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electronic Submission of Medical Documentation (esMD) electronic Determination of Coverage (eDoC) Workgroup Oxygen Concentrators and Portable Oxygen (OCPO) User Story Launch September 24, 2014
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Sponsors & Support Pamela durbin, RN, BSN,CDS, ISSO
Mark D Pilley, MD AAFP, AADEP, ABQAURP Medical Director Strategic Health Solutions, LLC Viet Nguyen, MD Chief Medical Information Officer Systems Made Simple, Inc. Sweta Ladwa, MPH Project Manager / Epidemiology ESAC, Inc. Pamela durbin, RN, BSN,CDS, ISSO Health Insurance Specialist, COR II CMS / OFM / Provider Compliance Group Dan Kalwa Health Insurance Specialist, CMS / OESS Michael Handrigan, MD Medical Officer CMS / OFM / Provider Compliance Group Robert Dieterle, Initiative Coordinator 2
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Agenda / Presenter Opening Remarks S&I Process
Overview of eDoC Workgroup Related Initiatives Description of Oxygen User Story Structured Data Mapping Oxygen to eDoC and Other Initiatives Timeline and Summary Closing Remarks Robert dieterle Mark Pilley, MD SWETA LADWA, MPH Robert dieterle 3
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Standards & Interoperability (S&I) Framework
“…a collaborative community of participants from the public and private sectors who are focused on providing the tools, services and guidance to facilitate the functional exchange of health information.” Why use the S&I Framework? It is a robust, repeatable process that will help improve interoperability and adoption of standards and health information technology. Standards & Interoperability (S&I) Framework is “…a collaborative community of participants from the public and private sectors who are focused on providing the tools, services and guidance to facilitate the functional exchange of health information.”
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Solution Development Lifecycle
eDoC Phase Details Charter Challenge statement Timelines and milestones Goals and outcomes Use Case Create Use Case and User Stories Actors and roles Activity and Sequence diagrams Dataset Requirements Risks, Issues and obstacles Sub-workgroup effort Structured data requirements Templates for data capture Decision support Standards Harmonization Identify candidate standards Create data model(s) Map data model(s) to candidate standard(s) Identify gaps, barriers and obstacles Work with SDOs to address gaps The Solution Development Lifecycle of electronic Determination of Coverage (eDoC) under the S&I Initiative is completed over multiple Phases: Pre-Discovery began with establishing a “Charter” containing a “Challenge statement, Timelines & milestone, Goals & outcomes” Discovery involves “Use Case” development, Creating the Use Case & User Stories, Actors and roles, Activity and Sequence diagrams, Minimal Dataset Requirements, Risks, Issues and obstacles, supported by Sub-workgroup effort in defining Structured data requirements, developing Templates for data capture, & providing Decision support Implementation requires Standards & Harmonization of those Standards. This starts with Identifying candidate standards, Creating a data model(s), Mapping the data model(s) to candidate standard(s), Identifying gaps, barriers and obstacles, & Work with Standard Development Organization s (SDOs) to address gaps. Next is the Implementation Guidance and Piloting Phases. This requires the Creation of an Implementation Guide(s), Identifying pilot participants, Developing pilot / demonstration plan, followed by Evaluating for success & making Modifications to the Implementation guide(s) as required. Implementation Guidance & Piloting Create implementation guide(s) Identify pilot participants Develop pilot / demonstration plan Evaluate success Modify Implementation guide(s) as required 5
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Related S&I Framework Initiatives
Description Relationship Transitions of Care (C-CDA) Defines the electronic communication and data elements necessary for clinical information exchange to support transfers of care between providers and between providers and patients Standards for the exchange of clinical information Provider Directories Defines transaction requirements and core data sets needed to support queries to provider directories to enable electronic health information exchange Electronic endpoints for participants in eDoC Structured Data Capture (SDC) External template driven capture of structured data within the EHR Templates and workflow to capture payer required information Health decisions (HeD) Decision Support to enable complex workflows based on externally provided rules that enable capture of information and provide guidance for physician ordering Decision support for data capture and preferred order management esMD Author of Record Standards for providing digital signatures to transactions and documentation. Standards for Digital Signatures on transaction and documents Direct a simple, secure, scalable, standards-based way for participants to send authenticated, encrypted health information Utilize Direct as a transport mechanism between providers, payers and suppliers Data Provenance (DPROV) Standards for the provenance of medical record information that is exchanged for clinical or administrative purposes Provides more detailed information regarding the origin and assembly of data elements in an electronic exchange 6
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eDoC Workgroup Structure
Charter Use Case Harmonization Pilots Sub-Workgroups User Stories Power Mobility Devices Lower Limb Prostheses Home Health Services Oxygen Concentrators and Portable Oxygen Structured Data Determine documentation requirements Evaluate appropriate clinical elements Clinical Vocabularies Define CCDA template Documentation Templates Define template requirements Define template workflow Define EHR data capture requirements Specify storage requirements Transport ASC X12 275, 278, 277 CONNECT Direct At this time there are 4 active & ongoing eDoC Sub-Workgroups User Stories, Structured Data, Documentation Templates, & Transport. There are 3 current User Stories - Power Mobility Devices, Lower Limb Prostheses, Home Health Services The Structured Data SWG - Charged with Determining documentation requirements, Evaluate appropriate clinical elements & Clinical Vocabularies, & further Define CCDA Documentation Templates SWG – Charged with Defining template requirements, Defining template workflow, Defining EHR data capture requirements, Specify storage requirement Transport SWG – Determining the IG for exchange of Medical Documentation, Structured Documentation using specific Transport systems: ASC X12, 275, 278, & 277; Direct, & CONNECT. The esMD Initiative is developing Implementation Guides based on current acceptable Documentation Standards, HL7, supporting structured Medical Documentation, Consolidated CDA allowing for Structured Data Capture in support of electronic Determination of Coverage. Consolidated CDA Structured Data Capture esMD eDoC IGs 7
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esMD Background Phase 1: Phase 2: Before esMD: Provider 8 electronic
Healthcare payers frequently request that providers submit additional medical documentation to support a specific claim(s). Until recently, this has been an entirely paper process and has proven to be burdensome due to the time, resources, and cost to support a paper system. Review Contractor Provider Request Letter Paper Medical Record Phase 1: Doc’n Request Letter electronic Phase I of esMD was implemented in September of It enabled Providers to send Medical Documentation electronically The ONC S&I Framework Electronic Submission of Medical Documentation (esMD) initiative is developing solutions to support an entirely electronic documentation request. electronic Phase 2: 8
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esMD Process Flow The overall esMD process can be divided into three steps: A provider registers with a payer to receive electronic medical documentation requests (eMDRs) 1. Register to Receive eMDRs A payer sends an eMDR to a registered provider 2. Send eMDRs A provider electronically sends medical documentation to a payer in response to an eMDR 3. Send Medical Documentation esMD Phase 2 esMD Phase 1 9
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Electronic Determination of Coverage (eDoC)
Underlying Challenge: Enable provider capture of documentation and benefit determination based on payer rules Secure exchange of templates, decision support, and documentation between payers, providers, service suppliers and beneficiary Scope: Focus on defining the use case, user stories and requirements supporting a standards-based architecture Reuse of existing S&I Initiative efforts where possible Creation of structured data capture templates and supporting exchange standards General approach to documentation as the Use Case Specific benefits as user stories (Oxygen Concentrators and Portable Oxygen (OCPO) Outcome: Successful pilot of templates, decision support, information exchange standards over standard secure transactions for the purpose of determining coverage Validation of user story for Oxygen Concentrators and Portable Oxygen (OCPO) 10
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eDoC General Workflow Patient LCMP / IDTF Physician Specialist /
Service Provider Templates and Rules Payer 11
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Oxygen Concentrator / Portable Oxygen (OCPO)
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Improper Payment - OCPO
Highest Medicare Improper Payment for Service Types Billed to DME – Oxygen Supplies/Equipment $1.2 Billion – 75.2% (CERT Improper Payments, 2013) No Documentation – 0.3% Insufficient Documentation Errors – 73.2% Oxygen Concentrators (E1390) - $1 Billion – 75.6% Overpayment Rate Claims Containing Errors – 68.1% (Medicare FFS 2013 Improper Payment Rate Report – Supplementary Appendices ) 2006 Office of Inspector General (OIG) Report “Medicare Home Oxygen Equipment: Cost and Servicing” 2004 – Home Oxygen Equipment 24% of all Medicare DME, Prosthetics, Orthotics and Supplies (DMEPOS) Costs $2.7 Billion of $11.1 Billion total payments for DMEPOS 1. Medicare and Medicaid issue billions of dollars in improper payments every year. These are not fraudulent situations, but rather cases where the health care provider unintentionally fails to comply with the Medicare and Medicaid coverage, coding on Medicare and Medicaid coverage, coding the medical recasting(?) rules. 2. CMS hires Review Contractors to help find improper payments. Nurses and other clinicians at the review contractors look for these improper payments by comparing the claim to the medical documentation created by the provider of the time of service. 3. Hospitals, Physician Offices and other providers receive many requests for patient’s medical records every year from Medicare and Medicaid Review Contractors.
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OCPO Definition E1390 E1391 PORTABLE OXYGEN CONCENTRATOR, RENTAL E1392
OXYGEN CONCENTRATOR, SINGLE DELIVERY PORT, CAPABLE OF DELIVERING 85 PERCENT OR GREATER OXYGEN CONCENTRATION AT THE PRESCRIBED FLOW RATE E1390 OXYGEN CONCENTRATOR, DUAL DELIVERY PORT, CAPABLE OF DELIVERING 85 PERCENT OR GREATER OXYGEN CONCENTRATION AT THE PRESCRIBED FLOW RATE, EACH E1391 PORTABLE OXYGEN CONCENTRATOR, RENTAL E1392 PORTABLE GASEOUS OXYGEN SYSTEM, RENTAL; HOME COMPRESSOR USED TO FILL PORTABLE OXYGEN CYLINDERS; INCLUDES PORTABLE CONTAINERS, REGULATOR, FLOWMETER, HUMIDIFIER, CANNULA OR MASK, AND TUBING K0738 14
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OCPO Reviews OCPO Reviews require Suppliers to submit:
Evidence of qualifying test results Performed within 30 days before initial date of service (DOS) Evidence of in-person visit with a treating physician Detailed written order NCD – Home Use of Oxygen (240.2) Coverage requires patient testing when in the “Chronic Stable State” All Co-Existing “Diseases or Conditions that can cause hypoxia must be treated sufficiently.” Patient “Must have a severe lung disease”:e.g.; “COPD, diffuse interstitial lung disease, cystic fibrosis, bronchiectasis, widespread pulmonary neoplasm, or hypoxia-related symptoms or findings anticipated to be improved with Oxygen Therapy.” 15
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OCPO Reviews OCPO Reviews require Suppliers to submit:
Certificate of Medical Necessity (CMN) Completed, signed, and dated by the treating physician May act as a substitute for detailed written order CMS Form 484 (DME form ) Proof of Delivery Any other medical documentation to support the LCD requirements 16
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OCPO – Order Requirements
OCPO – Detailed Written Order (DWO) Detailed Written Order The detailed written order must include: Patient name; Detailed description of the items being provided, including: a. The means of oxygen delivery, b. The specifics of varying oxygen flow rates and/or non-continuous use of oxygen, and c. The length of need; Treating physician’s signature and date order signed; and Start date of the order (only required if the start date is different from the signature date) . 17
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OCPO Definition PORTABLE GASEOUS OXYGEN SYSTEM, RENTAL; INCLUDES PORTABLE CONTAINER, REGULATOR, FLOWMETER, HUMIDIFIER, CANNULA OR MASK, AND TUBING E0431 PORTABLE LIQUID OXYGEN SYSTEM, RENTAL; HOME LIQUEFIER USED TO FILL PORTABLE LIQUID OXYGEN CONTAINERS, INCLUDES PORTABLE CONTAINERS, REGULATOR, FLOWMETER, HUMIDIFIER, CANNULA OR MASK AND TUBING, WITH OR WITHOUT SUPPLY RESERVOIR AND CONTENTS GAUGE E0433 PORTABLE LIQUID OXYGEN SYSTEM, RENTAL; INCLUDES PORTABLE CONTAINER, SUPPLY RESERVOIR, HUMIDIFIER, FLOWMETER, REFILL ADAPTOR, CONTENTS GAUGE, CANNULA OR MASK, AND TUBING E0434 Requires an in-person or face-to-face interaction prior to prescribing A Written Order Prior to Delivery (WOPD) – required DMEPOS supplier must have documentation of: face-to-face visit, & completed WOPD prior to the delivery must be sufficient information documented meeting applicable coverage criteria are met. AFFORDABLE CARE ACT (ACA) 6407 REQUIREMENTS 18
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OCPO Submission Methods
OCPO Documentation submission methods Mail – USPS, FedEx, UPS Fax – to secured site CD/DVD - Password Protected esMD – via HIH 19
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Types of Review Order Validation – New Prepay Review - Ongoing
Post-pay Review - Ongoing . 20
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Request Process for OCPO
Visits Physician/ Practitioner – Opt Office / ED Hospitalized for Respiratory Failure / Exacerbation of COPD / Pneumonia, etc. – Medical Documentation substantiates Requires &/or Benefits from Supplemental O2 Beneficiary IDTF/Hosp/Home Orders ABGs, Oximetry, 6-minute walk, PFTs, VO2 Max, etc. Refers for Sleep Study Documents the in person visit or F2F visit in Medical Documentation, (progress note, medical record, Hospital H&P/Dismissal Summary/Transfer Sheet ) Must include: Diagnosis supporting need for OCPO, Exam findings, Required Testing Ordering Physician/Practitioner Writes, signs, and dates DWO and Completes the CMN Submits Documentation Package including: In person visit or F2F visit DWO CMN POD Other Supporting Documentation Receives/Files F2F visit progress note, DWO, and CMN Completes OCPO Delivery Obtains Proof of Delivery (POD) Supplier 21
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Request Process for OCPO - Order Validation
Visits Physician/ Practitioner – Opt Office / ED Hospitalized for Respiratory Failure / Exacerbation of COPD / Pneumonia, etc. – Medical Documentation substantiates Requires &/or Benefits from Supplemental O2 Beneficiary IDTF/Hosp/Home Orders ABGs, Oximetry, 6-minute walk, PFTs, VO2 Max, etc. Refers for Sleep Study Documents the in person visit or F2F visit in Medical Documentation, (progress note, medical record, Hospital H&P/Dismissal Summary/Transfer Sheet ) Must include: Diagnosis supporting need for OCPO, Exam findings, Required Testing Ordering Physician/Practitioner DWO – Order Validation Writes, signs, and dates DWO and Completes the CMN Submits Documentation Package including: In person visit or F2F visit DWO CMN POD Other Supporting Documentation Receives/Files F2F visit progress note, DWO, and CMN Completes OCPO Delivery Obtains Proof of Delivery (POD) Supplier 22
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eDoC General Workflow Patient IDTF / Hosp / Opt Lab Physician
DME Supplier Templates and Rules Payer 23
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OCPO Documentation & Coverage Requirements
Common Oxygen and Oxygen Equipment Errors MLN ICN December 2011 1. Missing documentation showing that the patient was seen by a physician within the appropriate timeframes for certification or recertification of the need for oxygen supplies. 2. Missing documentation of original blood gas or saturation test results. 3. Missing documentation indicating that the patient needs or is using oxygen and supplies. 4. Missing documentation to show that the patient is mobile within the home (for portable oxygen). 5. Missing physician order for oxygen supplies. 6. Missing the most recent Certificate of Medical Necessity (CMN).
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OCPO Documentation & Coverage Requirements
Overlooked Policy Requirements MLN ICN December 2011 1. Medicare requires home oxygen to be ordered by a physician after evaluating a patient’s medical need. This visit must occur either prior to, but no earlier than, 2 days prior to the inpatient hospital discharge date, or while the patient is in a chronic stable state. The physician notes must establish the need for oxygen based upon Local Coverage Determination (LCD) requirements and show that the visit (and test) does not exceed 30 days from the Initial Date on the CMN. 2. For Medicare to pay for oxygen equipment, a patient must have both a continued need for oxygen in the home and must also be using the equipment. 3. For patients to qualify for portable oxygen, they must be mobile within the home and be tested under specific conditions (during exercise or at rest). 4. Medicare requires all patients who use home oxygen to first be tested either by arterial blood gas (ABG) or oximetry test (SAT). There must be a record of the test results in the physician’s notes to verify that the test occurred.
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OCPO Documentation & Coverage Requirements
Oxygen Documentation Checklist Medicare requires the following documentation for Medicare oxygen therapy: MLN ICN December 2011 Detailed Written Order The detailed written order must include: Patient name; Detailed description of the items being provided, including: a. The means of oxygen delivery, b. The specifics of varying oxygen flow rates and/or non-continuous use of oxygen, and c. The length of need; Treating physician’s signature and date order signed; and Start date of the order (only required if the start date is different from the signature date)
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OCPO Documentation & Coverage Requirements
Oxygen Documentation Checklist Medicare requires the following documentation for Medicare oxygen therapy: MLN ICN December 2011 Coverage Home oxygen therapy is covered only if all of the following conditions are met: The treating physician has determined that the patient has a severe lung disease or hypoxia-related symptoms that might be expected to improve with oxygen therapy. The patient’s blood gas study meets the criteria stated below. The qualifying blood gas study was performed by a physician or by a qualified provider or supplier of laboratory services. The qualifying blood gas study was obtained under the following conditions (a or b): a. If the qualifying blood gas study is performed during an inpatient hospital stay, the reported test must be the one obtained closest to, but no earlier than, 2 days prior to the hospital discharge date; or b. If the qualifying blood gas study is not performed during an inpatient hospital stay, the reported test must be performed while the patient is in a chronic stable state (that is, not during a period of acute illness or an exacerbation of his or her underlying disease). Alternative treatment measures have been tried or considered and deemed clinically ineffective.
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OCPO Documentation & Coverage Requirements
Oxygen Documentation Checklist Medicare requires the following documentation for Medicare oxygen therapy: MLN ICN December 2011 Medicare Qualifying Saturation Test Results Medicare covers home oxygen therapy only if the patient’s arterial saturation test results meet the following criteria: The patient’s test results must be within 48 hours of the date of delivery, unless the arterial saturation tests were taken during an outpatient encounter or during the patient’s sleep. If tests were taken during an outpatient encounter or during the patient’s sleep, the patient’s arterial saturation test results must be within 30 days of the date of delivery. Arterial saturation test results that qualify for coverage are classified into Group I or Group II. The group determines specific CMN requirements. The criteria for each group are listed in Table 1 and Table 2 below. (Following Slides)
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Structured Information for OCPO
Supports Data collection by providers during in person visit or face-to-face visit Reporting of clinical information for coverage determination Clinical decision support and automated determination of coverage 29
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Evaluation Process for OCPO Structured Documentation
Examination of individual clinical elements for each section of the template Determine if a clinical element is codifiable (e.g. Diagnosis), requires a narrative (e.g. History of Present Illness), or is mixed (e.g. Review of Systems) Compare coded elements to existing standard coding systems (e.g. SNOMED-CT, ICD) and CDA components Map to CDP1 Template Sections and Entries based on User Story Requirements 30
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References/Contact Information Links esMD Initiative: esMD Program: esMD eDoC Initiative: Electronic+Determination+of+Coverage Contact Information Robert Dieterle – esMD Initiative Coordinator Sweta Ladwa – ESAC ) Dan Kalwa – CMS Pamela Durbin – CMS Dr Mark Pilley – Co Lead Dr. Viet Nguyen – Co Lead 31
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References for Coverage and Documentation Requirements
Complete coverage and documentation requirements are outlined in the following policy and CMS Publication: National Coverage Determination (NCD) for OCPO CMS MLN Matters - Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/MM4389.pdf Provides further guidance and clarification about documentation for physicians and treating practitioners when ordering OCPO 32
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References for Coverage and Documentation Requirements
Additional Guidance regarding coverage and documentation requirements are outlined in the following CMS Transmittals: The NCD can be found in transmittal 57, CR4389, at on the CMS website Claims processing instructions are available in Transmittal 961, CR4389, which is available at on the CMS website 33
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References for Coverage and Documentation Requirements
Additional Guidance regarding coverage and documentation requirements for Home Oxygen Use for Cluster Headache (CH) are outlined in the following CMS Transmittals: Assigned Codes for Home Oxygen Use for Cluster Headache (CH) in a Clinical Trial (ICD-10) – MM7820 – Transmittal #: R2465CP The official instruction, CR7820, is located at on the CMS website 34
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References for Coverage and Documentation Requirements
DME MAC policy regarding coverage and documentation requirements are outlined in the following policies: LCDs and LCD Articles for OCPO Jurisdiction A LCD Jurisdiction B LCD Jurisdiction C LCD Jurisdiction D LCD results.aspx?SearchType=Advanced&CoverageSelection=Local&ArticleType=SAD%7cEd&PolicyType=Both&s=All&CntrctrType=10&KeyWord=Oxygen+and+Oxygen+Equipment&KeyWordLookUp=Title&KeyWordSearchType=Exact&kq=true&bc=IAAAAAAAAAAAAA%3d%3d& 35
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References for Coverage and Documentation Requirements
DME MAC policy regarding coverage and documentation requirements are outlined in the following policies: LCDs Oxygen and Oxygen Equipment (OCPO) Jurisdiction A LCD Jurisdiction B LCD Jurisdiction C LCD Jurisdiction D LCD 36
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References on OCPOs from the DME MACs
Jurisdiction A: NHIC, Corp. Jurisdiction B: National Government Services (NGS) Juridiction C: CGS Jurisdiction D:Noridian Administrative Services, LLC (NAS) 37
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eDoC OCPO Timeline 38 Sept ‘14 Oct ‘14 Nov ‘14 Dec ‘ 14 Jan ‘15
Feb ‘15 Mar‘15 Apr ‘15 Kick-Off OCPO – User Story Development Standards/Data Model/Harmonization OCPO Pilots Sub Workgroup LLP Structured Data OCPO Implementation Guide UPDATED SWETA – CHANGED THIS SLIDE What is OCPO Phase 2? 38
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eDoC Timeline October ‘13 December ‘13 February ‘14 April ‘14 June ‘14
We are here October ‘13 December ‘13 February ‘14 April ‘14 June ‘14 August ‘14 October ‘14 December ‘14 February ‘15 Electronic Determination of Coverage WG PMD and LLP e-Clinical Template Pilots Home Health User Story Oxygen Concentrators and Portable Oxygen User Story LLP User Story eDoC Harmonization and Structured Data eDoC Administrative Documents Templates IG for HL7 Ballot eDoC HL7 Clinical Documents for Payers Set 1 Ballot Reconciliation SWETA UPDATED
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Call for Public Participation
As an S&I Initiative, esMD is requesting public participation and input to identify and assess existing standards and define requirements for the eDoC OCPO User Story Targeted Participants: Medicare, Medicaid, and Commercial Payers Providers, Provider Organizations Service suppliers (e.g. DMEs) Health Information Handlers (HIHs) HIT/EHR Vendors and Vendor Associations State HIEs, HIE Vendors SDOs Others with Expertise/Interest in Coverage Determination, Structured Documentation, Decision Support, and Pre-authorization, 40
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Summary eDoC workgroup identifies Best Practice for:
Payer interaction with providers for determination of coverage Developing, delivering and using structured information to support coverage determination Addressing Author of Record requirements Establishing secure electronic communication between payers, provider, suppliers and beneficiaries Creating implementation guides for payers and providers for all required eDoC processes and transactions The focus for next user story is on Oxygen Concentrators and Portable Oxygen (OCPO) 41
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Next Steps The electronic Determination of Coverage Workgroup is open for anyone to join. This community will meet weekly by webinar and teleconference from 1:00 to 2:00 pm ET on Wednesday see S&I Framework calendar for webinar information: Information on how to join the esMD Community can be found on the electronic submission of Medical Documentation (esMD) page: In order to ensure the success of the eDoC efforts, we encourage broad and diverse participation from the community. Wide community participation will ensure that the standards reflect technology that is useable across the industry and meets the needs of all stakeholders. This is your chance to have an impact on the evaluation and selection of standards, in addition to the creation of business requirements and implementation guides for the electronic Determination of Coverage OCPO User Story 42
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Thank You
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