter measurement periods, after other options are exhausted. Want a meaningful baseline to have goals for DY4-5. Won’t mandate you switch measures if this is the measure that works best for your projects.

There will be a triage list of options to go through first.

No follow up questions from MHMRTC.

Question 2:






more than 1)


Question: We have received this feedback from HHSC regarding one of our Category 3 measures for the identified project in the Subject line and need further clarification on the Dual Diagnosis language:

The selected measure (IT-6.2.a CSQ-8) may be an appropriate fit for the project, but is not the strongest. Provider should consider replacing the selected patient satisfaction measure with one that better reflects project goals. As IT-11.26.b is an appropriate fit for the project, provider should consider replacing current selection with IT-11.9 Care Planning for Dual Diagnosis, which will reflect care coordination services described in the project narrative.



In the measure specifications for IT-11.9, Dual Diagnosis is defined as individuals with a mental disorder and a substance abuse disorder. Our target population is identified as individuals with IDD or ASD and a co-occurring behavioral or medical problems. Behavioral problems being mental illness. We wanted to get further guidance from you all regarding the fit of the recommended measure for our target population. What we are considering dual diagnosis seems to be different than the measure specifications.


Yes the definition of co-morbid conditions is different from the measure HHSC suggested, and the measure HHSC suggested probably won’t work for them. Can keep the measure that they like.

Question 3:





Highlight which area of feedback you have question(s) on: (could

be more than 1)


Question: The recommended alternative measure, IT-11.8 Initiation and Engagement of Alcohol and Other Drug Dependence Treatment (SA, P4P) with an MHMR wide facility subset appears to be a good fit for our project since we are adding AOD services to Mental Health clinics. However, we were unclear about whether we could do this on all Dual Diagnosis (mental health and AOD) individuals across MHMR facilities or if we would need to include those who had only an AOD diagnosis and were not receiving mental health treatment (such as those receiving detox services only).

Could you please define MHMR wide facility subset further?

Also, is it possible or preferred to use this measure in place of the ANSA (P4R) measure selected previously, as we are having difficulty finding a Population Focused Priority measure that will


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST suit our project?


Both proposals would work – would be up to the provider to select.

Provider question: If DY5 QISMC is met in DY4 – how does that happen - you would only need to maintain the DY5 – for payment. In a qualitative standpoint HHSC would like to see more improvement of DY5 – but for payment purposes would only be held to the DY5 goal.

Question 4:

RHP TPI Provider Name Contact Email Category 3 Project ID

RHP 10 081599501 MHMR of Tarrant

County [email protected] Multiple Projects




more than 1)


Question:

Are the six measures listed for CMHC Priority Focused Population the only options we have for PFP? In some cases none of these measures matches our population or would not relate to our intervention. In other cases, we do not have a baseline available since the intervention has already begun. Could we make another category 3 measure focused on a priority focused population or are we limited to those six listed?

Notes from HHSC Comments/ Responses: No, there are a few cases where HHSC has seen BH providers

use primary care measures if it is something they can accomplish. If you cannot complete any of the PFP – you can complete a stretch activity. Just give a detailed explanation of why the stretch activity is a better fit and why the priority focused population measures won’t work.

Remember – that the population focused doesn’t have to specifically fit the project, but could focus on the provider as an overall organizational provider priority and not the specific Cat 1 or 2 projects.


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST Just need a nice clear explanation of why you selected the one you did.

Question 5:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 022817305 Tarrant County

Public [email protected]@tarrantcounty.com

HIE-022817305.3.1A.S.-022817305.3.19

Cat 1,2 Project ID Category 3 Outcome SelectedHIE-3022817305.1.1

Antenatal Steroid-3022817305.2.1HIE-5.1.aA.S.-8.12

Cat 1, 2 Project Area Cat 1,2 Project Settingmultiple / multiple

Highlight which area of feedback you have question(s) on: (could be more

than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther – Baseline period

Question: If the requested baseline period lies outside the allowable measurement periods, HHSC has stated they will work with provider to determine an appropriate historical baseline rate or potentially a proxy population for baseline determination. Therefore, are we not able to use a baseline period that extends 9/30/14, or will assistance be given on a “case-by-case” basis?


Would like to look at a 6 months baseline reporting period. HHSC will work with providers on a project by project population and looking at proxy populations or different baseline periods.

Question 6:






RHP 10

022817305Tarrant County Public Health

[email protected]@tarrantcounty.com

Chronic Dis. - 5.3.8Tobacco- 5.3.16

Fall Prev.-5.3.100PRIDE - 5.3.5

Cat 1,2 Project ID Category 3 Outcome Selected5.2.4, 5.2.8, 5.2.100, 5.2.2 10.1.h / 15.15

Cat 1, 2 Project Area Cat 1,2 Project SettingAmbulatory


than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther – other recommended OD measures in addition to selected approved measure

Question:

HHSC recommends that provider compliment a sole OD measure with an additional clinically based outcome or if the provider decides to retain the sole measure, provide sufficient justification. If we are retaining the sole measure, what type of response is requested? i.e. additional specific details of the project, such as setting, curriculum, etc. to demonstrate how it would not fit the other OD measures in general, or details why specific IT’s (or OD’s) were not selected?


In the cases where HHSC is recommending an OD-6 or OD-10 HHSC believes you will strengthen your Cat 3 selection, but if the provider believes that either of these is not sufficient or is not related to the project; give HHSC an understanding why it is not meaningful in your project.

If you are proposing a sole OD-6 or OD-10 outcome, just give HHSC a strong understanding of why these are the only options. Build up a strong rationale.

Question 7:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 130606006 Wise Regional

Health System [email protected]

Cat 1,2 Project ID Category 3 Outcome Selected130606006.2.1 IT-2.7

Cat 1, 2 Project Area Cat 1,2 Project SettingDesign evidence based interventions Outpatient Behavioral HealthHighlight which area of feedback you • Prior Authorization (if required)






have question(s) on: (could be more than 1)

• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther

Question:

During the selection process of Cat 3, it was stated that if a provider was unable to provide "risk adjusted" measures, then the provider could choose to report on the non-risk adjusted measure (P4R). Now it seems we are made to select a different outcome measure that is risk-adjusted. HHSC feedback asks the provider to justify why the measure selected is a better fit than the risk-adjusted measure. Fit is not a relevant consideration since the provider is not capable of measuring the "risk-adjusted" measure. . In other words...we stated we could not provide risk-adjusted measures when we submitted our new Cat 3 Template, now we are being asked to select them anyway. Please clarify.


• Approved for use with additional provider clarification- Response required.

OD-2 and OD-3 outcomes mostly; HHSC is not familiar with data reporting capacity and made assumption on capabilities based on provider types.

HHSC recommends that you provide the rationale that you don’t have certain data capacities based on yourself being a small provider. HHSC needs documentation that you don’t have risk adjustment capabilities – and that will take care of any prior authorization needed for outcomes that were P4R versus P4P.

Question 8:




RHP 10

130606006Wise Regional Health System [email protected]

130606006.3.7 and 130606006.3.108

Cat 1,2 Project ID Category 3 Outcome Selected130606006.1.2 and 130606006.2.101 IT-9.3a and IT-1.29

Cat 1, 2 Project Area Cat 1,2 Project SettingCare Transitions and Child Obesity Hospital and School-based


than 1)


Question:

For some of our category 3 measures, there was provider action requested due to the need to remove a facility denominator subset. On one measure it appears as though the measure was "not currently approved as described" for this reason, and on other measure the feedback was "approved for use with additional provider clarification". Both measures seemed to require response for similar reasons, but the HHSC feedback varied. Does this mean we only have to remove the facility subset and the outcome measures will be approved in both situations?

Can we propose to keep IT-9.3a by removing denominator facility subset?

Notes from HHSC Comments/ Responses: • Approved for use with additional provider clarification-

Response required.

Measure is not currently approved as described. Response required.

IT9.2 and IT9.3a – denominator population for these outcomes needs to be that population metro area. We cannot tailor these outcomes to a particular ED or facility – because it throws off the interpretation of the outcome or the data to be captured.

HHSC says to remove subset – and your denominator becomes the entire county population so you will need to have a substantial impact on the numerator to see change.

A subset that is allowed for this measure is the Medicaid population because there is data to show how many Medicaid enrollees in a certain area.




For providers who picked 9.2a and 9.3a – look at the ambulatory care sensitive conditions – gets more at the facility level for ED type measures.

Question 9:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 206106101 Wise Clinical Care

Associates [email protected]

Cat 1,2 Project ID Category 3 Outcome Selected206106101.1.100 IT-2.19

Cat 1, 2 Project Area Cat 1,2 Project SettingExpand Primary Care Clinic


than 1)


Question:

If an outcome measure is not currently approved, but the provider makes the changes or responds to comments on the other sections, will the outcome measure then be available for approval?


Measure is not currently approved as described. Response required.

You are able to speak to the points that HHSC brings up in areas of concern and help them understand the answers to their questions you can help them make this an approvable outcome.

Question 10:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 206106101 Wise Clinical Care

Associates [email protected]


Cat 1, 2 Project Area Cat 1,2 Project SettingClinic

Highlight which area of feedback you • Prior Authorization (if required)



have question(s) on: (could be more than 1)

• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther

Question:

I have another one that does not necessarily fit with a specific project but rather most of our projects. That is how can we risk-adjust our measures that are not risk-adjusted?The document provided on HHSC’s website on risk-adjusted does not apply to our outcome measures and the way we capture them according to our quality department and our coding and billing department.


Risk adjusted measures are already defined in OD-2 and OD-3. There are also non-risk adjusted compliment. As far as risk-adjusting measures, they are already defined by the measures you select.

HHSC is working to help provide some insight into risk adjusting and setting up a call with 3M. In many cases it is challenging to set up a risk-adjusting methodology if they don’t already have one.

If providers are interested in participating in the 3M call – send a message to the inbox – 3M risk adjusting conversation so that you are invited on the call. Call will likely be at the beginning of August.

Question 11:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 13891087 Dallas Children’s [email protected]




than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST • DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther

Question:

The projects in RHP 10 by Children’s Medical Center of Dallas are “mirror” projects of projects in RHP 9 just in different geography and smaller in scale (one primary care practice versus 14). We would like to use the same Category 3 measures we submitted in RHP 9 for the same projects in RHP 10. Will that be possible?


Yes, more than welcome to, since you are a provider in multiple regions. Even if you have projects in both, for RHP 10 projects, be sure that your populations are different based on the regions; just ensure that your denominators are different. Look at the populations and make sure the denominators are different based on geography.

Question 12:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 138980111 UNTHSC [email protected]




than 1)


Question:

With the recent process for plan modification, we are looking at changing our percentage mix of Medicaid/low-income, uninsured patients. How would we change our Category 3 subsets to reflect this? For example, if a project changed from 100% Medicaid to 50% Medicaid and 50% low-income, uninsured, how would the project change the Category 3 subset from “Medicaid” to “Both”? Where would be the appropriate place in the feedback workbook to notate this change?

Notes from HHSC Comments/



Responses:

Plan mod needs to be utilized to expand this population outside of the Category 3 feedback.

Be sure to add a note in the provider interpretation of the outcome be sure to add this as it doesn’t fit anywhere else in the template.

If you are picking a new measure, be sure to utilize the selection tool and let HHSC know in that box that you will be selecting a new outcome.

Question 13:





than 1)


Question:

If the overall percentage of the Medicaid/low-income, uninsured served remains the same, but the mix of the two changes, is a plan modification necessary? Would this instead be a technical change? For example, would a plan modification be necessary if a project went from serving 100% Medicaid to 50% Medicaid and 50% low-income, uninsured?


Question 14:





Tuesday July 22, 2014 1:00 pm – 3:00 pm CST Cat 1, 2 Project Area Cat 1,2 Project Setting


than 1)


Question:

It seems the target population in the spreadsheet cells is broader than our subsets. Is this accurate? If not, is the provider response section to HHSC’s understanding of the selected outcome the appropriate place to clarify the target population (include subset information for population)?


HHSC clarifying question: are you planning on modifying the target population.

Provider: wants to make sure they and HHSC are interpreting the population and subsets the same way.Project description – Cat 1/ 2 project on project summary (copy and paste exercise) – HHSC used this to help understand the context of the outcome selected for the project. This is how you defined the target population of the project.

Question 15:


RHP 10 138980111 UNTHSC [email protected]

138980111.3.202, 138980111.3.203, 138980111.3.204

Cat 1,2 Project ID Category 3 Outcome Selected138980111.2.5 IT-1.21, IT-1.23, IT-12.4

Cat 1, 2 Project Area Cat 1,2 Project Setting2.12.2 multiple


than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments



Tuesday July 22, 2014 1:00 pm – 3:00 pm CST • HHSC understanding of outcome selectedOther

Question:

HHSC noted in its Category 3 feedback that it is unclear why this care transitions project is using the above listed outcomes (BMI assessment, tobacco use and cessation, and Pneumonia Vaccinations) and not readmissions. These were chosen in response to the designation of our previous outcomes (30 day readmissions and patient fall rate) being designated as appropriate only for inpatient settings. We are a non-hospital provider and were instructed to change our readmission outcomes during the last round of changes. Is this the explanation HHSC is looking for?


Provide more data in feedback form and use readmission rates. And a strong justification as to why you went one way or the other.

If there is a reason other suggested outcomes don’t work for the provider, just let HHSC know.

Provider – already changed direction of the project based on previous feedback, which is one reason why they would like to keep the current options selected.

Question 16:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 112677302 THR FW [email protected]

Multiple

Cat 1,2 Project ID Category 3 Outcome Selected112677302.1.100112677302.2.100

IT-13.5, IT-5.2, IT-13.2IT-4.11, IT-5.2, IT-12.7

Cat 1, 2 Project Area Cat 1,2 Project SettingInpatient

Highlight which area of feedback you have question(s) on: (could

be more than 1)


Question: There is inherent problem with two of the projects/ Category 3 feedback for Texas Health Resources Fort Worth.

Throughout the 3-year project approval / feedback process, HHSC


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST required this provider to switch two of their project options, as the original workbook was loaded incorrectly.

Original Submission

Project Name

Correct/ Approved Submission

Project Name

112677302.1.100 WeeCare 112677302.2.100 WeeCare112677302.2.100 Cystic

Fibrosis112677302.1.100 Cystic

Fibrosis

The provider accomplished this through 3-year project approval process.

With Category 3 done on a separate track, it seems some of the information in the templates is correct, however not all of it is.

In the Category 3 feedback templates, the project names and options are correct, however HHSC reviewed and approved Category 3 milestones based on the wrong projects. So the feedback is mixed up. This seems to have been observed in light of 1 project, but not both.

Please help the provider understand how they should respond to feedback, as for the WeeCare project you reviewed the Cystic Fibrosis measures. For the Cystic Fibrosis project, the outcomes were approved, however they were outcomes selected for the WeeCare project.

It would seem that both of these 3-year projects need a re-review of the outcomes selected. The correct outcomes for each project should be:

Project Title Cat 3 outcomes112677302.2.100 WeeCare IT-13.5, IT-5.2, IT-

13.2112677302.1.100 Cystic Fibrosis IT-4.11, IT-5.2, IT-

12.7

If HHSC will not have the opportunity to re-review these outcomes/ projects prior to when providers must submit their Category 3 feedback, please advise on how you would like the provider to respond to feedback. Should they reselect new measures in the Selection workbook and basically start over?

Notes from HHSC Comments/ Responses: Jennifer should get an updated feedback form to THR FW – and do

a re-review and resend the feedback form. Look at other any


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST feedback needed and respond to this. Jennifer to send in as soon as the call is over.

Question 17:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 126675104 JPS Health Network

Cat 1,2 Project ID Category 3 Outcome Selected126675104.2.6 IT 1.8



than 1)

• Potential overlap or duplication of Category 1 or 2 project milestones

Question:

There was an identified potential overlap or duplication with a category 2 milestone P-103 Depression Screening at Integrated Locations and IT 1.8 Depression Screening with Treatment Plan Documented.

Both have similarities but are distinctly separate in what they are measuring. The category 2 milestone is measuring only if screening was conducted on the target population at the sites where we have integrated. The IT 1.8 outcome measures screening and treatment plan for all individuals seen by a PCP at a PCMH within the organization which is much broader than the intervention population

Would this still be considered overlap?


One of the measures is specific to the integrated care locations, the other location is broad to the whole network. Provider doesn’t see it as duplication since one is a small population and the other is large.

If provider can give an estimation of the 4 clinics versus the broad denominator. Help understand the difference between intervention population and broad denominator population.

Question 18:


RHP 10 126675104 JPS Health Network

Cat 1,2 Project ID Category 3 Outcome Selected126675104.2.104




Highlight which area of feedback you have question(s) on:

(could be more than 1)

• HHSC understanding of outcome selectedOther

Question:

The way the outcome currently reads leaves the outcome dependent on a patient survey response. We would like to be able to measure this through documentation and assessment data from a vocational rehabilitation specialist. Would this be acceptable? If yes, do we need to respond to the Cat 3 feedback with that or would this be considered synonymous?


HHSC would like to advocate that the patient report pieces are important. You can use chart review to narrow the people in the numerator down, but HHSC thinks it is still important to have the patient report. Could the patient fill out a report based on what they talked about today? Could help create more follow up with the patient

Most of the project is focused on homeless so we are going to help get the patient connected and engaged in a voc rehab program outside of the provider.

Will the patient get all of the services from the provider? Yes HHSC says to put a facility subset on this measure so it is abundantly clear that it is voc rehab at the provider. Visit type will be much cleaner – but moves away from the intention of the measure. Patient perception is the meaningful part of the measure.

Question – project likely to impact hundreds, not thousands. There will be a qualitative data piece that will be cumbersome. HHSC doesn’t know of a better measure for the project, and if at all possible would like to see a patient report. If provider finds that outside of the realm of possibility – can go back to the measure steward.

Question 19:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 126675104 JPS Health Network [email protected]

126675104.3.18

Cat 1,2 Project ID Category 3 Outcome Selected126675104.2.3 IT 9.2 ED ACSC Visits

Cat 1, 2 Project Area Cat 1,2 Project SettingCare Transitions


than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST • Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther

Question:

We are doing a project targeted on care transitions for homeless population. Our requested subset was for a clinic and outreach team which is located in the homeless shelter district. We expect by DY5 that the intervention population will comprise approximately 25% of the patients affiliated with the clinic and outreach.

Secondly, HHSC comments were that the clinic didn’t have an ED. While this is true, we had planned to report on the JPS Health Network ED utilization for those connected to the clinic in the shelter district. Given this background information related to the clinic subset, would this be an appropriate option for Category 3 subset?

As an additional option, we would like to consider “homeless” as a custom subset. Since March submission there has been integration developed between the EMR and the Homeless Management System which tracks social service and shelter utilization. This allows us to track homeless patients who have engaged anywhere in the JPS Health Network. We currently have 3080 patients flagged as “Possible homeless”. Our intervention population for this year is 500, thus making it 16% of the target population.

Our ideal subset would be to use the homeless status as we are able to measure this cohort more broadly.

Notes from HHSC Comments/ Responses: HHSC is concerned about an intervention only population.

Don’t want to limit to individuals that are part of the intervention.

Provider – only touching on a small subset of the actual homeless population – and not a direct overlap to the overall homeless population.

Facility subset – JPS emergency department.

Homeless could not be used as a facility subset – goes back to the notion of the intervention population. And that is not a true denominator subset. Should be able to get to the same end of just using the JPS ED.

Jennifer – no this is not ok to just use Cypress clinic population – one thing you could do would be to look at an ambulatory measure that is amendable to the facility – a1C at the cypress clinic. You would be doubling the denominator subset, but still believes.


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST 1) Stay with ED measure and keep JPS – use subsets for

uninsured – comorbid conditions, etc. Most gender of males. Wouldn’t just be cypress clinic but could get more down to a smaller population.

2) Ambulatory care sensitive conditions3) More ambulatory outcome in nature –

HHSC doesn’t know what subset you use to get to the HUD population. In the spirit of DSRIP – homelessness is more of a diagnosis of comorbid condition –

Jennifer and Dawn continued conversation after the formal call concluded. Dawn provided insight into the HUD data / file - for all who have accessed homeless services in the last 12 months. Provider – goal is to measure guys all the way through the system. Want to prevent the pattern of ED use.

Like using HUD population as a payer – would look less likely as an intervention population.

Possible approval in RHP 3, 6, 9, or 10 – have precedence of charity care as a payer. Could you detail the thought process to get to the data and suggest HUD as a payer subset.

Question 20:

RHP TPI Provider Name Contact Email Category 3 Project IDRHP 10 126675104 JPS Health Network [email protected]

P4P Risk Adjustment Methodology

Cat 1,2 Project ID Category 3 Outcome Selected126675104.2.17126675104.2.4126675104.2.5126675104.2.7

IT-4.11IT-3.3IT-3.1

IT-3.14Cat 1, 2 Project Area Cat 1,2 Project Setting


than 1)

• Prior Authorization (if required)• Phase 1 comments addressed (if applicable)• Setting• Fit of outcome to Category 1 or 2 project activities• Rationale provided for outcome selection• Potential overlap or duplication of Category 1 or 2 project milestones• Use of denominator subsets (if applicable)• DY4 and DY5 achievement levels• Response to provider's additional comments• HHSC understanding of outcome selectedOther – Clarification needed regarding “contingent on using a risk adjustment methodology”

Question:The Knowledge Management team has identified a potential risk adjustment methodology to support the projects listed



Tuesday July 22, 2014 1:00 pm – 3:00 pm CST above that have received feedback to utilize a risk adjusted model to measure pay for performance.

Is the risk adjusted model described in the attached word document an acceptable model?

The 3m model only accounts for about eighty percent of the criteria needed to identify and predict our expected readmission rate. The population we serve are high utilizers and typically have longer lengths of stay as most do not have insurance to cover after care services.

See below


Needs CMS stamp of approval as a model (another homegrown risk adjustment model) – aligned with DRG weighting. Seeing on the index admission and nothing elsewhere. This is on HHSC’s radar – and they are working on defining this methodology for providers so they don’t have to get new software.

Missing a piece on readmission reason – how can this be done meaningful to providers.

For all cause readmission – might be useful

Jennifer will send to me to send to the Region – to try and get there

For IT-3.2 – could use 3M? HHSC will send to CMS for approval. Jennifer will circulate to quality folks and send to CMS next week.

Risk adjusted readmission for BH – causes provider concern. HHSC knows this is tough -

After reviewing dozens of NQF, AHRQ, CMS, and HHSC documents that “mention” Risk Adjusted Readmissions, we have come to the conclusion that there is no “validated and accepted” Behavioral Health Risk Adjusted Readmission algorithm available for us to use.

However, I was able to find the following document from HHSC written specifically for the Texas DSRIP Category 3 Risk Adjustment questions, but it just discusses common models with no specifics.

https://www.hhsc.state.tx.us/1115-docs/CAT3/Cat3PPE_RiskDraft.pdf

They acknowledge that the 3M APR DRG Severity of Illness and Risk of Mortality categories are validated and commonly available (40% of hospitals in Texas have access to the 3M model). Hospitals can also combine a limited number of risk factors that have been shown to significantly increase risk of readmission into a RRF Score – Readmission Risk Factor Score.

The literature Donna and I reviewed most commonly listed the following readmission risk factors (RRF):

1. APR DRG Risk of Mortality (ROM)

https://www.hhsc.state.tx.us/1115-docs/CAT3/Cat3PPE_RiskDraft.pdf


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST 2. APR DRG Severity of Illness (SOI)3. Length of Stay greater than 3 standard deviations above the hospital average

LOS (LOS_3SD)4. High Utilization of ED and IP in 12 months (IP + ED Visits >= 10) (HUG_10)5. Age Greater than 64 years at admission (AGE_65)

So we could fairly easily use these 5 RRFs to calculate a Readmit Risk Score for each hospital inpatient visit as RRS = ROM + SOI + LOS_3SD + HUG_10 + AGE_65 with the following possible values for each of those variables:

ROM SOI LOS_3SD HUG_10 AGE_65

1: Low 1: Low 0: LOS < Avg LOS 0: IP + ED < 10 0: Age < 65

2: Medium 2: Medium + 3 Std. Dev. 1: IP + ED >= 10 1: Age >= 65

3: High 3: High 1: LOS >= Avg LOS

4: Very High 4: Very High + 3 Std. Dev.

Then we calculate the Average and Standard Deviation of the RRS for the entire population (Avg_RRS) in order to find the Average RRS + 3 standard deviations as the threshold breakpoint (RRS_3SD) for visits that are statistically different from the mean. Visits with RRS > RRS_3SD can then be considered “expected readmits” that get excluded from the risk adjusted readmission rate.

Example: If 100 denominator cases have an Avg_RRS of 5.16 with a standard deviation of 0.29 then:

AVG_RRS = 5.16, RRS_3SD = 5.16 + (3 * 0.29) = 6.03

Column A B C D E = C – D (min = 0)PAT_ENC_CSN_ID RRS READMIT_FLAG EXP_FLAG ADJUST_FLAGPatient 1 5 1 0 1Patient 2 6 1 1 0Patient 3 4 0 0 0Patient 4 9 0 1 0Patient 5 3 1 0 1Patient 6 7 1 1 0Patient 7 2 0 0 0Patient 8 4 1 0 1Patient 9 8 1 1 0Patient 10 6 0 1 0

5 cases of the 10 had RRS >= RRS_3SD (> 6) so they are flagged as Expected and excluded from Adjusted Rate.

Observed Readmit Rate = 6 / 10 = 60%, Adjusted Readmit Rate = 3 / 10 = 30%

JPS Question: Julie – removing one of her measures and replacing – needs help with selection tool. Removing one – adding another. Denominator subset – could you utilize JPS as the facility for patients discharged to a long term care setting. HHSC – go ahead and propose – JPS discharges to a long term care facility. Any patient discharged to LTC.


Tuesday July 22, 2014 1:00 pm – 3:00 pm CST JPS Question: Lori – Sepsis – doesn’t see link between Cat 1 and 2 project and selection of Cat 3 outcome. HHSC needs more detailed rationale for selection. How you want to improve, etc. as

to why it is the best fit for the project.

rhp10txwaiver.comrhp10txwaiver.com/images/region_10_cat_3_ta_call_q… · web viewin order to...

Documents