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2014 Annual Conference
Engaging the IPA Physician
Jessica Kwon, Pharm.D.
2014 Annual
Conference
ABC Physician Association IPA
100,000 patients, 18,000 senior lives
1,000 independent physicians 180 PCPs
90% PCPs are exclusive
10 year history of EMR strategy 75% of patients are on EMR
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Conference
HCC Department Resources
Varied Resources• 5 coders
• Clinical RAF Educator
• 2 Home Visit Coordinators
• 1 Clerical
• Data Analytics
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Then and Now:
Irritated FrustratedConfused Silent Disengaged Disdain
Engaged EducatedQuestions IdeasInput Experts
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RAF Score Increase
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
2008 Score 2009 Score 2010 Score 2011 Score
14%
Audit Scores: 2009: 69%2010: 78%2011: 84%2012: 91%2013: 92%
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The IPA Physician
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OpportunitiesCharacteristic Opportunities
Self-motivated Identify what motivates them
Entrepreneur Engage them in providing own solutions and be innovative
Competitive Provide numbers and data
Individualized workflows Provide support that will be flexible for the physician to adopt into their own office
Fairly engaged Get information to them accurately and timely
Resistant to change Provide habits and workflows that optimize RAF and become second nature
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Challenges
Not enough time
This is a game – it is not clinical and does not improve care
Patients don’t come in
I need tools
My office staff is the problem
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Build a Reputation Physicians trust is our greatest asset
“Trust is like a eraser. It gets smaller and smaller after every mistake.”
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EngagementIdentify what motivates them
Give them a platform to provide input
Provide support but Teach to Fish
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MotivationClinical Value Population
management Continuity of care Financial resources
Incentives Specific actions Consistent and clear Providers have direct
control
Reports and Data Negative Lists Scorecards
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Motivation: Incentives
Examples Chronic Condition Recapture
See Senior Panel Before Deadline
Increase PCP Clinical RAF Score (improvement)
Program Components Spaced throughout year
Audit Adjusted
Consistent
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Motivation: Reports and Data
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Chronic Codes Not Captured
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Seniors Not Seen
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2013 Mid-Year Scorecards
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Engagement: Physician Input
Provide clinical input on gray area codes
Gives program feedback
Provide ideas on incentives
Become “HCC Advocates” among physicians
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Engagement: Teach to Fish
More Consistent Scores
Build on Previous Years
More Efficient
Better Documentation and Fewer Missed Opportunities = Increased Revenue
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Engagement: Support
Enhance EMR to “make it easy”
Provide solutions
• Home Visit Program
Mentorship Programs
• Physician Mentorship
• Hospitalist/Coder Feedback
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Master PCP LYNTY
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Key Learning'sMake it easy
Make it relevant
Make it worth their while
“Already know you that which you need” -- Yoda
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HPMS Memos / HCC RerunsBottom Line Implications
----------RADV
R U Prepared?
Prepared by:Karen Bach
Pam Klugman
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HPMS MEMOsCMS Communications – HPMS Memo
Health Plan Management System (HPMS)
Plan Guidance
Manual Chapters
Our Focus: Risk Adjustment Related
• 2014 Risk Score Reruns for Purposes of Payment Recovery (March 25, 2014)
Payment Years impacted: 2006-2009, 2012
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Purpose: All deletions of diagnoses for these payment years are able to be submitted in the Risk Adjustment Processing System (RAPS) at this time. • CMS will sweep diagnoses submitted for a prior
payment year as of the deadline (communicated by CMS).
• MA Organizations should look to the monthly payment letters to determine when adjustments will be applied to payments.
2014 Risk Score Reruns
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What we know ….
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CMS is in the process of rerunning risk scores during calendar year 2014 for the following payment years:• 2006, 2007, 2008, 2009, 2012
2014 Payments Months affected:• March, July, August, October
Deletes only• New codes not accepted
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May be precursor to the overpayment collection rules inside ACA
Reruns for deletes will include all FFS information
EDPS training – insights gained
• Unpredictable bottom line impact
CPT drives Fee for Service (FFS) submissions
FFS overlays diagnosis information
• Your risk is proportional to the new members coming from FFS during those years
Why is this happening?
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Transition to next topic
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Risk Adjustment Data Validation
While you can’t plan which charts CMS will select, you can prepare….
RADV – Are you Ready?
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CMS conducts Medicare Advantage (MA) risk adjustment data validation activities for the purpose of ensuring the accuracy and integrity of risk adjustment data and MA risk adjusted payments.
Risk adjustment data validation (RADV) is the process of verifying that diagnosis codes submitted for payment by an MA organization are supported by medical record documentation for an enrollee.
What is RADV
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READINESS SCALERegret ReviewAgony AssessDefeat DevelopVolatile Verify
Where do you want to be?
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PLAN PREPARE PROSPER
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Project Manage
• CMS Selects Plan for Audit
• Determine best record (Provider, Inpatient)
• Communicate to impacted providers
• Create process for handling receipt
• Medical Record Review
• Report on findings
• Appeal process
Major components of audit process
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HOW TO SELECT
Project Management
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Follow CMS sampling selection criteria
Refer to Notice of Final Payment Error Calculation Methodology for Part C Medicare Advantage Risk Adjustment Data Validation Contract-Level Audits (http://www.cms.gov/Medicare/Medicare-Advantage/Plan-Payment/PaymentValidation.html)
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First, CMS identifies all beneficiaries under each MA contract who are “RADV-eligible” because they meet the following criteria:
Enrolled in an MA contract in January of the payment year
Continuously enrolled from January of the data collection year through January of the payment year;
Sampling Method
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Non-End Stage Renal Disease (non-ESRD) status
Non-hospice status
Enrolled in Medicare Part B coverage for all 12 months during the data collection year
Had at least one risk adjustment diagnosis (ICD-9-CM code) that led to at least one CMS-Hierarchical Condition Category (HCC) assignment for the payment year.
Sampling Method
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Section of up to 201 enrollees for medical record review
Divide into three equal groups• 1st – highest risk scores
• 3rd – lowest risk scores
• 2nd – the rest of them
Sample Size and Strata
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Random select 67 from each group
The corresponding stratum-based enrollee weights will be computed as the number of RADV-eligible enrollees in the population grouping (or stratum) divided by the number of enrollees selected from that grouping for the sample, i.e., Nh/nh, where h represents the corresponding stratum.
Sample Size and Strata
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Treat the RADV process as a project
• Project Manager, project team (risk adjustment team, clinical)
• Certified coders, staff with HCC experience, Medical Directors
Conduct Mock Audits and/or Targeted Audits
Review / train on CMS Requirements at least annually
Review CMS Sampling methodology for eligibility
Conclusion - PLAN
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Ongoing provider education ‘snippets’ in newsletters or provider communications
• Importance of proper and accurate documentation
• Medical record must support HCC
Identify IT resources and software (PDF reader/professional)
Ensure document retrieval options are viable (paper, fax, electronic)
Conclusion - PLAN
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Manage the Process and Flow
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Identify Providers
Request Records, Call Providers and Send Letters
Record Retrieval
Image and Index in system
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Manage the Process and Flow
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Review Records
Follow Up Requests (2nd and
3rd)
Determine Best
Record
Submit Record to
CMS (Secure)
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While you can’t plan for which charts CMS will select, you can prepare by performing an internal mock audit using CMS methodology.
Last thought….
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Adjustment Analytics: Measuring Illness Burden to Optimize Health Plan Payment
Presented by: Richard Lieberman
Mile High Healthcare Analytics, LLC
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You need to understand how risk adjustment models identify and quantify member illness burden
You want to learn how health insurance issuers need to incorporate risk adjustment into their care delivery systems
You need to appreciate the similarities and differences between risk adjustment approaches used by different insurance sponsors
You want to predict how issuer and member behavior will change because of the ACA’s reliance on risk adjustment
A compare and contrast of the various revenue optimization strategies would be peachy!
WHY ARE YOU HERE?
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Because, I have been actively involved in the development of risk adjustment systems for over 20 years
• Johns Hopkins ACG Development Team, 1991-2005
• Designed the risk-adjusted payment system for Maryland Medicaid
• Worked with CMS on development of the Medicare risk adjuster
One of the nation's leading experts on financial modeling, risk adjustment, and quality measurement in the managed care industry
I combine a unique array of expertise in provider profiling, risk adjustment, case-mix measurement, and provider reimbursement strategies
WHY AM I HERE?
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Prior to the 2004 advent of risk adjustment in Medicare-Advantage risk adjuster, health plans cherry-picked healthier-than-average members
The limited deployment of risk adjustment in Medicaid managed care prevented expansion of Medicaid managed care to higher risk populations
Community-rating in small-group/individual products requires risk adjustment
Risk adjustment provides a limited-response to the, “my patients are sicker” retort
THE PURPOSE OF RISK ADJUSTMENT
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According to the Society of Thoracic Surgeons, as of 2014, “…A relatively new term being discussed among those in the health care field is "risk adjustment.“ (http://www.sts.org/patient-information/what-risk-adjustment, accessed on 10/11/2014)
The B-52’s SAID IT BEST!
• Certain state Medicaid programs starting using risk adjustment in 1997
• Medicare implemented risk adjustment in 2004
• Commercial issuers in the small-group and individual markets are subject to risk adjustment beginning in 2014
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Risk adjustment models organize diagnosis codes, and sometimes prescription drug claims, into discrete categories• Relatively homogenous with respect to cost
and utilization
• Category groupings need to be clinically meaningful to minimize opportunities for gaming or discretionary coding
• Condition categories should have adequate sample sizes
RISK ADJUSTMENT MODELS
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Understanding the risk adjustment model is only the beginning
The risk adjustment methodology incorporates
• The risk adjustment model
• Define how the payment weights are constructed
• Calculation of plan average actuarial risk
• Risk adjustment data collection approach
• The schedule for the risk adjustment program
• Payment integrity provisions
RISK ADJUSTMENT MODEL vs. METHODOLOGY
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Sponsors that have adopted risk adjustment have designed their methodologies very differently:
• Medicare Advantage: Assigns risk scores to individual members and pays for each member individually; prospective model is used
• Health Benefit Exchanges: Will pay at the plan level, with no payment lag; a concurrent model is used
• Medicaid: Most states pay at the plan level with a multi-year lag; others for each member individually; a mixture of prospective and concurrent models are used
Currently 24 states use risk adjustment in their Medicaid programs
• Dual-Eligible Financial Alignment “Demonstrations”
Typically parallel Medicare and Medicaid risk adjustment schemes
Medicaid risk adjustment is typically rating categories: institutional vs. LTSS
DESIGN VARIATIONS BY LINE OF BUSINESS
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Both Medicare and Commercial issuers are subject to a single risk adjustment model (models have enrollment-sensitive variations)
Medicaid states that use risk adjustment, have selected from a variety of different models• Most Medicaid states use Chronic Illness and Disability and Payment
System, CDPS (http://cdps.ucsd.edu/)
• The Johns Hopkins ACGs are used by three states
• Arizona uses the Episode Risk Groups (ERGs), derived from Episode Treatment Groups. The ERG model assigns each member to one or more of the 167 ERGs based on diagnostic and procedural information available on medical and pharmacy claims
• New York State uses the 3M CRGs (Clinical Risk Groups)
THE ARRAY OF RISK ADJUSTMENT MODELS
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Some analysts argue that prescription drug claims represent actual treatment; diagnosis codes are subject to reporting bias• But prescription drugs fail to capture treatment not accomplished with
drugs, e.g., chronic renal failure
Diagnosis-based risk adjustment sometimes engenders perverse responses by health plans and risk-bearing entities
The explanatory power of prescription drugs alone is rarely better than diagnosis codes; Rx data doesn’t improve the explanatory power when combined with diagnosis code data
WHY DON’T WE RELY ON PHARMACY DATA?
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AGGREGATING DIAGNOSIS CODES FOR LINEAR MODELS
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AFFORDABLE CARE ACT VS. MEDICARE RISK ADJUSTMENT
Category ACA Risk Adjustment Medicare
Plan Benefits
Benefit tiers based on actuarialvalue; benefit structure varieswithin tiers
Plans provide, at a minimum, Medicarebenefits
Plan-level premiums
Can vary based on age,geography and family size of subscriber unit
Uniform plan premiums
Monetary basis fortransfers
Based on premiums seen in market Standardized bid
Transfer of funds
Charges assessed at issuer level;lower risk plans are charged andhigher risk issuers make payments after the benefit year
Prospective payment adjustments (up ordown) to individual standardized bid
Budget Budget-neutral Not budget-neutral
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RISK ADJUSTMENT IN THE HEALTH BENEFIT EXCHANGES
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AFFORDABLE CARE ACT VS. MEDICAID
Category ACA Risk Adjustment Medicaid
Plan BenefitsBenefit tiers based on actuarial value; benefit structure varies within tiers.
Plans provide, at a minimum, federally or state-mandated benefits
Plan-level premiums
Premiums paid by enrollees can varybased on age, tobacco use, geographyand family size.
Premiums paid to plans typically vary by eligibility category, age, gender, and geographic area
Model estimation ConcurrentProspective or concurrent (more states use concurrent)
Lag Period None Typically 1 – 2 years
Transfer of funds
Charges assessed at issuer level; lower risk plans are charged and higher risk issuers makepayments after the benefit year.
Prospective adjustment for relative risk based on historical plan-level average; a few states employ individual level risk adjustment
Budget Budget-neutral Budget-neutral
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RISK ADJUSTMENT DATA FLOW (MEDICARE & MEDICAID)
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Risk Adjustment Administrator (CMS or
State Medicaid)Pharmacy Data
Medical Claim Data
Eligibility Data
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RISK ADJUSTMENT DATA FLOW (EXCHANGES)
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Risk Adjustment Administrator (Exchange)
Issuers’ Edge Server
Pharmacy Data
Medical Claim Data
Eligibility DataDe-identified Risk AssessmentScores/Prevalence Data
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De-identified data: do the XML files going to the EDGE server accurately represent the utilization documented in the data warehouse?
Risk score calculation is very tightly tied to enrollment status
• Metal level (5 different models, with 4 models blended together)
• Cost-Sharing Reduction (CSR) status
• Diagnosis codes must occur within the enrollment window
Diagnosis code acceptance for risk adjustment is tied to paid claims
COMPLEXITY OF EXCHANGE DATA FLOW
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BASIC FORM OF THE PAYMENT TRANSFER CALCULATION
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ZERO-SUM TRANSFER AT THE ISSUER LEVEL
Plan 1Average risk score = 0.9
Exchange Plan 2Average risk score = 1.1
Average pmpm premium = $400Plan A pays Plan B: $40 pmpm
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Data files processed by the EDGE servers by December 5th
Intends to generate issuer-specific risk scores in December
No state-wide average risk scores will be generated
Many issuers are still struggling with EDGE server provisioning yet
No one has visibility into the payment transfer formula
Zero-sum financial settlement of risk-adjusted 2014 premiums is slated for June 2015
A comprehensive audit regimen begins in 2015, plans must select an auditor by early 2015
Open enrollment began in November 2015; how will that go?
Most states have significant new issuer entrants; increased competition
CONCERNS OF EXCHANGE ISSUERS
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Quality measurement and reporting requirements begin next year
• Initial year (2015) is a beta test
Many issuers are eager to pursue revenue management strategies, but have been consumed by program implementation tasks
The impact of the “transitional policy” phase-outs and the “private option” Medicaid expansions vary by state
MORE CONCERNS…..
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There is some actuarial evidence that the profits lie in the sicker than average enrollees, not the healthier-than-average ones
• ACA risk adjustment may turn much of the predictions about age distribution among enrollees on its head
• Relatively few diseases in the model; very large coefficients
• Issuers are concerned about the financial viability of the bronze products
WHAT IS DIFFERENT ABOUT COMMERCIAL RISK ADJUSTMENT?
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There is also substantial evidence that many morbidities in this population are not represented by diagnosis codes transmitted by paid claims and these members do not have valid office visits during the risk assessment year
• Several “targeting runs” for in-home assessments reveal that up to half of all risk score augmentation requires bringing the members into care
WHAT ELSE IS DIFFERENT ABOUT COMMERCIAL RISK ADJUSTMENT?
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In-home assessments may be valuable for selected members, but there is a greater need for bringing these members into treatment
If a member has significant morbidities, as evidenced by prescription drug use, clinical care needs to be deployed.
In-office health risk assessment programs are likely to be appropriate for the commercial population
REVENUE MANAGEMENT STRATEGIES FOR COMMERCIAL ISSUERS
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Most Medicare-Advantage plans have a very narrow view of risk adjustment
• They view it primarily as a way to increase revenue
In-home “health risk appraisals”
Retrospective medical record reviews
Very high probability that CMS policy will change in 2015
• CMS will be changing the rules around the provision of in-home assessments
Health plan concerns about the recalibration of models based on encounter data
MA PLAN RESPONSES TO RISK ADJUSTMENT
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Linking relative risk scores to the provision of health benefits
• If risk scores go up resulting from a data collection intervention, then there need to be clinical interventions associated with the increase
Using risk adjustment models to identify patients with particular co-morbidity vectors
CMS is now ready to calibrate risk adjustment models from encounter data, instead of Medicare fee-for-service data
Extracting data from electronic medical records
• Hampered by limited inoperability by EMR vendors
“NEXT GENERATION” RESPONSES
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CONTACT INFORMATION
Richard Lieberman
720-446-7785
www.healthcareanalytics.expert
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HCC Diagnosis ReconciliationsAre you sure everything is working?
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Our Journey
Supposed Path of a Diagnosis
Real-world Paths
HCC Reconciliations
Technical Processes
Business Processes
Key Points
Q&A
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Simple Path of a Diagnosis
Providers Send Claims
Health Plans Adjudicate Claims
Health Plans Transmit Diagnoses to CMS
CMS Stores the Diagnoses
CMS Calculates Risk Scores
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Simple path of a diagnosis
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More than Providers, Health Plans & CMS
Lots of Systems, Not Just Claims
Data Quality
Data Transfers
Encounter Filtering
Miracle
5010 837s
The Real Path of a Diagnosis
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Reality… a subway system
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Reconciliations
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Missing Diagnoses
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The RAPS Record
HICN… the Member ID
Provider Type… IP, OP and Prof
From Date & Thru Dates
Diagnosis Code
New, Home Code
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Business Knowledge
Data Quality
Systems Come in all Flavors
People… Business & Technical
Data Transfers
Flawed Filtering Logic
Differing Opinions
Common Problems
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Acquisition
Data Discovery
Encounter Filtering
Reconciliation Granularity
Venn Diagram, SQL OUTER JOIN
Audit Reports
837s Solution
Technical Processes
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Internal Data Acquisition… and Discovery
External Data Acquisition… and Discovery
External Acquisitions Issues
Internal Resources
Commitment from the Top
Business Understanding
Encounter Acquisition
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Data Distributions
Encounter Counts for Focus
Comes in all Flavors
Decimals
Member IDs
More to come on this
Data Discovery
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Inpatient, Outpatient and Professional
Under vs Over Filtering
Filtering Matching the Data
Institutional vs Professional Claims
Codes that Count
Provider Specialty
Federal Exchange Procedure Codes
Encounter Filtering
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Encounter Level
Member Diagnosis Level
Member HCC Level
Pros and Cons
No Choice
Reconciliation Granularity
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This is the easy part
Think Venn Diagram
Tools to Use
Outer Join & Granularity
What to do w/Fall Outs
Reconciliation
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Small Audit Samples
Tools to Generate
Provider Specialty
Paid Date
Provider
Audit Tools & Processes
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Initial Contact w/Business Unit
Business Units Stretched
Listen, Ask to Show You
Beauty of Routine
Patterns
Findings… All Kinds
Getting Business Involved
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Finding the Right Person
Small, Solid Examples
Make Routine
Technical vs Business Involvement
Finding Solutions
Finding Root Cause
Plan B
Health Plans & Submitters
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Things Break
Slow to Start, Takes Support of Leadership
Audit, Audit, Audit
Problems Everywhere
Small, Golden Examples
Make Routine
Key Points to Remember
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Q & A
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HCC Risk Adjustment Reimagined
Accuracy. Brought to You By Data Science
Overview
• HCC risk adjustment accuracy challenges
• The HCC risk adjustment process
• Can data science help?
• How to apply what we’ve learned
About Bob
Chief ScientistApixio
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Poll
Are you involved in:
A. Coding
B. MA risk adjustment
C. Commercial risk
D. Healthcare IT
E. Other?
Another Poll
Is your organization a:
A. Provider Group?
B. Plan/Payor?
C. Vendor?
D. Other?
HCC Is Challenging
CodingDocumentation
ACCURACY!
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The Risk Adjustment Process
Documentation Coding Submission
Documentation Gaps
What conditions does each member have?
Coding Gaps
Is each condition properly coded?
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Coding Errors
Is each code properly documented?
RAPS Gaps
Did CMS actually accept each code?
Accuracy at Scale?
DATA
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What Does a Plan Member Look Like To A Data Scientist?
Structured Data
Text
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Scanned Documents
How Can We Access ALL the Data?
Knowledge Graph
Knowledge Graph
Glucose
Hemoglobin
A1c
Retinal Eye
Exam
Echo
Diabetes
Type 1
Diabetes
Type 2
Glucose
A1c
Retin
al Eye Exam
Echo
Diab
etes Typ
e 1
ICD 250.xx
Knowledge Graph
Glucose
Hemoglobin
A1c
Retinal Eye
Exam
Echo
Diabetes
Type 1
Diabetes
Type 2
Glucose
A1c
Retin
al Eye Exam
Echo
Diab
etes Typ
e 1
ICD 250.xx
NLP & Machine Learning
Pattern Analysis
Flexible Ontology
Endocrine andmetabolic disorders
Endocrine andmetabolic disorders
DM w/o complication
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Endocrine & metabolic disorders
DM w/o complication
Encounter Note
Endocrine & metabolic disorders
DM w/o complication
Encounter Note
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Coding Gaps
Is each condition properly coded?
Manual chart audits…
Manual Chart Audit25,000 Medicare Advantage Lives
4 charts per hour = 3.1 coder‐years
10 coders will take almost 4 months
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A Study To Measure Accuracy
• 14 organizations• 2.1 million MA patient‐years• 2011‐2014 dates of service• 239,000 annotations
Study Procedure
Automate chart review
Validate all codes
Measure:• Efficiency• Accuracy• Documentation quality
Charts Per Hour
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UnderstandingChart Audit Accuracy
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Manual vs Automated
10 results!
Coder Performance
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High Error Rate Means High Audit Risk
X
Fast Coders are Accurate Coders!
Multiple Coding Reduces Error Rates
+
+
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Coders Disagree On Some HCCs More Than Others
Which HCCs Have Gaps?
Machine Learning Helps Close Documentation Gaps
What conditions does each member have?
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“Heart Failure”in EHR problem list
Is it Heart Failure?
Heart Failure No Heart Failure
… or Chart Failure?
Machine Learning
Heart failure
NOHeart failureM
easurement 1
Measurement 2
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Annotation Data Helps Close Documentation Gaps
What conditions does each member have?
Identify Key Areas For Improvement
Providers Struggle To Document These HCCs
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Provider Scorecard
Best Practices
• Use All Data Types• Automate HCC Identification• Measure Coder Accuracy• Tailor Education to Specific Gaps• Use Measure‐Based Incentives for Providers
The Old Risk Adjustment Process
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The NEW Risk Adjustment Process
Thanks, Data Science!
Thank you!
Bob [email protected]@scientistBob
Labs
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Lab Details
Tables
Claims
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Problem List
Progress Note
Discharge Summary
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Consult Letter
Text Mining Finds New Codes Even After A Manual Audit
% of accepted codes
HCC Category Description
How Long To Review Each HCC?
Confident Decision More Uncertainty
Time on page
% of documents (findings)
Distribution for HCC 19 (Diabetes)
Time on page
% of documents (findings)
Distribution for HCC 83 (Angina Pectoris)
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QA Oversight
Distribution of HCC Codes per Patient Among Patients with at Least One New Code
# of Codes per Patient with at Least One New Code
Distribution of New HCC Codes for PY2013 model Found from 2013 DOS
HCC Category Description
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Distribution of New HCC Codes for PY2014 model Found from 2013 DOS
HCC Category Description
What Are My Coders Doing?
What Are My Coders Doing?
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The Risk Adjustment Process
Documentation Coding RAPS