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RFP-CMS-2015-8A-0101 Amendment Number 2 Clarification of CMS Responses to Industry Questions July 9, 2015

Question #
Section Name
Question Received
CMS Response/Comment
Clarification Question
CMS Clarification Response/Comment
56
C.3; Task 3: Determining Payment Status for LTCH, IRF, and Hospice Quality Reporting Programs; c

Does CMS anticipate eventually housing the reconciled program-collected data in the CMS Clinical Warehouse?

Data is warehoused at CMS, however, in order for the contractor to complete that analysis required, they will need to house the data.

Would CMS clarify if the PII/PHI data from the CMS data warehouses such as QIES is expected to be housed at a contractor facility?

In our experience housing of PII/PHI data requires an Authority to Operate (ATO) from CMS. Please clarify if CMS is requiring an external contractor environment for storing this data?

The contractor will be expected to obtain and store data extracts, which could contain PHI, from claims, QIES or other systems for analysis, monitoring and evaluation. Since the contractor will not be the source of the information, an ATO is not required.

64
C.3; Task 5: Validation of Facilities Quality Data

1. Is the validation of the 500 records annually inclusive of all three programs, or is it 500 per program? 2. How many data elements are abstracted/validated per program type during the validation process? 3. Historically, what is the average time to abstract each data element? 4. How are the validation records selected and requested? Does the contractor need to send out the request for records? 5.

Is the contractor responsible for any reimbursement to the facility for medical record copy and mailing costs? 6. How long does the contractor need to retain and store the medical records that were validated? 7. Is the validation does through an electronic or paper tool?

1. The 500 is the total of the records for all programs reviewed. 2. Currently there are 9-11 data elements and 3-5 administrative elements, however, as measures are added, those numbers could increase. 3. Average time is not currently known. 4. The contractor is not involved in the selection or requesting the records, the records will be delivered via secure electronic media. 5. The contractor is not responsible for any reimbursement. 6.

CMS will have an electronic copy of the medical record, so the contractor need only store the records for the length of the project. 7. The validation is electronic.

Would CMS clarify if the electronic medical records contain PII/PHI and if the contractor is expected to house this data in a contractor environment external to CMS?

Yes, the records contain PHI. The contractor must make the necessary arrangements for housing the data.

69
C.3, Task 7, d
Does CMS anticipate that the program-specific data will be published on Hospital Compare or another public reporting compare site (e.g., Hospice Compare and IRF Compare)? If so, when is the anticipated start date?
CMS has proposed policy for public reporting in both the IRF and LTCH notices of Proposed Rulemaking. During the public comment period, CMS is not able to provide any additional comment.
“CMS has proposed policy for public reporting in both the IRF and LTCH notices of Proposed Rulemaking.” Does CMS have an anticipated date for proposing policy for public reporting in the Hospice Notice of Proposed Rulemaking?
No.
81
C.3, Task 4: Help Desk Support
What is the expected resolution time for a Help Desk ticket or issue?
According to page 11 "Ninety-five percent of public questions shall be answered and submitted to CMS for approval within 5 business days following receipt unless forwarded to another, appropriate party or as otherwise directed; questions that require forwarding to another party shall be forwarded within 5 business days. Problems and significant issues must be reported as soon as possible to the COR."
“According to page 11 ‘Ninety-five percent of public questions shall be answered and submitted to CMS for approval within 5 business days following receipt unless forwarded to another, appropriate party or as otherwise directed; questions that require forwarding to another party shall be forwarded within 5 business days. Problems and significant issues must be reported as soon as possible to the COR.’” How does CMS define “public questions”?
Questions that are submitted by a member of the public, provider, provider’s office or agent.
83
C.3, Task 5: Support for Validation of Facilities Quality Data

What date range will the validation methodologies cover (e.g. prior 6 months or prior year)? Are we validating measures from FY2015 only in year 1 and then progressing to the other years?

Validation methodologies could cover any time period. The contractor should develop and provide statistically valid sampling methodology proposals/options for CMS. The contractor should have expertise in data validation/statistics available for this task.
As per response to question #64, the contractor is not involved in selection of the medical records, would CMS clarify that sampling methodologies for medical records are not required to be proposed in this RFP response?
The contractor will not need to request records; however the contractor is required to propose the sampling methodologies.

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