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COMMERCE BUSINESS DAILY ISSUE OF NOVEMBER 4,1998 PSA#2215Health Care Financing Administration 7500 Security Blvd., Baltimore,
MD. 21244-1850 Q -- REQUEST FOR INFORMATION -- DRAFT 6TH STATEMENT OF WORK (SOW) FOR
PEER REVIEW ORGANIZATIONS (PROS) DUE 111698 POC Brenna Smothers,
Contract Specialist, 410-786-1277 Edward Hughes, Contracting Officer,
410-786-0203 A draft of the Peer Review Organization (PRO) 6th
Statement of Work (SOW) is being made available for review and comment.
The Payment Error Prevention Program (PEPP) is born out of two
concerns. First, there is an intolerably high amount of money spent in
error in the Medicare program and, second, it is the responsibility of
the Health Care Financing Administration (HCFA), as the program
manager, to deal with this problem. Most errors are not fraud, most
errors are human beings attempting to use and manage a complex process
to accomplish a social good. For Medicare, this social good is
providing health care to the nation's elderly population. Monitoring
for these errors and minimizing their occurrence is the purpose of
PEPP. In particular, PEPP is directed to inpatient Perspective Payment
System (PPS) services and includes correct coding as well as the
provision of necessary services. The PROs will be required to develop
projects to monitor the suitability and accuracy of payments for
services providedto Medicare beneficiaries. They will also be required
to develop programs to educate provider and practitioners on how to
prevent these errors, to correct the effects of previous errors and to
monitor the effects of their intervention efforts. Fraud in the
Medicare system is an intentional misrepresentation to obtain payment,
but payment for fraudulent bills is also an error to be prevented.
Detecting and prosecuting fraud, abuse and waste is the responsibility
of special contractors and law enforcement agencies. However, the PROs
are required to conduct such analyses as necessary to find mistakes,
determine the nature of the mistakes and take appropriate actions. If
these mistakes are persistent, intentional misrepresentation of facts
or otherwise determined to represent consistent attempts to
inappropriately enhance reimbursement, then the PROs will have
mechanisms in place to draw in the fiscal intermediaries to engage in
overpayment recoveries and the Office of the Inspector General to
investigate and prosecute as appropriate. The draft contains a new Task
outlining the PROs responsibilities with regard to Quality Improvement
System for Managed Care (QISMC). The PRO will not be responsible for
determining whether a particular Managed Care Organization (MCO) meets
QISMC standards. More specific directives on the QISMC activities of
PROs (which are scheduled to begin January 1, 1999) will be issued
shortly by HCFA's Office of Clinical Standards and Quality. The
indicators for the National Health Improvement Topics were chosen in an
effort to balance the importance and relevance of the indicators with
the likelihood of being able to effect and measure improvement. Many,
such as those selected for Acute Myocardial Infarction, Stroke,
Congestive Health Failure and pneumonia treatment, have been used in
successful inpatient projects. The diabetes measures are those measures
from the Diabetes Quality Improvement Project which were amenable to
measurement using administrative data. Influenza and pneumococcal
vaccination and mammography are well-supported preventive practices.
HCFA is acutely aware of the need to ensure that the quality indicators
remain sound throughout the entire contract period. To this end, we
expect each Clinical Area Team (CAT), working in conjunction with its
respective Clinical Area Support PRO (CASPRO) to: 1) Keep abreast of
current developments, 2) Participate in and rely on expert panels and
resources in professional associations, governmental agencies (i.e.
AHCPR, CDC, NIH) and consumer representatives, 3) Make appropriate
modifications to the indicators and the evaluation scheme, when
necessary, and 4) Develop methods to measure increasingly relevant
indicators in more appropriate settings. To evaulate the PROs work
under the national projects task we intend to create a combined
weighted average of the entire set of quality indicators. By evaluating
the PROs based on this global measure, we give the PROs the latitude to
determine how best to distribute their improvement efforts so that they
achieve the maximum feasible improvement, taking into account local
conditions. The combined weighted average will be calculated in two
steps. The score for each clinical priority will be a weighted average
of the indicators for that priority. The weights will probably reflect
an estimate of both the clinical impact and the feasibly achievable
improvement in each indicator. We are still working on the detail of
this weighting scheme. As a second step, the six clinical topic
weighted averages will be combined, with equal weights, into an overall
average. After a great deal of internal and external discussion and
consultation, we believe the following percentages roughly represent
the relative level of effort: 1) 60% -- QIP (75% -- National, 25% --
Local) 2) 30% -- PEP 3) 10% Beneficiary Rights/Outreach/Statutorily
Mandated Review Activities We anticipate the Standard Data Processing
System will be modified to allow most, if not all of the QIP and PEPP
activities to be reported through systematic, regular, routine data
entry and that PROs should not have to spend time and effort creating
and submitting a great many ad hoc reports. Further information
including specific directives on this activity should be available at
the time the Request for Proposal (RFP) is published and will be
included with that document. At this time, we are seeking comments on
the overall direction of the PRO program as documented in the draft 6th
SOW. The specific processes will be described in the PRO Manual
sections which will be part of the RFP now scheduled for publication in
early January. Comments received will be taken into consideration when
finalizing the SOW but will not be responded upon individually. If you
would like your comments to be considered, they must be submitted no
later than November 16, 1998 to: Ms. Susan Smith via E-Mail
(SSmith1@hcfa.gov), fax (410-786-8532) or mail (Ms. Susan Smith, Health
Care Financing Administration, Office of Clinical Standards and
Quality, Mail Stop S3-02-01, 7500 Security Boulevard, Baltimore, MD
21244-1850). These points of contact are for comments ONLY, the SOW can
be viewed as noted below. You may view the SOW at the following website
address: http://www.hcfa.gov/quality/qlty-5b.htm. If you require a hard
copy of the SOW, you may contact Brenna Smothers at 410-786-1277 and
one will be mailed to you. Posted 11/02/98 (I-SN267385). (0306) Loren Data Corp. http://www.ld.com (SYN# 0049 19981104\Q-0002.SOL)
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