J.7_QIO_Communications_Handbook.pdf

QIO Communications Handbook for the

10th Statement of Work Contract Cycle

(2011-2014)

Updated October 25, 2013

NOTE TO ALL BIDDERS: This handbook serves as a compendium of guidance available to QIOs to assist them in conducting communications work under the QIO 10th Statement of Work, and is the most recent version available as of the date of this RFP. This handbook does not reflect changes to CMS communications policy that will be needed in order to implement the communications-related activities of the 11th Statement of Work.

NOTE TO BIDDERS WHO ARE NOT 10th SOW QIOs: This document contains hyperlinks to memoranda and policy guidelines that are available only from the QualityNet QIOnet intranet through the HCQIS system. Bidders that do not have access to the QIOnet intranet or the HCQIS system may obtain copies of all associated material at http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment- Instruments/QualityImprovementOrgs/Future.html.

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityImprovementOrgs/Future.html http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/QualityImprovementOrgs/Future.html

QIO Communications Handbook

Contents Introduction

Focus on Procedures and Processes

Procedural Policies

Beneficiary Helpline Policy/Promotion TDD Line Policy

Confidentiality, Disclosure and Release of Information Notice to Providers Safeguarding Protected Health Information (PHI) and Personally Identifiable Information (PII) Release of Information Documents QIO Status Under HIPAA

Conflict of Interest Allowed Non-QIO Partners Prohibited Partnerships Conflicts of Interest Certificate Endorsements Prohibited

Partnerships with Stakeholders Partnership and Stakeholder Meetings

Retaining Materials

Website Standards and Guidelines Hardware and Software Catalogs

Gathering Information

Collecting Information (Surveys) Activities Requiring Clearance Activities that Do Not Require Clearance

Information Provider Protection

Health Communication Skills

Communication Skill Set

Leveraging the Principles of Social Marketing

Measuring Communication

Creating Materials

Efficiency, Sharing, and Developing New Materials QIO Sharing Review of Media Activities and High-Profile Events

Enabling Access: Making Materials Accessible and Easy to Read Cultural Competence Plain Language

How to Refer to CMS and Your QIO Branding Plan CMS Proper Reference QIO Proper Reference Using the DHHS Logo and CMS Identity Mark Avoiding Incorrect Uses of the Identity Mark

Impact Statements: Guidelines

Success Stories

Engaging Patients in Outreach Efforts Disclosure of Confidential Information Valid Authorization from Beneficiaries

Outreach Materials Definition

Integrated Innovation Spread Strategy: 10th SOW Deliverable

Publishing and Disseminating Information

Copyright

Disclaimer and Publication Numbering Numbering System

DDST Submissions

Scientific Publications Definition Scientific Disclaimer and Publication Number Confidentiality Requirements

508 Compliance Policy

Digital Media Use

Resources

QIO Resources Fact Sheets Developing Effective QIO E-Newsletters Guide to Planning and Drafting Scientific Submissions Success Story Toolkit

CMS Resources Navigating to Statement of Work Documents and the QIO Manual CMS Newsroom Page CMS Press Mailing List CMS Product Ordering Listservs QIOnet QualityNet.org QIO Program Commonly Used Acronyms Question and Answer System WebEx Resources

Contact Information

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Introduction The QIO Communications Handbook is designed to support Quality Improvement Organization (QIO) communications staff and innovation spread advisors as they conduct their work under the QIO Program’s 1oth Statement of Work contract cycle. QIOs conduct a variety of communications activities that include positioning the organization as a resource to the general public in support of Centers for Medicare & Medicaid Services (CMS) initiatives, and efforts that support specific 10th SOW Aims. The handbook is also a reference for CMS staff in the Central and Regional Offices (RO) who work with QIO Program Care Reinvention through Innovation Spread (CRISP) strategies and requirements. This set of communications initiatives translates the principles of social marketing, communities of practice/learning networks and innovation spread into practical goals intended to drive transformation in health care quality.

This guide serves as your “one stop shop” for all relevant CMS CRISP guidelines, policies, procedures and other information related to QIO communication. It both quotes and sometimes (for ease of reading) paraphrases official policies and procedures, and provides hyperlinks1 to original documents for reference to the exact language. The CRISP National Coordinating Center (CRISP NCC) will update this handbook periodically to include new or revised CMS CRISP-related policies, guidelines or procedures.

Focus on Procedures and Processes The material in the handbook is arranged according to the procedures QIO communicators need to reference and the processes they use in their day-to-day work:

• procedural policies

• health communication skills

• gathering information

• creating materials

• publishing and disseminating information

• making use of resources and contacts

An introductory paragraph prefaces each section, which is then arranged alphabetically or follows a process order relevant to the types of tasks described. Within the text, cross references provide a way to move to related sections, while the Table of Contents allows you to search for specific topics.

1 Many links in this document are directed to QIOnet. You must view this document on a Standard Data Processing System (SDPS) computer or the links will appear to be broken. Another resource referenced frequently in this document is the CRISP Community on the Collaborative Tool. You must be a member of the CRISP Community to view the content on the site.

http://qionet.sdps.org/ http://healthcarecommunities.org/default.aspx

Procedural Policies CMS policies and procedures are contractually-binding. The descriptions and summaries of key policies, procedures and guidelines contained throughout this document are not intended to replace CMS policy.

Questions about policy clarification should be directed to your Contracting Officer Representative (COR).

Beneficiary Helpline Policy/Promotion For all new beneficiary-targeted outreach materials, QIOs must publish and promote the national 1-800-MEDICARE helpline for all information related to beneficiary protection, with the exception of appeals. (TOPS Memo 2003-11; Note: the contents of this memo replace the policy included in the QIO Manual, Chapter 12, 12120.)

For appeals, QIOs must maintain and promote their own cost-free appeals helpline. The QIO must have a method in place to accept requests for appeals 24 hours a day and to perform reviews seven days a week.

TDD Line Policy QIOs are not required to maintain a Telecommunications Device for the Deaf (TDD) line. If a QIO receives a call from a TDD line, the call may be forwarded to Medicare’s TDD line. (Q&A System ID# 158476, category:

Beneficiary and Family Centered Care.)

Confidentiality, Disclosure and Release of Information Medicare beneficiaries, providers and other entities with whom QIOs work in their health care quality improvement initiatives have a right to confidentiality. The statutes that govern these rights include sections of Part B of Title XI of the Social Security Act, the Code of Federal Regulations (CFR) designated as 42 CFR Part 480, and sections of the Health Insurance Portability and Accountability Act (HIPAA). Chapter 10 of the QIO Manual provides the detailed information on confidentiality as it affects the entire QIO program.

What follows are summaries and information about confidentiality, disclosure, and release of information that pertain to QIO communication.

Notice to Providers The QIO must give the provider 30 days’ notice that the QIO will release the name of collaborators or provider-specific information. This notice is not required if:

• The provider consents to or requests the release of information; or http://qionet.sdps.org/tops_memos/03-11.htm http://qionet.sdps.org/tops_memos/03-11.htm http://cms.hhs.gov/manuals/downloads/qio110c12.pdf https://cms-qio.custhelp.com/app/answers/detail/a_id/158476/kw/158476 http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/qio110c10.pdf http://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/qio110c10.pdf

• The information meets the definition of public information in 42 CFR 480. Public information may include the provider posting a certificate of participation in a public lobby of the facility.

(TOPS Memo 2004-14) (TOPS Memo 2003-03)

Safeguarding Protected Health Information (PHI) and Personally Identifiable Information (PII) CMS released SDPS Memo 09-395-GN on November 2, 2009, to remind all users of the appropriate use of QualityNet email and the proper procedures for transmitting confidential email. PHI and PII must be safeguarded at all times by all individuals and organizations working for, or on behalf of, CMS. The disclosure or misuse of PHI or PII by an individual or organization working on behalf of CMS can cause irreparable damage to individuals whose personal records are at stake. In addition, the disclosure or misuse of PHI or PII by an individual or organization could result in legal liability from those whose information was inappropriately released. The memo further explains the proper methods for transfer of sensitive or protected data.

Release of Information Documents Clarification from CMS on January 23, 2006, specified that for each new Statement of Work (SOW) QIOs must obtain a new release of information document from providers when releasing their name or information.

QIO Status Under HIPAA In April 2003, CMS released SDPS Memo 03-150-GN, which provides guidance on supplying information to QIOs under HIPAA in a Questions and Answers document.

Conflict of Interest Partnership activities are an integral part of the CMS mission. Developing and sustaining partnerships is central to collaborative outreach efforts, sharing information, and leveraging resources. For more information on CMS partnership communities, see the “Partner with CMS” section of the CMS website.

The following policies will help you prevent actual or apparent conflicts of interest:

Allowed Non-QIO Partners QIOs are allowed, under certain specific circumstances, to cooperate with other organizations to accomplish the goals of the Medicare contract (e.g., conference sponsorship). QIOs must make sure that collaborating does not create actual or apparent conflict of interest, inadvertent endorsement of products, or contract funding issues. (TOPS Memo 2001- 04).

http://qionet.sdps.org/tops_memos/04-14.htm http://qionet.sdps.org/tops_memos/03-03.htm http://qionet.sdps.org/sdps_memos/sdps_memos_2009/09395gn.htm http://qionet.sdps.org/sdps_memos/sdps_memos_2003/03150gn.htm http://qionet.sdps.org/sdps_memos/sdps_memos_2003/attachments/April14Q_A.pdf http://qionet.sdps.org/sdps_memos/sdps_memos_2003/attachments/April14Q_A.pdf http://www.cms.gov/Partnerships/01_Overview.asp http://qionet.sdps.org/sdps_memos/sdps_memos_2001/01-04.htm http://qionet.sdps.org/sdps_memos/sdps_memos_2001/01-04.htm

Prohibited Partnerships It is a prohibited organizational conflict of interest for a QIO to be owned by or affiliated with a Medicare health care facility, or association of facilities, payer organization, health plan, pharmaceutical company or manufacturer, laboratory, DME supplier, provider of ambulance or medical transport services, health information technology vendor, or any other entity CMS identifies, in the QIO area, through management, common control or ownership. It’s also considered a conflict of interest to be a corporation, partnership, joint venture or other entity comprised of, affiliated with, reimbursed by, or funded by any of the above organizations. (Section H.11, 10th Statement of Work2)

QIOs may not enter into contracts with providers or practices over which the QIO has review authority or for which the QIO performs other quality-related services under its QIO contract. This also applies to any related commercial entity operating in the same geographic service area as the QIO.

QIOs that wish to engage in commercial business related to or similar to work the QIO performs must do so through an entity that is separate from and independent of the QIO. A QIO’s related commercial entity may enter into contracts and arrangements with providers and practices outside the QIO’s geographic area. If such providers or practices are part of a “chain” organization, any such contracts or arrangements entered into by the QIO’s related commercial entity cannot include services provided to any provider or practice within the QIO’s geographic service area.

Related commercial entities are not prohibited from entering into contracts or arrangements with other parties that do not participate in Medicare, regardless of whether such parties are within or outside of the geographic service area of the QIO. (TOPS Memo 2006-08)

Conflicts of Interest Certificate The QIO shall submit the Organizational Conflicts of Interest Certificate with the QIO’s initial proposal, when the contracting officer requests a revision, annually on the second Friday of months 13 and 25 following contract award, and 45 days before any change in the information submitted is to be in effect. (Section H.11.D.2, 10th Statement of Work)

Endorsements Prohibited When working on national campaigns, neither the QIO nor its management and staff may give the appearance that the QIO is endorsing an external entity or its products or services. If any partner or

2 Please note: The 10th Statement of Work is referenced several times in this document.

Modifications may be made to this contract. Please refer to the SDPS memo system on QIONet for information about updates to the 10th Statement of Work.

https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://qionet.sdps.org/tops_memos/06-08.htm https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://qionet.sdps.org/sdps_memos/SDPS_memos.shtml other external entity solicits an endorsement, it must be turned down.

(SDPS Memo 07-096-CO)

A QIO must discourage providers from using the data they receive from QIOs — whether it appears on the Hospital Compare or Nursing Home Compare websites or comes as part of other QIO programs — for promotions in which they compare themselves to other providers in the state, region, or nation. They may, however, promote their improved measures against their baseline data.

CMS and QIOs should never appear to “endorse” or “rate” any provider above their peers through publication of comparative data. (Q&A System

ID# 158751)

Partnerships with Stakeholders In addition to the required collaborative activities outlined in the 10th Statement of Work, the QIO may coordinate activities with stakeholder organizations in its state or jurisdiction working on comparable improvement efforts or interested in teaming with the QIO. Coordination with stakeholders may involve creating, joining, and supporting partnerships with organizations with similar goals and objectives, or facilitating ongoing discussion among the various stakeholders. (Section C.4.H, 10th Statement of Work) QIO communicators planning to work with stakeholder organizations should review any policies that pertain to stakeholders (Procedural Policies).

Coordination with stakeholders may involve creating, joining, and supporting partnerships with organizations with similar goals and objectives, or facilitating ongoing discussion among the various stakeholders. The nature of the activity to facilitate coordination must be consistent with the terms of the contract and may require advance approval from the Contracting Officer. (Section C.4.H, 10th Statement of Work)

Partnership and Stakeholder Meetings QIOs should meet at least twice per year with organizations directly affected by the activities of the QIO Program. These organizations should include, but are not limited to:

• state and local provider organizations

• medical societies

• specialist societies and state licensure agencies.

All meetings should be appropriately documented. (QIO Manual, Chapter 12, 12210) http://qionet.sdps.org/sdps_memos/sdps_memos_2007/07096co.htm http://www.hospitalcompare.hhs.gov/ http://www.medicare.gov/NHCompare/Include/DataSection/Questions/SearchCriteriaNEW.asp?version=default&browser=IE%7C7%7CWinXP&language=English&defaultstatus=0&pagelist=Home&CookiesEnabledStatus=True http://www.medicare.gov/NHCompare/Include/DataSection/Questions/SearchCriteriaNEW.asp?version=default&browser=IE%7C7%7CWinXP&language=English&defaultstatus=0&pagelist=Home&CookiesEnabledStatus=True https://cms-qio.custhelp.com/app/answers/detail/a_id/158751/kw/158751 https://cms-qio.custhelp.com/app/answers/detail/a_id/158751/kw/158751 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://cms.hhs.gov/manuals/downloads/qio110c12.pdf

Retaining Materials In addition to SOW requirements, the Federal Acquisition Regulations require that all other documents (e.g., outreach materials) related to contracts entered into by negotiation be retained for three years after final payment under the contract. (QIO Manual, Chapter 13, 13140)

Website Standards and Guidelines The CMS website provides a complete list of CMS Contractor Website Guidelines. This site and the QIO contract (Section C.4.I.1) include the following guidelines:

• Link to any content that is available on CMS websites rather than duplicating it.

• Your site should display a Privacy Policy.

• If displaying the CMS Identity Mark on your website, follow the

CMS Identity Mark Usage Guidelines

• Your site must be compliant with Section 508 of the Rehabilitation

Act (for more detail refer to 508 Compliance Policy section in this handbook).

• Your site must comply with all other applicable CMS and Program requirements.

• Follow the “Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons,” released on June 12, 2002 and by DHHS on August 4, 2003.

• Only use the website for informational purposes; do not design any applications or software unless approved through your COR.

QIOnet, in cooperation with CMS and the SDPS Web Strategies and Communications Workgroups, has developed 508 Compliance and Accessibility Resources along with a Chronological Compilation of QIO website guidance. Additional 508 Compliance information can be found on the Collaborative Tool, under the CRISP Reference Shelf, in the 508 Compliance folder. Additional information on the internet presence of QIOs can be found in the 10th Statement of Work, Attachment J-11.

Hardware and Software Catalogs Listings of SDPS-approved software and hardware are available on QIOnet. These catalogs list the product name, model, manufacturer, details, status and estimated cost. (SDPS Memo 04-113-GN)

Software Catalog

Hardware Catalog http://cms.hhs.gov/manuals/downloads/qio110c13.pdf http://www.cms.hhs.gov/AboutWebsite/13_contractorwebguidlines.asp http://www.cms.hhs.gov/AboutWebsite/13_contractorwebguidlines.asp https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf http://qionet.sdps.org/training_resources/accessibility.shtml http://qionet.sdps.org/training_resources/accessibility.shtml http://healthcarecommunities.org/default.aspx https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://qionet.sdps.org/sdps_memos/sdps_memos_2004/04113gn.htm http://qionet.sdps.org/tech_info/sdps_hrdw_softw/sdps_software.shtml http://qionet.sdps.org/tech_info/sdps_hrdw_softw/sdps_hardware.shtml

Gathering Information QIO communicators gather information for conducting outreach, education and promotion of SOW Aims from a variety of sources:

beneficiaries, partners, and other QIOs, among others. Policies relating to these information gathering activities, including policies related to confidentiality, conducting surveys and working with partners, are placed (in alphabetical order) in this section.

Collecting Information (Surveys)

Activities Requiring Clearance Any given SOW may require, in the contract, that certain satisfaction and other surveys be performed by an outside contractor. If, however, a QIO wishes to collect information outside of SOW contractual requirements, CMS policies apply.

All information collection activities directed to 10 or more persons, whether exempt from Office of Management and Budget (OMB) clearance or not, must be cleared through your COR. This applies to information collected from:

• Beneficiaries

• Health care providers

• Other entities

It does NOT apply to medical record abstraction conducted as part of a quality improvement project. Be aware that the Paperwork Reduction Act (PRA), which is applicable here, defines “person” in a way that pertains to more than just individuals. Chapter 12 of the QIO Manual provides a helpful clarification specifically for QIOs:

For practical purposes, CMS recommends that QIOs think in terms of the “unit of information collection” in place of the PRA’s “person.” That is, a unit of information collection would be considered the basic unit from which data are collected and the level at which those data are analyzed. Thus, a unit of information collection could be an individual, a focus group, a hospital, or a meeting, depending on what unit the QIO is interested in knowing more about.

Using the guideline above, for example, a QIO could hold six focus group sessions, and, by collecting information at the focus group level (but NOT at the level of the individual participant) fall below the 10-person threshold that would trigger the need for an OMB review. The CMS information collection approval process has two parts:

http://cms.hhs.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/qio110c12.pdf

Part I: Proposal Approval: The QIO completes an Information Collection/Proposal-Approval Template (see QIO Manual, Chapter 12, exhibit 12-1) and submits it electronically to the COR.

Part II: Activity Approval: Once the COR has approved the proposal, the QIO must use the Information Collection/Activity-Approval Template (see QIO Manual, Chapter 12, exhibit 12-2) to submit documents to the Regional Office (RO) to review and approve. The following documents are required:

Document 1: Justification: a document justifying the information collection activity Document 2: Methodology: a description of the methods the QIO intends to use, and Document 3: the final draft of the proposed information collection instrument In some cases you must also submit a fourth document:

Document 4: Beneficiary Notification Letter: (If necessary – see Note 2 below).

Note 1: Some ROs may require that both of the aforementioned forms

(proposal approval and activity approval) be submitted simultaneously.

Note 2: If Medicare beneficiaries comprise any of the respondent samples, you must also submit a Beneficiary Notification Letter.

The purpose of the notification is to give the beneficiary advance warning of the activity and the opportunity to opt out of participating.

Your COR, in consultation with the RO scientific staff, must approve the information collection instruments and all supporting documentation before you implement the actual information collection activity. No preliminary contact, including a cover letter or scripts, may be sent out until the approval is received. You may, therefore, want to consult with RO staff as you are developing these documents.

Your COR can deem an information collection project exempt from OMB clearance. If it is not exempt, s/he will submit the project for clearance.

Activities that Do Not Require Clearance When undertaking activities that do not require RO review and approval, QIOs are still encouraged to inform their RO. These activities include the following types of information collection activities directed to fewer than 10 participants:

• Focus groups that use open-ended questions

• Screening tools used to determine focus group participants

• Discussion guides/prompts with open-ended discussion topics http://cms.hhs.gov/manuals/downloads/qio110c12.pdf

• Acknowledgements

• Consents

• Receipts

• Publication order forms

• Reader response cards/feedback forms if questions are open-ended

• Website feedback (suggestion box format only) and order forms for publications or other materials

• Evaluation forms for meetings

• Follow-up contacts for meetings

• Phone scripts that are open-ended

• Continuing intermittent feedback from physicians

• A closed-ended question survey that goes to nine or fewer persons

• A subcontract if CMS is not sponsoring the collection

(QIO Manual Chapter 12, 12620)

Information Provider Protection No person or provider supplying information to a QIO will be held, by reason of having provided such information, to have violated any criminal law or to be civilly liable under any state or federal law, unless the information provided is unrelated to the performance of the contract of the QIO or the information is false and the individual knew or had reason to believe that the information was false (SDPS Memo 03-106-GN).

Health Communication Skills Outreach is a primary function of QIOs, necessary for both educating beneficiaries and providers about QIO Program services and conducting health quality improvement interventions according to the Aims of a given SOW. In addition to customer knowledge-building, QIO communicators are engaged in intervention planning, message design, and tracking and measurement. QIO communicators assist in managing public recognition and the press, and work not only with their own QIO’s clinical staff, but also local, statewide and national stakeholders in social marketing interventions. Other types of outreach communication include crafting success stories, and preparing scientific articles and presentations.

Policies pertaining to creating materials and engaging in outreach follow, alphabetically. Some of the primary skills and methods used by QIO communicators are described below.

Communication Skill Set Each QIO shall appoint 1-2 individuals to serve as Innovation Spread Advisors (ISAs), which are considered key personnel for their state or territory. This individual shall bring knowledge to every QIO Aim (or project) team within the enterprise by helping Aim teams. ISA(s) from each QIO shall identify which members of QIO Aim teams shall serve as brand ambassadors. Each Aim team shall contain at least one individual designated as a “brand ambassador,” although the QIO may designate as http://qionet.sdps.org/sdps_memos/sdps_memos_2003/03106gn.htm many individuals as needed for this designation. (Section C.10.C.3, 10th Statement of Work)

Leveraging the Principles of Social Marketing In performing the tasks of the SOW, the QIO incorporates various tactics to stimulate widespread positive changes in the attitudes and behavior of various target audiences. QIOs are encouraged to engage in health promotion campaigns using their own creative strategies.

Effective QIO CRISP work in support of the SOW Aims is based on the CRISP Model. The model has 3 phases: 1) initiation and “will building;” 2) engagement and maintenance; and 3) retention and sustainment throughout the life of the QIO task. The goal of the model is to give access to the right information and services, in the right form, at the right time, to the right people in the right place. The model does this by focusing the QIO’s energies such that each policy, action, and decision is made with an educated and strategic consideration of the impacts they may have on stakeholders.

Because every task has “stakeholders,” every task shall be informed by the principles of the model. The model shall be used throughout all activities; it minimizes internal fragmentation and siloing within the QIO so that all operations are stakeholder-centric and support at least 1 of 3 model phases. (Section C.10.3.A, 10th Statement of Work,) Additional information on which activities fall under the CRISP model can be found in Attachment J-11.

The QIO must effectively adhere to CMS policy requirements and agency and departmental directives. In addition, the QIO must use social marketing theories (a systematic approach to achieve behavioral change) in developing strategies and products to ensure that content, design, and dissemination appropriately conform to target audience(s).

The CRISP Community on the Collaborative Tool houses multiple training resources on social marketing. The resources are available under the CRISP Reference Shelf in the Social Marketing Help folder. Among the trainings posted is the three-part series presented in April 2012 by Mike Newton-Ward.

Also, on QIOnet under Presentations/Articles, a 2009 QualityNet Conference presentation by John Strand, “Quality Improvement – How Can Social Marketing Help?” provides more detail about social marketing principles and QIO work.

Measuring Communication The Integrated Innovation Spread Strategy (IISS) provides a section for measuring communication tactics. QIOs shall conduct evaluations of the stakeholder-facing tactics they deploy during the prior quarter and report these results to CMS through the IISS. This evaluation shall be designed https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://healthcarecommunities.org/ http://qionet.sdps.org/presentations_articles/pres_qualnetconf.shtml so that its results can be used to determine whether a tactic is effective and worth repeating or replicating in other formats or with other communities.

An SDPS memo (11-221-DD) provides a link to IISS FAQs which provide further guidance on measurement:

“First, it is important for all evaluation methods to comply with CMS requirements for information collection outlined in the QIO Manual, Chapter 12, Sections 12600-12670. It is equally important to understand that a practical approach to evaluation is desired. The intent is to conduct some form of measurement that helps determine whether a tactic is effective and worth repeating (Did the tactic help remove a barrier to behavior change?). Evaluation is NOT expected to be based on a formal or complex design.”

The IISS FAQ guide explains further:

“Effective evaluation should be matched to tactics, and can include: website traffic analysis, media measurement, conference evaluation forms, reader surveys with open-ended questions, and focus groups that meet CMS requirements.

Another evaluation option is to set a goal for response to your ‘call for action,’ such as a targeted attendance for a provider workshop that you are promoting.”

July 2010 Communications Measurement Training: This three-part training was held on July 13, July 20, and July 27, 2010.

Presentations by Angela Sinickas are captured in slides, transcript, audio recording, and the complete WebEx, which are available on the Collaborative Tool, under the CRISP Reference Shelf in the Measurement Help folder.

Creating Materials Efficiency, Sharing, and Developing New Materials The QIO should manage its resources as efficiently and effectively as possible. CMS recognizes three major sources from which QIOs can obtain already-prepared marketing materials and resources:

• Other CMS contractors

• ESRD Networks

• Other external sources that provide non-copyrighted materials and resources The QIO may also develop its own materials.

https://qionet.sdps.org/sdps_memos/sdps_memos_2011/11221dd.pdf http://www.healthcarecommunities.org/

QIO Sharing QIOs are encouraged to share materials with the general QIO community.

QIOs can share their materials in the Works in Progress folders on the CRISP Community or share with the CRISP GTL or the QIO’s COR.

Any member of the CRISP Community can post their materials directly to the Collaborative Tool in the Works in Progress folders. Items posted in the Works in Progress folders do not have to be 508 compliant; however, those materials do need to be made compliant before sharing on individual QIO websites.

Review of Media Activities and High-Profile Events The QIO shall adhere to review requirements with regard to media activities and/or materials supporting high-profile events and national initiatives. Once a submitted document has been approved by the CMS communications lead, the QIO shall provide a copy of the final version to the COR and CMS communications lead. (Section C.4.I, 10th Statement of Work). CMS press office contact information and resources are available on the CMS Newsroom Center.

Enabling Access: Making Materials Accessible and Easy to Read

QIO communicators are called upon to consider how all members of their audience might best access the materials they create, disseminate or publish; this section reviews cultural competence and plain language guidelines. For information on Section 508 compliance (access to electronic information by people with disabilities) please see the 508 Compliance Policy section.

Cultural Competence Cultural competence is the ability of the individual and organization to function effectively in cross-cultural situations. Achieving cultural competence is one step along the path to reducing the disparities gap in health care. As the website of the Department of Health and Human Services (DHHS) Office of Minority Health says:

“Quite simply, health care services that are respectful of and responsive to the health beliefs, practices and cultural and linguistic needs of diverse patients can help bring about positive health outcomes.”

QIO communication must reflect the heterogeneity of the beneficiary population at large with respect to race, color, age, sex, physical handicaps and national origin. This includes not only the choice of language, but also the images and illustrations used. Sometimes separate ethnic or cultural versions of a communications product may be required. Your communication, in whatever medium, whether it directly portrays or identifies a group or groups of people, or whether it does so http://www.healthcarecommunities.org/ https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 https://www.fbo.gov/?s=opportunity&mode=form&tab=core&id=e920275a568fd25d069e8adc9d84d290&_cview=0 http://cms.gov/Newsroom/Newsroom-Center.html http://minorityhealth.hhs.gov/templates/browse.aspx?lvl=2&lvlID=11 by implication, must not reflect adversely on that group or groups. You may not portray stereotyped behavior unless it serves the purpose of the communications product.

DHHS has developed a website of resources about cultural competence, www.ThinkCulturalHealth.hhs.gov. The site offers links to examples of training materials, articles and tool kits for addressing cultural competence issues. The website also includes cultural competence training modules that are eligible for CE credits for a variety of health care professionals and first-responders. Among the other resources on the Publications and Tools page is a list of links to websites that address specific ethnic populations — useful when there is a known culture you are trying to reach.

Plain Language Federal government contractors must use plain language (or “plain English”) in all written communication. By using plain language, we send a clear message about what the program is doing, what it requires, and what services it offers. Plain language documents are logically organized, use easy-to-read design, and feature:

1. common, everyday words, except for necessary technical terms

2. “you” and other pronouns

3. the active voice

4. short sentences

Several plain language resources are available online, including the Federal Plain Language website. In particular, review the Federal Plain Language Guidelines. There are also several resources available on the CRISP Community of the Collaborative Tool, including Jessica Ridpath’s QualityNet presentation “It Takes a Village to Build a CRISP Strategy”.

Jessica’s presentation can be found in the CRISP 101 folder. Other plain language resources, including information on the Program for Readability in Science and Medicine (PRISM) can be found in the Writing Help folder.

While most of us have heard the expression “the active voice,” before, we may not know exactly what it means, nor how to find and remove its opposite (the passive voice) from our prose. The Federal Plain Language Guidelines include a brief explanation of how to revise passive language into active language. Consult a writing handbook for a more in-depth explanation of the attributes of passive language and how to avoid them, for example, Style: Ten Lessons in Clarity and Grace, by Joseph Williams.

http://www.thinkculturalhealth.hhs.gov/ https://www.thinkculturalhealth.hhs.gov/creditinfo.asp https://www.thinkculturalhealth.hhs.gov/pubs_tools.asp http://www.plainlanguage.gov/howto/guidelines/bigdoc/writeActive.cfm http://www.plainlanguage.gov/ http://www.plainlanguage.gov/howto/guidelines/bigdoc/TOC.cfm http://www.plainlanguage.gov/howto/guidelines/bigdoc/TOC.cfm http://www.plainlanguage.gov/howto/guidelines/bigdoc/writeActive.cfm

How to Refer to CMS and Your QIO

Branding Plan In the communications field, the word “branding” is mentioned frequently, but what is a brand and what are the goals of the QIO branding plan? A brand entails:

• a promise

• an identity

• the customer/stakeholder experience

• becoming an asset with equity

The promise sets the stakeholder’s expectation about interaction with the organization and its products or services; it encompasses the brand messages. The visual identity is created by the graphic representation that triggers brand recognition. The stakeholder experience is affected by emotional attributes and benefits provided at all touch-points with the brand, which, over time, as expectations are met with positive experiences, becomes an asset with equity.

The QIO Branding Program aims to:

• Create greater consistency of message and identity across all QIO program communication

• Create greater brand awareness of the QIO Program among beneficiaries and stakeholders

• Create better understanding of QIOs and their impact

Details on the QIO Program Brand can be found on the Collaborative Tool, under the CRISP Reference Shelf in the Branding folder. Resources available include QIO Program Brand Guidelines, logos, and templates.

The Brand Guidelines are a key tool in supporting the QIO Program Brand and include information on logo use, color palettes, typography, photo usage, co-branding, and messaging.

CMS Proper Reference In written references to the Centers for Medicare & Medicaid Services, QIOs must use the ampersand (&) and not the word “and.” When referring to the agency using an acronym, use the acronym “CMS.”

(TOPS Memo 2002-02) More information on the proper way to reference CMS can be found in the CMS Brand Strategy & Graphics Standard Guide.

The proper reference to CMS is, “The Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human http://healthcarecommunities.org/ http://healthcarecommunities.org/ http://healthcarecommunities.org/content.aspx?id=4294973374 http://qionet.sdps.org/tops_memos/02-02.htm http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf

Services.” The reference to DHHS is only required the first time that CMS is mentioned in the document.

Elements of CMS Style points out that the correct possessive form of CMS is “CMS.’” Sometimes it may be necessary to use this form, but in English, possessives of words that end in “s” are awkward to pronounce and can slow a reader’s progress, so try to avoid the usage by revising.

Since “CMS” can form part of a noun phrase this is usually easy to do.

For example, instead of “CMS’ quality initiatives cover nursing home, home health and hospital care,” it communicates clearly to say, “CMS quality initiatives cover…….etc.”

QIO Proper Reference When referring to your organization, use the term “Quality Improvement Organization” or “QIO.” In describing contract work with CMS, a QIO may choose to identify itself as a “Medicare QIO.” (TOPS Memo 2002-02)

Using the DHHS Logo and CMS Identity Mark The DHHS Logo and CMS identity mark (logo) cannot be used by QIOs without CMS clearance. These materials should be numbered using the QIO’s internal publication numbering system (See “Disclaimer and Publication Numbering”). A disclaimer is not required if clearance is obtained to use the DHHS Logo or CMS identity mark.

When planning to use the CMS identity mark, QIOs and National Coordinating Centers should use the following process. Please note that section 1140 of the Social Security Act governs the use of the CMS identity mark, and penalizes unauthorized use of the logo with a fine.

• Send the product to the appropriate Aim-specific NCC for a clinical review.

• Ensure that the content clearly and accurately reflects CMS-approved messages, correct placement of the CMS identity mark, and correct references to CMS and/or DHHS. Use the CMS Brand Strategy & Graphics Standard Guide as your primary resource to ensure appropriate use of the mark and logo.

• Email a request for approval to your QIO’s CRISP NCC account manager and copy your COR on all related communication. Please include a contact name, telephone number, and FAX number.

Send the final draft of your material and as much information as possible in your request (e.g., why you need the logo, what format the final product will be in (digital vs. print), what file format you need the logo in, what it will be used for, amount of duplication, distribution, who will see it, a timeline, etc.). If you need a reply in fewer than 15 business days, please call the CRISP NCC at 804-289-5320 first. The CRISP NCC will work together with the http://healthcarecommunities.org/Comm_DocsDetails.aspx?id=4294976161 http://qionet.sdps.org/tops_memos/02-02.htm http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf http://healthcarecommunities.org/Comm_DocsDetails.aspx?id=4294972825 http://healthcarecommunities.org/Comm_DocsDetails.aspx?id=4294972825

CMS Office of External Affairs to secure approval of your QIO’s logo request. Once approved, the COR will notify the requestor that material is suitable for distribution.

Note: This supersedes the directions provided in SDPS Memo 07-

067-GN.

You may retain the logo and identity mark on materials without further clearance if you do not modify these materials or if you modify them only as follows. You may:

• Add the logo and contact information including name, address, etc., of your organization (note that the DHHS logo must be larger and more prominently placed than the CMS identity mark or any other logo);

• Select any color(s) to fit your corporate image;

• Add the names of local partners; and delete any text and references (but not author acknowledgments if included in the CMS document) that you select to shorten the materials, without altering the message of the original document. In this instance, you must include the following disclaimer on the materials:

o “This is an edited version of a document prepared by the Centers for Medicare & Medicaid Services and/or its contractors. You can find the original, unedited version of the document at (fill-in the cms.gov website address here).”

(TOPS Memo 99-30)

If the logo and identity mark appear on materials used to contain/present other information (folders, binders, covers, etc.) the cover should bear the following disclaimer:

o “The enclosed material was prepared and assembled by (name of QIO) under contract with the Centers for Medicare & Medicaid Services (CMS). The contents presented do not necessarily reflect CMS policy.” (TOPS Memo 99-23)

Avoiding Incorrect Uses of the Identity Mark

• Do not alter the position of the identity mark elements.

• Do not alter or change the typeface.

• Do not rotate any of the identity mark elements.

• Do not combine the mark with other elements to create a new mark, symbol, etc.

• Do not stretch, distort, or otherwise alter the aspect ratio of the identity mark.

http://qionet.sdps.org/sdps_memos/sdps_memos_2007/07067gn.htm http://qionet.sdps.org/sdps_memos/sdps_memos_2007/07067gn.htm http://qionet.sdps.org/sdps_memos/sdps_memos_archive/SDPS_memos_99/99-30.pdf http://qionet.sdps.org/sdps_memos/sdps_memos_archive/SDPS_memos_99/99-23.pdf

• Do not position the identity mark too close to other items or images.

• Do not alter the color of any of the identity mark elements.

• Do not position the identity mark on colors that do not compliment the mark’s colors.

• Do not position the identity mark on a photographic background where there is insufficient contrast between the photographic image and the identity mark and typography.

(From the CMS Brand Strategy & Graphics Standard Guide)

Impact Statements: Guidelines QIO impact statements are used to communicate QIO data and attribute improvements demonstrated by the data to the work of the QIO. The statements target external audiences including providers, state legislators, media, stakeholders, and the general public.

Use the following guidelines when developing impact statements:

• Include information that provides context for the QIO Program and the data presented.

• When appropriate, articulate differences between those providers that work with the QIO (such as identified participants) and those that do not.

• Identify data source(s) and methodology(ies) for all data presented.

• Outline specific measurable achievement by setting rather than as a cross-setting aggregate.

• CMS provides specific separate guidance for reporting on the following three topics: lives improved, cost savings, and project impact. Refer to TOPS Memo 2007-01 for each topic.

• Promote activities that are CMS and QIO Program priorities, such as (a) adoption and use of health information technology, (b) beneficiary protection, and (c) other topics that may be identified by CMS.

• QIOs may include local success stories as examples of impact.

• Include a publication number and disclaimer

Please note: None of the data or other content provided by the QIO in impact statements can be used in lieu of the contractual evaluation criteria specified in the SOW contract and its supporting documents to determine eligibility for interim award fees, final award fees, or group award fees or to determine if the QIO has met the SOW contract performance criteria to be eligible to have its contract renewed non-competitively. (TOPS Memo 2007-01) http://www.cms.gov/About-CMS/Agency-Information/CMS-Brand-Identity/Downloads/CMS-Branding-Guidelines.pdf http://qionet.sdps.org/tops_memos/07-01.htm http://qionet.sdps.org/tops_memos/07-01.htm

Success Stories A story can be defined as a narrative designed to interest, amuse or instruct. Yet, when the word “success” is added before the word “story,” expectations of the narrative heighten.

In the case of the QIO Program, success stories can draw attention to the effectiveness of QIO interventions and technical assistance in improving health care for real people. Success stories can inspire other providers or beneficiaries to make similar improvements in health quality or personal health behavior. Well-written success stories can also help readers understand the value of the QIO Program by making it less abstract; they demonstrate its concrete benefits. Often QIOs gather success stories at the point in the contract when meaningful data that can demonstrate success have become available.

A Success Story Toolkit, created by the CRISP NCC, is posted on the CRISP Community of the Collaborative Tool. The toolkit, in addition to defining and explaining, offers several examples, describes applicable policies and provides a success story template. This toolkit and others created by the CRISP NCC are also listed in the “Resources” section of this handbook.

Engaging Patients in Outreach Efforts

Disclosure of Confidential Information Effective January 1, 2013, CMS promulgated new QIO regulations at 42 CFR 480.145 that govern a beneficiary’s right to authorize a QIO to use or disclose a beneficiary’s confidential information, including his or her name3. CMS made these regulatory changes as part of its commitment to patient-centered care: allowing beneficiaries to share their “real-world” experiences can help QIOs demonstrate a compelling need for health care delivery reform. This, along with the fact that Medicare beneficiaries have asked to participate in QIO work in a meaningful way, provided an impetus for revising previous regulations.

As such, QIOs may disclose confidential information about a beneficiary, provided the QIO has that beneficiary’s informed consent, as the term is defined by the Health Insurance Portability and Accountability Act

(HIPAA).

3 This regulation was published as part of the Calendar Year 2013 Outpatient Prospective Payment System (OPPS) final rule, notice CMS-1589-FC.