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People and processes: Planning health and human services IT systems modernization to improve outcomes

11.23.20

Read this if you are a director or manager at a Health and Human Services agency in charge of modernizing your state's Health and Human Services systems. 

When states start to look at outdated Health and Human Services systems like Eligibility Systems or Medicaid Enterprise Systems, they spend a lot of time on strategic planning efforts and addressing technology deficiencies that set the direction for their agencies. While they pay a lot of attention to the technology aspects of the work, they often overlook others. Here are three to pay attention to: 

  1. Business process improvement
  2. Organization development
  3. Organizational change management

Including these important steps in strategic planning often improves the likelihood of an implementation of Health and Human Service systems that provide the fully intended value or benefit to the citizen they help serve. When planning major system improvements, agencies need to have the courage to ask other critical questions that, when answered, will help guarantee greater success upon implementation of modernized system.

Don’t forget, it’s not only about new technology—it’s about gaining efficiencies in your business processes, structuring your organization in a manner that supports business process improvements, and helping the people in your organization and external stakeholders accept change.  

Business process improvement 

When thinking about improving business processes, a major consideration is to identify what processes can be improved to save time and money, and deliver services to those in need faster. When organizations experience inefficiencies in their business processes, more often than not the underlying processes and systems are at fault, not the people. Determining which processes require improvement can be challenging. However, analyzing your business processes is a key factor in strategic planning, understanding the challenges in existing processes and their underlying causes, and developing solutions to eliminate or mitigate those causes are essential to business process improvement.

Once you pinpoint areas of process improvement, you can move forward with reviewing your organization, classifying needs for potential organization development, and begin developing requirements for the change your organization needs.

Organization development

An ideal organizational structure fully aligns with the mission, vision, values, goals, and strategy of an organization. One question to ask when considering the need for organization development is, “What does your organization need to look like to support your state’s to-be vision?” Answering this question can provide a roadmap that helps you achieve:

  1. Improved outcomes for vulnerable populations, such as those receiving Medicaid, TANF, SNAP, or other Health and Human Services benefits 
  2. Positive impacts on social determinants of health in the state
  3. Significant cost savings through a more leveraged workforce and consolidated offices with related fixed expenses—and turning focus to organizational change management

Organization development does not stop at reviewing an organization’s structure. It should include reviewing job design, cultural changes, training systems, team design, and human resource systems. Organizational change is inherent in organization development, which involves integration of a change management strategy. When working through organization development, consideration of the need for organizational change should be included in both resource development and as part of the cultural shift.

Organizational change management

Diverging from the norm can be an intimidating prospect for many people. Within your organization, you likely have diverse team members who have different perspectives about change. Some team members will be willing to accept change easily, some will see the positive outcomes from change, but have reservations about learning a new way of approaching their jobs, and there will be others who are completely resistant to change. 

Successful organizational change management happens by allowing team members to understand why the organization needs to change. Leaders can help staff gain this understanding by explaining the urgency for change that might include:

  • Aging technology: Outdated systems sometimes have difficulty transmitting data or completing simple automated tasks.
  • Outdated processes: “Because we’ve always done it this way” is a red flag, and a good reason to examine processes and possibly help alleviate stressors created by day-to-day tasks. It might also allow your organization to take care of some vital projects that had been neglected because before there wasn’t time to address them as a result of outdated processes taking longer than necessary.
  • Barriers to efficiency: Duplicative processes caused by lack of communication between departments within the organization, refusal to change, or lack of training can all lead to less efficiency.

To help remove stakeholder resistance to change and increase excitement (and adoption) around new initiatives, you must make constant communication and training an integral component of your strategic plan. 

Investing in business process improvement, organization development, and organizational change management will help your state obtain the intended value and benefits from technology investments and most importantly, better serve citizens in need. 

Does your organization have interest in learning more about how to help obtain the fully intended value and benefits from your technology investments? Contact our Health and Human Services consulting team to talk about how you can incorporate business process improvement, organization development, and organizational change management activities into your strategic planning efforts.

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Related Professionals

Erica Rice as a Senior Consultant and Prosci®-certified Change Practitioner (CCP) in BerryDunn's Government Consulting Group currently supporting State Medicaid Agencies. She offers clients demonstrated expertise in the areas of organizational development; organizational change management; MITA State Self-Assessments (SS-A), and CMS certification of Medicaid Enterprise systems.

Erica helps State Medicaid agencies with MITA SS-As, certification, organizational development, and organization change management, vendor assessments, and RFP development.
 

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Erica Rice

Read this if your agency is planning to procure a services vendor.

In our previous article, we looked at three primary areas we, or a potential vendor, consider when responding to a request for services. In this follow-up, we look at additional factors that influence the decision-making process on whether a potential vendor decides to respond to a request for services.

  • Relationship with this state/entity―Is this a state or client that we have worked with before? Do we understand their business and their needs?

    A continuing relationship allows us to understand the client’s culture and enables us to perform effectively and efficiently. By establishing a good relationship, we can assure the client that we can perform the services as outlined and at a fair cost.
  • Terms and conditions, performance bonds, or service level agreements―Are any of these items unacceptable? If there are concerns, can we request exceptions or negotiate with the state?

    When we review a request for services our legal and executive teams assess the risk of agreeing to the state’s terms and compare them against our existing contract language. States might consider requesting vendors provide exceptions to terms and conditions in their bid response to open the door for negotiations. Not allowing exceptions can result in vendors assuming that all terms are non-negotiable and may limit the amount of vendor bid responses received or increase the cost of the proposal.

    The inclusion of well-defined service level agreements (SLAs) in requests for proposals (RFPs) can be an effective way to manage resulting contracts. However, SLAs with undefined or punitive performance standards, compliance calculations, and remedies can also cause a vendor to consider whether to submit a bid response.

    RFPs for states that require performance bonds may result in significantly fewer proposals submitted, as the cost of a performance bond may make the total cost of the project too high to be successfully completed. If not required by law that vendors obtain performance bonds, states may want to explore other effective contractual protections that are more impactful than performance bonds, such as SLAs, warranties, and acceptance criteria.
  • Mandatory requirements―Are we able to meet the mandatory requirements? Does the cost of meeting these requirements keep us in a competitive range?

    Understanding the dichotomy between mandatory requirements and terms and conditions can be challenging, because in essence, mandatory requirements are non-negotiable terms and conditions. A state may consider organizing mandatory requirements into categories (e.g., system requirements, project requirements, state and federal regulations). This can help potential vendors determine whether all of the mandatory requirements are truly non-negotiable. Typically, vendors are prepared to meet all regulatory requirements, but not necessarily all project requirements.
  • Onsite/offsite requirements―Can we meet the onsite/offsite requirements? Do we already have nearby resources available? Are any location requirements negotiable?

    Onsite/offsite requirements have a direct impact on the project cost. Factors include accessibility of the onsite location, frequency of required onsite participation, and what positions/roles are required to be onsite or local. These requirements can make the resource pool much smaller when RFPs require staff to be located in the state office or require full-time onsite presence. And as a result, we may decide not to respond to the RFP.

    If the state specifies an onsite presence for general positions (e.g., project managers and business analysts), but is more flexible on onsite requirements for technical niche roles, the state may receive more responses to their request for services and/or more qualified consultants.
  • Due date of the proposal―Do we have the available proposal staff and subject matter experts to complete a quality proposal in the time given?

    We consider several factors when looking at the due date, including scope, the amount of work necessary to complete a quality response, and the proposal’s due date. A proposal with a very short due date that requires significant work presents a challenge and may result in less quality responses received.
  • Vendor available staffing―Do we have qualified staff available for this project? Do we need to work with subcontractors to get a complete team?

    We evaluate when the work is scheduled to begin to ensure we have the ability to provide qualified staff and obtain agreements with subcontractors. Overly strict qualifications that narrow the pool of qualified staff can affect whether we are able to respond. A state might consider whether key staff really needs a specific certification or skill or, instead, the proven ability to do the required work.

    For example, technical staff may not have worked on this particular type of project, but on a similar one with easily transferable skills. We have several long-term relationships with our subcontractors and find they can be an integral part of the services we propose. If carefully managed and vetted, we feel subcontractors can be an added value for the states.
  • Required certifications (e.g., Project Management Professional® (PMP®), Cybersecurity and Infrastructure Security Agency (CISA) certification)―Does our staff have the required certifications that are needed to complete this project?

    Many projects requests require specific certifications. On a small project, maybe other certifications can help ensure that we have the skills required for a successful project. Smaller vendors, particularly, might not have PMP®-certified staff and so may be prohibited from proposing on a project that they could perform with high quality.
  • Project timeline―Is the timeline to complete the project reasonable and is our staff available during the timeframe needed for each position for the length of the project?

    A realistic and reasonable timeline is critical for the success of a project. This is a factor we consider as we identify any clear or potential risks. A qualified vendor will not provide a proposal response to an unrealistic project timeline, without requesting either to negotiate the contract or requesting a change order later in the project. If the timeline is unrealistic, the state also runs the risk that the vendor will create many change requests, leading to a higher cost.

Other things we consider when responding to a request for services include: is there a reasonable published budget, what are the minority/women-owned business (M/WBE) requirements, and are these new services that we are interested in and do they fit within our company's overall business objectives?

Every vendor may have their own checklist and/or process that they go through before making a decision to propose on new services. We are aware that states and their agencies want a wide-variety of high-quality responses from which to choose. Understanding the key areas that a proposer evaluates may help states provide requirements that lead to more high-quality and better value proposals. If you would like to learn more about our process, or have specific questions, please contact the Medicaid Consulting team.

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What vendors want: Other factors that influence vendors when considering responding to a request for services

Read this if your agency is planning to procure a services vendor. 

Every published request for services aims to acquire the highest-quality services for the best value. Requests may be as simple as an email to a qualified vendor list or as formal as a request for proposal (RFP) published on a state’s procurement website. However big or small the request, upon receiving it, we, or a potential vendor, triages it using the following primary criteria:

  1. Scope of services―Are these services or solutions we can provide? If we can’t provide the entire scope of services, do we have partners that can?
    As a potential responding vendor, we review the scope of services to see if it is clearly defined and provides enough detail to help us make a decision to pursue the proposal. Part of this review is to check if there are specific requests for products or solutions, and if the requests are for products or solutions that we provide or that we can easily procure to support the scope of work. 
  2. Qualifications―What are the requirements and can we meet them?
    We verify that we can supply proofs of concept to validate experience and qualification requirements. We check to see if the requirements and required services/solutions are clearly defined and we confirm that we have the proof of experience to show the client. Strict or inflexible requirements may mean a new vendor is unable to propose new and innovative services and may not be the right fit.
  3. Value―Is this a service request that we can add value to? Will it provide fair compensation?
    We look to see if we can perform the services or provide the solution at a rate that meets the client’s budget. Sometimes, depending upon the scope of services, we can provide services at a rate typically lower than our competitors. Or, conversely, though we can perform the scope of services, the software/hardware we would have to purchase might make our cost lower in value to the client than a well-positioned competitor.

An answer of “no” on any of the above questions typically means that we will pass on responding to the opportunity. 

The above questions are primary considerations. There are other factors when we consider an opportunity, such as where the work is located in comparison to our available resources and if there is an incumbent vendor with a solid and successful history. We will consider these and other factors in our next article. If you would like to learn more about our process, or have specific questions, please contact the Medicaid Consulting team.
 

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What vendors want: Vendor decision process in answering requests for services

Read this if your agency is involved with COVID-19 vaccination distribution.

Although states have already created COVID-19 vaccination plans, your state can still implement critical strategies to improve your distribution plan. In October 2020, the Centers for Disease Control (CDC) released the Interim Playbook version 2.0, providing a key framework for states and jurisdictions to build their COVID-19 vaccine distribution plans. The federal government asked that immunization programs in each state plans based on this model. The Playbook contains 15 sections of planning elements for states to consider in the development of their plan. Completing a plan of this extent while simultaneously trying to manage the pandemic has led some states to leave out or not thoroughly address critical components in their plans. 

The Kaiser Family Foundation (KFF) analyzed and collected common themes from each of the 47 state vaccination plans. Their analysis identified areas of weakness in the following areas of each plan: 

  • Priority populations for vaccinations in states 
  • Identifying networks of providers 
  • Developing data collection and reporting
  • Forming communication strategies

Each of the four areas each contained multiple findings, but since the vaccine has already started to roll out, some aspects of the plan cannot be revised. However, it is not too late to improve upon certain elements, especially for data collection and reporting, as well as communication strategies. 

The following recommendations for improvement of state plans are based on the findings from the KFF State COVID-19 vaccine distribution analysis report

States should identify a clear data reporting and collection plan that accounts for the COVID-19-specific data requirements.

According to KFF, an immunization registry or database has been included in 53% of the state COVID-19 plans; in the others it was an unclear component of the plan. The data collection process for COVID-19 vaccinations will be complex and unique due to a number of factors including the nature of a phased rollout, new provider enrollment and onboarding, storage requirements, multiple vaccines and doses, and off-site vaccination locations

Since a little over half of all states have arranged for either new systems or are developing or adding features to current immunization registries, states that are lacking a comprehensive approach could benefit from adopting elements present in the other plans. For example, some states detail how their current immunization system is being utilized for the COVID-19 vaccine, in addition to upgrading certain features in order to meet the anticipated increase in demand. 

Other states have also described their transition to the Immunization Gateway, a centralized technical infrastructure sponsored by the CDC Immunization Information Systems Support Branch, and led by the US Department of Health and Human Services Office of the Chief Technology Officer. The Gateway is securely hosted through the Association of Public Health Laboratories (APHL). States can review the data collection and reporting sections of other states’ plans to gain a greater understanding of how their plan can be improved by describing data reporting and collection processes.   

States should address racial and ethnic disparities in vaccine distribution and acceptance through targeted and evidence-based communication strategies. 

The KFF analysis of state COVID-19 plans indicated about 49% of state plans include specific mention of racial or ethnic minority populations in regards to communication. Communication plans need to include targeted strategies as minority populations and people of color have shown greater hesitation in receiving the vaccine, even if it is free and determined safe by scientists and federal authorities. The virus has had a disproportionate impact on communities of color and minority populations, and a lack of communication to these populations may continue to enhance these disparate health outcomes.

One way to improve a communication plan by addressing racial or ethnic minority populations would be by incorporating the National Standards for Culturally and Linguistically Appropriate Services (CLAS), specifically the standards for Communication and Language Assistance:

  • Offer language assistance to individuals who have limited English proficiency and/or other communication needs, at no cost to them, to facilitate timely access to all health care and services
  • Inform all individuals of the availability of language assistance services clearly and in their preferred language, verbally and in writing
  • Ensure the competence of individuals providing language assistance, recognizing that the use of untrained individuals and/or minors as interpreters should be avoided
  • Provide easy-to-understand print and multimedia materials and signage in the languages commonly used by the populations in the service area

A communication plan that considers the racial and ethnic minority populations most vulnerable to adverse health outcomes and have shown a lack of trust in the scientific community would be advisable in order to combat disproportionate negative outcomes from the COVID-19 virus in the future. 

A COVID-19 vaccine distribution plan is an important aspect of each state’s strategy to control the spread of the virus. In order to lead to effective vaccine distribution, it is vital for the plans to thoroughly address data collection, reporting, and tracking. It is also important to consider implementing a communication plan that incorporates strategies to reach racial and ethnic minority groups who might have been disproportionality impacted by COVID-19 as a way to improve your state’s health equity approach to COVID-19 vaccination efforts. By implementing these considerations, your state’s COVID-19 vaccine distribution plan could become more effective in improving the health outcomes of your population. 

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Two ways states can improve their COVID-19 vaccination distribution plans

Read this if your facility or organization has received provider relief funds.

The rules over the use of the provider relief funds (PRF) have been in a constant state of flux since the funds started to show up in your bank accounts back in April. Here is a summary of where we are as of November 30, 2020 with allowable uses of the funds.
 
The most recent Post-Payment Notice of Reporting Requirements is dated November 2, 2020. In accordance with the notice, PRF may be used for two purposes:

  1. Healthcare-related expenses attributable to coronavirus that another source has not reimbursed and is not obligated to reimburse
  2. Lost revenue, up to the amount of the difference between 2019 and 2020 actual patient care revenue

The Department of Health and Human Services (HHS) has issued FAQs as recently as November 18, 2020.  The FAQs include the following clarifications on the allowable uses:

Healthcare related expenses attributable to the coronavirus

  1. PRF may be used for the marginal increased expenses or incremental expenses related to coronavirus.
  2. Expenses cannot be reimbursed by another source or another source cannot be obligated to reimburse the expense.
  3. Other sources include, but are not limited to, direct patient billing, commercial insurance, Medicare/Medicaid/Children’s Health Insurance Program (CHIP), or other funds received from the Federal Emergency Management Agency (FEMA), the Provider Relief Fund COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured, and the Small Business Administration (SBA) and Department of Treasury’s Paycheck Protection Program (PPP). This would also include any state and federal grants received as a result of the coronavirus.
  4. Providers should apply reasonable assumptions when estimating the portion of costs that are reimbursed from other sources.
  5. The examples in the FAQs for increased cost of an office visit and patient billing seem to point to only supplemental coronavirus related reimbursement needing to be offset against the increased expense.
  6. PRF may be used for the full cost of equipment or facility projects if the purchase was directly related to preventing, preparing for and responding to the coronavirus; however, if you claim the full cost, you cannot also claim the depreciation for any items capitalized.
  7. PRF cannot be used to pay salaries at a rate in excess of Executive Level II which is currently set at $197,300.

Lost revenues attributable to the coronavirus

  1. Lost revenues attributable to coronavirus are calculated based upon a calendar year comparison of 2019 to 2020 actual revenue/net charges from patient care (prior to netting with expenses).
  2. Any unexpended PRF at 12/31/20 is then eligible for use through June 30, 2021 and calculated lost revenues in 2021 are compared to January to June 2019.
  3. Reported patient care revenue is net of uncollectible patient service revenue recognized as bad debts and includes 340B contract pharmacy revenue.
  4. This comparison is cumulative, for example, if your net income improves in Q4, it will reduce lost revenues from Q2.
  5. Retroactive cost report settlements or other payments received that are not related to care provided in 2019 or 2020 can be excluded from the calculation.

Whether you are tracking expenses or lost revenues, the accounting treatment for both is to be consistent with your normal basis of accounting (cash or accrual).
 
As a reminder, the first reporting period (through December 31, 2020) is due February 15, 2021. The reporting portal is supposed to open January 15, 2021. Any unexpended PRF at December 31, 2020 can be used from January 1, 2021 through June 30, 2021, with final reporting due July 31, 2021.

The guidance continues to change rapidly and new FAQs are issued each week. Please check back here for any updates, or contact Mary Dowes for more information.

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Provider relief funds: Allowable uses 

Read this if you have a responsibility for acquiring and implementing victim notifications for your jurisdiction.

In the first article of this three-part series we explored the challenges and risks associated with utilizing multiple victim notification systems across your state, while the second focused on exploring what the choices are to address these challenges. In this final installment, we demystify the process of developing requirements for a victim notification system. Here are some things to address when developing requirements:

  • Considering all of your victim notification stakeholders and their specific needs
  • “Mining” requirements from your current victim notification system to ensure that your current needs are met in the future system 
  • Determining what the market can support (and what it can’t)
  • Utilizing standards to increase the likelihood that market solutions, designed based on these standards, will meet the needs of your jurisdiction 

Understanding the needs (and wants) of your stakeholder group is critical to defining a successful set of requirements that meets your specific needs. Representative stakeholders may include:

  • Victim advocacy groups (both government run and private sector)
  • Police and sheriff departments
  • Department of Corrections 
  • The courts
  • Probation department
  • Prosecutor offices
  • The victims themselves

Of course the stakeholder group in your jurisdiction may differ, and the needs of these groups will also differ. For example, victims and advocacy groups are concerned about ease of use, accuracy, and timeliness of notifications. Police and sheriff departments may be concerned about ensuring they are meeting their statutory and moral obligations to notify the victims when offenders are released from custody. 

Since these groups have varied needs, it’s important to engage them early and throughout the requirements development process. Talk to them, observe their practices, and review their current systems. It’s possible, for example, that it’s important that sheriff departments can integrate their jail management system to the replacement victim notification system and the integration creates a seamless and timeline notification process when an offender is processed out of jail and into the community. Because the Department of Corrections is designed to hold offenders for a longer period of time, the department may require that their offender management system triggers an alert to victims when pre-release planning activities begin.

Scaling victim notification systems

Utilization of victim notification systems can also include a broad spectrum; from a single jail engaging with a victim notification system vendor to provide specific notification services, to a statewide victim notification system that provides these services for the larger stakeholder group. Because of this, your requirements must reflect that “scale.” Consider the utilization of the system before developing your requirements so that you don’t over (or under) engineer the system for your jurisdiction.

As mentioned in the second article in this series, there are many victim notification system options to consider, from home-grown applications to turnkey software as a service (SaaS) services. Regardless of the path you choose, consider leveraging the victim notification system standards as defined by the Department of Justice (DOJ) Bureau of Justice Assistance (BJA SAVIN Guidelines). These guidelines and standards are terrific sources for victim notification system requirements, and can be thought-provoking as you engage your stakeholder groups. 

Though these standards are extremely useful, be sure to identify and include any jurisdiction-specific needs in your set of requirements. They may be driven by state statutes or by local policy or process. In defining your unique requirements, just ask, “Why are they important? Were they defined based on processes put in place because you don’t have a strong victim notification system, or are they critical to satisfying statute or policy?”

Stakeholder communication and engagement

Once you develop a preliminary set of requirements, it’s important to meet with the stakeholder groups to refine and prioritize the requirements. This exercise will result in a clear and concise set of requirements that are understandable by victim notification system vendors that may be responding to the resulting solicitation. When defining the requirements themselves, we find it useful to follow the guidelines from the Institute of Electrical and Electronics Engineers, Inc. (IEEE) called “IEEE Recommended Practice for Software Requirements Specifications.” According to the IEEE standard, good software and hardware requirements should be: 

  1. Correct
  2. Unambiguous
  3. Complete
  4. Consistent
  5. Ranked for importance
  6. Verifiable
  7. Modifiable
  8. Traceable

Prioritization of the requirements also helps responding vendors understand which requirements are most important to your jurisdiction. This prioritization model can also be used when scoring the vendors’ responses to the requirements once proposals have been received. 

Conclusion

In summary, it is important your victim notification system requirements reflect the needs of your stakeholders, are realistic, and clear. Vendors will be asked to respond to how they can accommodate the requirements, so using the IEEE method described above can be useful. 

Though this article doesn’t dive deeply into the development of the request for proposals (RFP) for the victim notification system, below are some actions to take to improve your chances for a successful system selection project:

  1. Define a meaningful project scope to scale the vendor market
  2. Assign a balanced evaluation committee with impartial scoring criteria
  3. Craft a structured procurement package that attracts multiple vendors
  4. Design a reasonable and achievable RFP schedule of events
  5. Reduce ambiguity and increasing clarity of RFP terms

If you have questions about your specific situation, please contact our Justice & Public Safety consulting team. We’re here to help. The BerryDunn team has developed a mature methodology for determining victim notification system requirements, and has a rich repository of requirements to start with so that you don’t need to start from scratch.
 

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Victim notification system requirements: It's easier (and harder) than you think

Read this if you are a state Medicaid agency (SMA) or managed care organization (MCO).

Value-based care (VBC) can help stabilize healthcare revenues during times of unexpected challenges and market volatility. Implementing or solidifying value-based payment (VBP) or purchasing arrangements between payers and providers is one pathway to stabilizing provider revenues, especially during the era of COVID-19.

On September 15, 2020, the Centers for Medicare & Medicaid Services (CMS) released a letter to state Medicaid directors (SMDs) on how states can advance VBC across healthcare systems. Earlier in 2020, the CMS Administrator indicated that value-based or capitated payments can help promote provider resiliency, allowing providers to focus on quality of care as opposed to increasing utilization for short-term reimbursement gains. 

Promoting the adoption of VBC in Medicaid managed care is a long-term strategy to create stable and predictable revenues for providers, and potentially critical to successfully react to market disruptions caused by COVID-19. Providers are encouraged or obligated to see patients to drive quality outcomes, receiving VBPs or capitation that shifts revenue streams away from traditional fee-for-service models. VBP arrangements focus on quality of care, and can promote beneficiary health while reducing total costs.

A roadmap to advancing VBP in Medicaid

As healthcare costs continue to increase, states, payers, and providers have started transitioning to VBC to reimburse services based upon particular conditions (e.g., diabetes), Episodes of Care (EOC) (e.g., pregnancy and delivery), or different population healthcare needs (e.g., immunizations and well-child visits). VBP arrangements can incentivize the delivery of healthcare innovations that prioritize care coordination and quality outcomes over volume of services rendered, and help to avoid waste and duplication of services. VBP seeks to incentivize providers based on performance, and can result in shared savings for both providers and healthcare payers.

While many states have made significant progress moving towards VBP arrangements in their Medicaid managed care programs, data from the Health Care Payment Learning and Action Network (HCP-LAN) indicates there is still opportunity for improvement. In 2018, 90% of Medicare payments were made through a VBP arrangement, yet only 34% of Medicaid payments were made through VBP.  

Through its recent guidance, CMS provides a roadmap, strategies, and alternative payment methodology frameworks for states and health plans to implement successful VBP models in collaboration with the provider community. Key considerations for successful VBP implementation include:

  • Defining level and scope of financial risk, and developing associated performance benchmarks
  • Selecting established quality metrics that incentivize provider performance without undue administrative burden
  • Encouraging multi-payer participation (e.g., Medicaid managed care, Medicare, commercial health plans) to align provider incentives across payers and delivery systems
  • Advancing Health Information Technology (HIT) capabilities across providers and delivery systems
  • Assessing health plan and provider/delivery system readiness
  • Promoting stakeholder engagement and transparency
  • Developing VBC programs focusing on sustainability

Regarding HIT and the exchange of data between providers, MCOs, and SMAs, CMS recommends states take advantage of the Advanced Planning Document (APD) process to request 90/10 funding to address technology infrastructure needs associated to help implement a robust VBC program and help ensure delivery system readiness. Facilitating data sharing and promoting real-time and reliable data transactions between payers and providers engaged in VBC is critical to measurement, monitoring, and programmatic success. Additionally, SMAs can leverage VBP arrangements to focus on areas of waste in the healthcare system, including care delivery, and care coordination. 

If you would like more information or have questions about VBC and guidance on assessing, developing or implementing changes to your managed care program, please contact us. We also offer services related to value-based payment, as detailed here. We’re here to help.

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Value-based care to increase provider and delivery system resiliency

Read this if you have a responsibility for acquiring and implementing victim notifications for your jurisdiction.

In the first article of this three-part series we explored the challenges and risks associated with utilizing multiple victim notification systems across your state. In this article we will explore what the choices are to address these challenges. 

System elements to consider

Many jurisdictions are under the impression that there are only one or two choices for victim notification systems. Though there are certainly market leaders in this space, you should select a system model that best meets your jurisdiction’s profile. The profile may include some of these elements:

  • Risk aversion (i.e., How risk averse is your organization regarding system implementations?)
  • Budget (i.e., How will the initial project be funded? Does your jurisdiction prefer an annual subscription model, or a traditional perpetual license with annual maintenance and support fees?)
  • Staff (Who do you need to implement and maintain the operational system?)
  • Time (i.e., Are you already out of compliance with state statutes?)
  • Hosting environment (i.e., Do you want to host in the cloud or on premise?)
  • Victim notification reach (i.e., state-wide, single jurisdiction, multiple justice partners)
  • Victim notification policy and statute complexity
  • Data ownership (i.e., To what degree does your jurisdiction enable the selling of victim notification data outside of the jurisdiction?)

Victim notification solutions range from hosted commercial off the shelf (COTS) solutions, which are typically least expensive; to custom solutions developed to address jurisdiction-specific needs. The latter tend to be more expensive, riskier than turnkey solutions, and take longer to operationalize. However, if your jurisdiction has unique requirements for victim notification, this may be a viable option. Unless you plan to engage the development vendor in a long-term contract for maintenance of this type of system, you must consider the impact on your existing IT staff. “Platform” solutions are a hybrid of COTS and custom development. With these solutions, there is typically a platform (i.e., Customer Relationship Management or CRM) on which the victim notification system is developed. Using a platform de-risks the development of the application’s architecture, may be a slightly less costly approach, and may simplify the maintenance of a system that is addressing unique requirements.

You may also already have licenses for victim notification capabilities, and not even realize it. Some offender management systems (OMS), jail management systems (JMS), and even prosecution systems (that support victim advocacy functions) may have built-in victim notification functionality included for the licensing price you are currently paying, or may include the option to purchase an add-on module. 

Advantages of using victim notification capabilities packaged with an existing system may include:

  • Lower acquisition and maintenance costs
  • Tighter integration with the OMS, JMS, or prosecution system may result in more seamless utilization of offender and victim data
  • You have a single contract, with a single vendor, reducing contract management overhead

A likely disadvantage, however, is the victim notification functionality may not be a robust as a point solution, or custom-built system. Additionally, if the “reach” of the JMS is a single county, then victim notification capabilities built into your JMS may not suffice for statewide use. However, if the built-in functionality meets your needs, then this is certainly a viable path to consider.

As mentioned in the first article, regardless of your approach the integration between your victim notification system and the JMS, OMS, prosecution system, and court system is critical to reducing redundancy and increasing the timeliness with which both offender and victim data is entered into the victim notification system―and used to trigger the notifications themselves.

Determining the best option for your victim notification system

So how do you determine which choice is best for your jurisdiction? The first step is to determine your jurisdiction’s risk profile versus the need to for jurisdiction-specific functionality. 

Mature market-based solutions are typically less risky to implement, since multiple jurisdictions are likely successfully using them to support their victim notification operations. However, these solutions may not be customizable or flexible enough to address your specific needs. 

“Build” models (using platform solutions or other application development models) tend to be a bit more risky (as many “from scratch” development projects can be); however these are more likely to address your specific needs. Here are a few questions that you should ask before making a determination between a COTS solution and a custom-build:

  1. Do we really have jurisdiction-specific victim notification needs?
  2. Can a COTS solution meet the statutes and policies in our jurisdiction?
  3. How risk-averse is our jurisdiction?
  4. Do we have time to develop a customized solution?
  5. Do we have the talent and capacity to maintain a custom solution?

Budget considerations

The next step is to determine your budget. We recommend you assess a budget over a 10-year total cost of ownership. The cost of a traditional, perpetual license-based COTS solution, including initial acquisition and implementation, will be higher in the first few years of use, but the ongoing annual fees will be lower. The cost of a custom-build solution will be even higher in the first few years, but annual maintenance should drop off dramatically. The cost of a subscription-based COTS solution will be relative even year over year. However, if you model these costs over 10 years, you will have a reasonable sense for how these costs trend (i.e., the cost of a subscription-based model will likely be higher over 10 years than the perpetual license model). 

The other consideration is how you plan to fund the system. If there are capital funds in the budget for initial acquisition and implementation, this may benefit the perpetual license model more than the subscription-based model. Regardless of the funding approach, you will likely be using the selected victim notification method for a significant period of time, so don’t settle.

Finally, determine how to acquire the system (or systems integration vendor that will help you develop the system), which is the subject of the third article in our series.

If you have questions about your specific situation, please contact our Justice & Public Safety team. We’re here to help. To learn more about other choices in victim notification procedures and systems, stay tuned for our third article in this series where we explore the process (and pitfalls) of procuring a statewide victim notification system.

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Victim notification systems: What choice do you have?