Common Credentialing Advisory Group Meeting August 2, 2017 1
Agenda • Welcome and Introductions • Implementation Update • CCAG Membership Update • Health Systems and Integrated Delivery Networks • Interface Update • Programmatic Updates • Upcoming Work 2
Implementation Update 3
Introductions • William (Billy) Morrissey, Director Civil and Health Organization • Elena Byrley, Senior Program Manager, Health Programs • George Webber, Project Manager 4
CC Implementation Team 5
Project Update • All subcontract negotiations completed on July 28 – 3 months longer than expected – Terms and conditions required additional scrutiny by subcontractor legal counsel • Evaluating a delay in Initial Operational Capability (IOC) because of subcontract execution delay (Targeting Q2 of 2018 instead of Q1) Actions from Peraton to get project back on track • Establish final Project Baseline (schedule) • Complete requirement elaboration with Medversant • Strengthen program management structure • Identify schedule and process efficiencies 6
CC Implementation Approach Warranty CC/SI Implementation Year 1 - Maintenance and Operations (M&O) Period Credentialing Operations Services, Help Desk Services Early General Availability General Availability Adopters Ramp-Up to 90% Participation Normal Operations UAT CC Initial Operational Capability ∆ ∆ CC Operational Go Live CC Operational Go Live/General CC/SI Implementation includes: Availability is targeted for Q3 of IOC is targeted • Requirements and workflow reviews 2018 for Q2 of 2018 • Development, integration, and configuration to meet OHA’s requirements • System, security, and performance IOC will focus on Early testing Adopters, a subset of • User Acceptance Testing (UAT) prior to Oregon Credentialing Initial Operational Capability (IOC) Organizations and Practitioners. 7
CCAG Membership Update 8
CCAG Membership Recommendations Resigning Member Replacement Representation Mary Pohlman Khen Lau, Credentialing Health System and Manager, Kaiser Permanente Integrated Delivery Network Ann Klinger Christa Shively, Senior Director Health System and of Quality and Medical Integrated Delivery Integration, Providence Health Network Plans Denal Everidge Ann Klinger, Director of Health System Medical Staff Services (OHSU) Shelley Sneed No Replacement (Ruby Jason Health Care to cover perspective) Regulatory Board Tooba Durrani Unknown (possible naturopath Alternative Medicine physician) Practitioner Note: All appointments are pending OHA director approval 9
Health Systems and Integrated Delivery Networks 10
Fee Model Development OHA worked with stakeholders on fee structure principles and on specific components of the OCCP fee structure whereby: • Practitioners pay a one-time application fee • Credentialing Organizations (COs) pay a one-time set up fee and annual subscription fees – Tiered fees for COs are based on practitioner panel size as a proxy for anticipated use of the system – Higher tiers reflect significant economies of scale discounts – Fully delegated practitioner counted only on panel of CO making decision – Health Systems that centralize decision-making count practitioners once 11
OCCP Fee Model Practitioner Fee: One-time initial application fee of $150 per practitioner Credentialing Organization Fees: Set-Up Fee Annual Fee Total Initial Fee Tier Practitioner Panel Size Fee Per CO Fee Per CO Per CO Tier 1 1-100 $10/practitioner $90/practitioner varies Tier 2 101-150 $1,010 $9,090 $10,100 Tier 3 151-250 $1,500 $13,500 $15,000 Tier 4 251-500 $2,500 $22,500 $25,000 Tier 5 501-750 $5,000 $40,000 $45,000 Tier 6 751-1,500 $7,200 $60,000 $67,200 Tier 7 1,501-2,500 $11,500 $85,000 $96,500 Tier 8 2,501-5,000 $14,500 $110,000 $124,500 Tier 9 5,001-7,500 $17,000 $125,000 $142,000 Tier 10 7,501-10,000 $19,500 $140,000 $159,500 Tier 11 10,001-15,000 $22,500 $165,000 $187,500 Tier 12 >15,000 $26,000 $195,000 $221,000 Expedited Credentialing Fee: Up to $100/practitioner assessed to COs that optionally request an initial credentialing application be expedited. 5 Note: Possibility to reduce fees once the OCCP is operational and additional users participate.
Treatment of Health Systems “Health System” an organization that delivers health care through financially owned hospitals, facilities, or clinics.* Questions Raised: 1. Should shared practitioners in a health system be “de- duplicated?” 2. Should integrated delivery networks** be discounted? * Current definition in OCCP proposed rules, which is being further assessed ** “Integrated delivery network” is tentatively defined as an organization that financially owns both a health system and a health plan. 13
Health System Issues Considerations OHA worked with stakeholders to assess issues: 1. Defining “health system” is complicated with no regulatory guidance 2. Health systems currently have some credentialing centralization 3. Generally, separate credentialing decisions are made at the CO level 4. Health systems want to be placed in a tier collectively 5. Health plans and hospitals governed by different accrediting bodies 6. Health system affiliations may shift over time 7. Integrated delivery networks* receive discounts in other programs 14
OHA Programmatic Fee Adjustments for Discussion with Stakeholders Adjustments Description Benefits Challenges Allow shared Practitioner • Acknowledges • Difficult to determine de- practitioners De-duplication sharing of duplicated practitioner across a health practitioners across panel sizes system to be systems • Inequalities due to fee counted only • Accounts for existing increases for other once centralization participants to ensure efficiencies revenue Provide a 15% Nominal • Acknowledges current • Complexity of defining discount to IDNs Discounts to centralization of and tracking health for both the IDNs (15%) businesses system and IDN health system • Incentivizes grater affiliations and hospital OCCP support from • Inequities due to fee IDNs increases for other participants to ensure revenue 15
De-Duplication Panel Size Example • Health System A owns 2 hospitals. – 200 practitioners are credentialed at Hospital 1 – 200 practitioners are credentialed at Hospital 2 • 100 practitioners are credentialed at both hospitals • Health System A’s “de-duplicated” panel size is 300 – Shared practitioners counted once, so there are 300 unique practitioners being credentialed by the health system 16
IDN Fee Discount Example • Organization A owns a health plan and a health system with 5 hospitals and 1 ASC – Health plan (HP) credentials 4,000 practitioners (tier 8) – Health system (HS) centrally credentials 1,000 unique (i.e., “de- duplicated”) practitioners (tier 6) Total Fees = (HP Tier 8*85%) + (HS Tier 6*85%) 17
Agreed Principles/Components Review Fee Structure Principles: Balanced, considering benefits and resources Efficient and economical to administer Transparent and justifiable in development Stable to ensure predictable income to support costs Fee Structure Components: Tiers based on practitioner panel size as a proxy for use Higher tiers reflect economies of scale discounts Fully delegated practitioners count only for the decision Health systems that centralize the decision count shared practitioners once 18
Feedback on adjustments? 19
Next Steps for fee adjustments Ove the next few months, OHA will be working to: • Obtain final feedback on fee adjustments • Assess health system definition impacts with the Department of Justice and stakeholders • Work with key stakeholders (those impacted, OHLC, and OAHHS) to obtain final feedback on preferred definition • Make a final decision and incorporate definition and fee adjustments into final program rules to be finalized by the end of September 2017* Note: There will be an opportunity for final review of final program rules by RAC, CCAG, and SMEs in September 2017 20
Interface Update 21
Business Need for an Interface Some credentialing organizations want to consume practitioner data from the OCCP system into their individual systems. Note: An interface to receive data directly is optional. All COs have the ability to access practitioner data from the OCCP system. Survey Findings: • COs need the ability to import bulk practitioner data into their own systems • COs need attachments (images) associated with each practitioner record and may need each attachment separate • Nightly frequency for posting data/attachments is acceptable • Most respondents only want to download new/changed data, but some expressed desire to receive the full data 22
What we know • Medversant supports SFTP and this will meet the requirement • Ample lead time is required – COs have internal procedures that must be followed when introducing these types of changes – COs require information (spec) in advance in order to secure funding and pursue changes with their vendors • These activities are built into the project schedule and will be communicated as soon as the schedule is baselined. • A technical SME group may be pulled together 23
Programmatic Updates 24
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