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CMS
CENTERS FOR MEDICARE & MEDICAID SERVICES
CARRIER/INTERMEDIARY
WORKLOAD CLOSEOUT
HANDBOOK
MEDICARE CONTRACTOR MANAGEMENT GROUP
JUNE 14, 2010
RRB Soliciation RRB11-R-001 – Part B Specialty MAC
TABLE OF CONTENTS
| CHAPTER 1: | INTRODUCTION | 1-1 |
| 1.1 | Carrier/Intermediary Workload Closeout Handbook | 1-1 |
| 1.1.1 | Chapters | 1-1 |
| 1.1.2 | Exhibits | 1-2 |
| 1.1.3 | Index | 1-3 |
| 1.2 | Transition Phases | 1-3 |
| 1.3 | Segment Transitions | 1-4 |
| 1.4 | Terminology | 1-4 |
| 1.5 | Goals of a Successful Workload Transition | 1-5 |
| CHAPTER 2: | CMS ORGANIZATION | 2-1 |
| 2.1 | CMS Contract Administration Personnel – Carrier/Intermediary Contracts | 2-1 |
| 2.1.1 | Carrier/Intermediary Contracting Officer | 2-1 |
| 2.1.2 | Carrier/Intermediary Contractor Manager | 2-1 |
| 2.1.3 | Business Function Lead | 2-1 |
| 2.1.4 | Technical Monitor | 2-2 |
| 2.2 | CMS Contract Administration Personnel – MAC Contracts | 2-2 |
| 2.2.1 | MAC Contracting Officer | 2-2 |
| 2.2.2 | MAC Project Officer | 2-2 |
| 2.2.3 | Implementation Lead (IL) | 2-3 |
| 2.2.4 | Medicare Implementation Support Contractor | 2-3 |
| CHAPTER 3: | GETTING STARTED | 3-1 |
| 3.1 | Award Notification | 3-1 |
| 3.2 | Carrier/Intermediary Contract Notification | 3-1 |
| 3.3 | Public Announcement | 3-1 |
| 3.4 | Initial Contact with Incoming MAC | 3-2 |
| 3.5 | Employee Notification | 3-2 |
| 3.6 | Closeout Project Team | 3-2 |
| 3.7 | Jurisdiction Kickoff | 3-3 |
| 3.7.1 | General | 3-3 |
| 3.7.2 | Outgoing Contractor Pre-Meeting | 3-3 |
| 3.7.3 | MAC Pre-Meeting | 3-4 |
| 3.7.4 | Jurisdiction Kickoff Meeting | 3-5 |
| 3.7.5 | Segment Kickoff Meeting | 3-6 |
| 3.8 | Transition Workgroups | 3-9 |
| 3.8.1 | General | 3-9 |
| 3.8.2 | Participants | 3-9 |
| 3.8.3 | Scope | 3-10 |
| 3.8.4 | Functions | 3-11 |
| 3.8.5 | Administration | 3-12 |
| CHAPTER 4: | PROJECT MANAGEMENT | 4-1 |
| 4.1 | Purpose | 4-1 |
| 4.2 | Project Team Modifications | 4-1 |
| 4.3 | Closeout Project Plan | 4-1 |
| 4.4 | Consultants | 4-2 |
| 4.5 | Interaction with the Incoming Contractor | 4-3 |
| 4.6 | Internal Communications | 4-3 |
| 4.7 | On-Site Presence | 4-3 |
| 4.8 | Nomenclature | 4-4 |
| 4.9 | Waivers | 4-4 |
| 4.10 | Documentation | 4-5 |
| 4.10.1 | Closeout Approach / Inventory Reduction | 4-5 |
| 4.10.2 | Closeout Project Plan (CPP) | 4-5 |
| 4.10.3 | Closeout Project Plan Update | 4-5 |
| 4.10.4 | Closeout Project Status Report | 4-5 |
| 4.10.5 | Workload Report | 4-7 |
| 4.10.6 | Issues Log/Action Items | 4-7 |
| 4.10.7 | Staffing Report | 4-8 |
| 4.10.8 | Asset Inventory | 4-8 |
| 4.10.9 | File Inventory | 4-8 |
| 4.10.10 | File Transfer Plan | 4-8 |
| 4.10.11 | Post-Cutover Activities and Resources | 4-9 |
| 4.10.12 | Lessons Learned | 4-9 |
| 4.11 | Meetings | 4-9 |
| 4.11.1 | Outgoing Contractor Pre-Meeting | 4-10 |
| 4.11.2 | Jurisdiction Kickoff Meeting | 4-10 |
| 4.11.3 | Segment Kickoff Meeting | 4-10 |
| 4.11.4 | Project Status Meetings | 4-11 |
| 4.11.5 | Transition Workgroup Meetings | 4-11 |
| 4.11.6 | Cutover Meeting | 4-12 |
| 4.11.7 | Post-Project Review Meeting (Lessons Learned) | 4-12 |
| CHAPTER 5: | PERSONNEL AND INFRASTRUCTURE | 5-1 |
| 5.1 | Personnel Actions | 5-1 |
| 5.1.1 | Employment Within the Company | 5-1 |
| 5.1.2 | MAC Employment | 5-1 |
| 5.1.3 | Termination | 5-2 |
| 5.2 | Severance Payment | 5-3 |
| 5.3 | Retention Bonus | 5-4 |
| 5.4 | Terminating Subcontracts | 5-5 |
| 5.5 | Licenses | 5-5 |
| 5.6 | Asset Inventory | 5-6 |
| 5.7 | Security Awareness | 5-6 |
| CHAPTER 6: CLOSEOUT OPERATIONS AND PROVIDING INFORMATION/ASSISTANCE | 6-1 | |
| 6.1 | Operational Analysis | 6-1 |
| 6.1.1 | Streamlining Operations | 6-1 |
| 6.1.2 | Workload Assessment | 6-1 |
| 6.1.3 | Contingencies | 6-2 |
| 6.2 | Closeout Approach | 6-2 |
| 6.3 | Access to Information | 6-2 |
| 6.4 | Deliverables | 6-3 |
| 6.5 | Incoming MAC Operational Assessment/Due Diligence | 6-4 |
| 6.5.1 | Initial Assessment | 6-4 |
| 6.5.2 | Areas of Focus | 6-4 |
| 6.5.3 | Specific Assessment Activities | 6-5 |
| 6.5.4 | Functional Area Assessments | 6-8 |
| 6.6 | EDI Assessment | 6-11 |
| 6.6.1 | Early Boarding | 6-12 |
| 6.6.2 | Electronic Funds Transfer | 6-12 |
| 6.7 | Print/Mail Operations | 6-12 |
| 6.8 | File Inventory | 6-13 |
| 6.8.1 | General | 6-13 |
| 6.8.2 | Mainframe Files | 6-13 |
| 6.8.3 | LAN/PC-Based Files | 6-14 |
| 6.8.4 | Hardcopy Files | 6-14 |
| 6.9 | Contract Compliance | 6-14 |
| 6.10 | Assisting MAC Communication Efforts | 6-14 |
| 6.10.1 | General | 6-15 |
| 6.10.2 | Provider Communication | 6-15 |
| 6.10.3 | Beneficiary Communication | 6-16 |
| CHAPTER 7: | CUTOVER AND POST-CUTOVER ACTIVITIES | 7-1 |
| 7.1 | Definitions | 7-1 |
| 7.2 | Cutover Plan | 7-1 |
| 7.3 | Cutover Workgroup | 7-2 |
| 7.4 | Daily Cutover Meeting | 7-3 |
| 7.5 | “Go/No Go” Call | 7-4 |
| 7.6 | Cutover Simulation | 7-4 |
| 7.7 | System Dark Days | 7-5 |
| 7.8 | Release of the Payment Floor | 7-6 |
| 7.9 | Payment Cycles | 7-7 |
| 7.10 | Data Migration | 7-8 |
| 7.10.1 | Final Inventory | 7-8 |
| 7.10.2 | File Transfer Plan | 7-8 |
| 7.10.3 | File Format | 7-9 |
| 7.10.4 | Encryption | 7-9 |
| 7.10.5 | Packing | 7-10 |
| 7.10.6 | Transfer of Hardcopy Files and Physical Assets | 7-10 |
| 7.10.7 | Disposition | 7-11 |
| 7.11 | Sequence of System Cutover Activities | 7-11 |
| 7.11.1 | System Closeout | 7-11 |
| 7.11.2 | Back Up | 7-11 |
| 7.11.3 | Transfer and Installation | 7-11 |
| 7.11.4 | Data Conversion | 7-12 |
| 7.11.5 | Initial System Checkout | 7-12 |
| 7.11.6 | Functional Validation of System | 7-12 |
| 7.11.7 | First MAC Production Cycle | 7-12 |
| 7.12 | Cutover Communication | 7-12 |
| 7.13 | Post-Cutover Activities | 7-13 |
| 7.13.1 | Post-Cutover Approach and Resources | 7-13 |
| 7.13.2 | Operations Wrap-up | 7-14 |
| 7.13.3 | Reporting Activities | 7-14 |
| 7.13.4 | Employee Access to CMS Systems | 7-15 |
| 7.13.5 | Contractor Access to Files and Records after Cutover | 7-16 |
| 7.13.6 | Closeout Assessment Review Process | 7-16 |
| 7.13.7 | Lessons Learned | 7-16 |
| 7.13.8 | Post-Project Review | 7-17 |
| CHAPTER 8: | FINANCIAL PROCESSES | 8-1 |
| 8.1 | General | 8-1 |
| 8.2 | Transition Costs | 8-1 |
| 8.3 | Transition Supplemental Budget Request | 8-3 |
| 8.4 | Termination Costs | 8-3 |
| 8.5 | Accounts Receivable Reconciliation | 8-5 |
| 8.5.1 | General | 8-5 |
| 8.5.2 | Accounts Receivable Reconciliation Process | 8-5 |
| 8.5.3 | Financial Reporting | 8-6 |
| 8.6 | Bank Accounts and Reports | 8-6 |
| 8.7 | Financial Coordination with the MAC | 8-7 |
| 8.7.1 | Outstanding Provider Payment Checks | 8-7 |
| 8.7.2 | Cash Receipts/Cash Refunds | 8-7 |
| 8.8 | PSOR/POR Reconciliation | 8-8 |
| 8.9 | Audits and Other Issues | 8-9 |
| 8.10 | 1099 Responsibilities | 8-10 |
| LIST OF EXHIBITS | 1 |
Carrier/Intermediary Workload Closeout Handbook 06/14/10
INTRODUCTION
Carrier/Intermediary Workload Closeout Handbook
This handbook was prepared by CMS to assist carriers and fiscal intermediaries in moving Medicare data, records, and operational activities to Medicare Administrative Contractors (MACs). It contains a compilation of best practices, lessons learned, and over 25 years of CMS experience in overseeing Medicare workload transitions. The handbook describes the basic responsibilities and processes required by the carrier or intermediary to close out its Medicare contract activities and to assist the incoming MAC in its efforts to assume Medicare claims administration functions. While both the carrier/intermediary and the incoming MAC are responsible for accomplishing various activities during the transition, this handbook is intended for use by the departing carrier/intermediary. A similar MAC Workload Implementation Handbook has been developed for incoming Medicare Administrative Contractors.
Every Medicare workload transition will vary depending on the unique circumstances and environment of the Medicare contractors involved. There may be activities and processes described in the handbook that will not be applicable to a specific transition. There may also be activities that will need to be performed that the handbook does not cover. The handbook cannot identify and address all of the variations that may occur during a workload transition, nor all of the tasks for which the outgoing contractor will be responsible. However, it will provide the framework for a successful workload closeout and guidance in addressing situations as they arise.
It should be noted that this handbook is written from the perspective of a carrier/ intermediary who is leaving the Medicare program. Not all of the activities described in the handbook will be applicable to a carrier/intermediary who will continue to process Medicare claims under other contracts. The handbook may also be of value to a Medicare contractor who may be moving just a portion of its workload to another contractor (e.g., out-of-jurisdiction providers), since many of the processes will be applicable, albeit on a smaller scale.
This June 14, 2010 version of the Carrier/Intermediary Workload Closeout Handbook is comprised of 8 chapters, 13 exhibits, and an index. It supersedes all other versions.
Chapters
1. Chapter 1: Introduction provides an introduction to the Handbook and the goals for a successful workload transition.
2. Chapter 2: CMS Organization provides information on the duties and responsibilities of CMS’s transition oversight staff.
3. Chapter 3: Getting Started describes the activities that are necessary to start the workload closeout process. It discusses establishment of the closeout project team, project kickoff meetings, and the organization and function of transition workgroups. The chapter also addresses initial notification activities.
| 4. | Chapter 4: Project Management discusses the various tasks necessary to manage the closeout process. This includes developing the Closeout Project Plan, the use of consultants, interaction with the incoming MAC, communications, and meeting and reporting requirements. |
| 5. | Chapter 5: Personnel and Infrastructure provides information on personnel issues and CMS policy on retention bonuses and severance pay. It also discusses policy on terminating subcontracts, asset inventory and disposition, and security. |
| 6. | Chapter 6: Closeout Operations and Providing Information/Assistance deals with the approach that a carrier/intermediary may take for its closeout operations and the type of information that should be provided to assist the MAC in its implementation. It discusses the MAC’s due diligence activities , deliverables, file transfer activities, and assisting the MAC’s communication efforts. |
| 7. | Chapter 7: Cutover and Post-Cutover Activities covers the activities associated with final preparations for the operational closeout and the migration of records, files, and data (both physically and electronically). In addition, the chapter provides information on cutover plans, system dark days, lessons learned, and post-cutover reporting. |
| 8. | Chapter 8: Financial Processes provides information on the development of closeout costs and the financial activities required to move the Medicare workload. It discusses the development of transition and termination costs, financial reporting, banking activities, the accounts receivable reconciliation, audits, and 1099 responsibilities. |
Exhibits Exhibit 1 Transition Phases and Terminology
Exhibit 2 MAC Contract Administrative Structure
Exhibit 3 Financial Information for Outgoing Contactors
Exhibit 4 Sample Closeout Project Plan
Exhibit 5 Outgoing Contractor Information/Documentation
Exhibit 6 Files to be Transferred to a Medicare Administrative Contractor
Exhibit 7 Workload Transition Meeting and Documentation Guide
Exhibit 8 Sample Workload Report
Exhibit 9 Sample Staffing Report
Exhibit 10 Sample Financial Closeout Memorandum
Exhibit 11 Workload Transition Lessons Learned—January 2010
Exhibit 12 Glossary
Exhibit 13 Acronyms
Index The index is found at the end of the handbook.
Transition Phases
While there are multiple parties involved in a Medicare workload transition, there are three major participants: the incoming contractor (MAC), the outgoing contractor (carrier or intermediary) and CMS. Each transition has three major phases. For an outgoing contractor, the three phases of a workload transition are identified as: operations (normal Medicare activities prior to the award of a MAC contract), closeout, and post-cutover.
Transition activities in the operations phase are generally not extensive and are largely dependent upon whether or not the carrier/intermediary submitted a proposal for the jurisdiction in which it resides. If a proposal was submitted, there would not be significant transition activity and normal Medicare operations would continue until the MAC contract was announced. However, if the carrier/intermediary did not submit a proposal for its jurisdiction, then it may take some initial steps described in this handbook to prepare for the closeout phase.
The closeout phase begins at contract award of the MAC jurisdiction and ends at the carrier/intermediary’s operational cutover to the new MAC. During this time the carrier/intermediary works with the incoming MAC to transfer Medicare data, records, and functions and to shut down its Medicare operation.
The post-cutover phase begins at the cutover and normally continues for several months. This is the period when the carrier/intermediary closes out the financial and reporting aspects of its contract.
While this handbook provides information for all three phases, its focus is on the closeout and post-contract phases of the carrier/intermediary’s transition. Exhibit 1, Transition Phases and Terminology, provides a graphic representation of terminology used for the major transition participants.
Segment Transitions
In a MAC transition, a carrier or intermediary’s workload is known as a “segment”. Each segment transition involves the movement of all or part of a carrier or intermediary’s Medicare data, files, and functions to the MAC. The establishment of a fully operational MAC jurisdiction will involve multiple segment transitions, the number of which will depend on the number of carriers and intermediaries that currently serve the states within the jurisdiction. The length of the segment implementations and sequence of individual segment implementations will be identified in the MAC’s Jurisdiction Implementation Project Plan, which will be approved by CMS. Segment implementation periods can range from 3-8 months, depending on the size of the outgoing contractor and various other factors; however, most are 5-6 months in length.
The incoming MAC will begin to perform Medicare functions after its first segment implementation has been completed. As each subsequent segment implementation of the MAC jurisdiction is completed, the MAC’s Medicare administrative responsibilities will expand over a wider area of its jurisdiction until the cutover of the last segment in the jurisdiction occurs. At that time, the MAC will be fully operational in all states within its jurisdiction.
Terminology
For purposes of this handbook, the term “outgoing contractor” refers to a carrier or fiscal intermediary (or simply intermediary) that is performing Medicare claims processing functions under a Part A agreement, Part A Plan subcontract agreement with the Blue Cross and Blue Shield Association (BCBSA) or a Part B contract. These contractors are also known as “legacy contractors.” The terms “outgoing contractor”, “carrier/ intermediary”, and “legacy contractor” are used interchangeably throughout this handbook. Legacy contractors may also be referred to as “Title XVIII contractors,” but this term should be avoided because the MAC contracts are also entered into under Title XVIII of the Social Security Act. The term “Medicare claims processor” refers to any entity that processes Medicare claims; i.e., a carrier, intermediary, or MAC.
The Medicare Administrative Contractor (MAC) who will be assuming the Medicare functions of the outgoing carrier or intermediary is referred to as the “incoming contractor.” Both “MAC” and “incoming contractor” are used interchangeably.
A “transition” is defined as the period of time that encompasses the movement of Medicare functions and workload from a carrier/intermediary to a MAC. The term “implementation” is used for those activities performed by the incoming MAC during a transition. The term “closeout” is used for those activities performed by the outgoing carrier or intermediary. However, in general usage, the term “transition” will often be applied to the “closeout” activities performed by the carrier/intermediary as well as the “implementation” activities performed by the incoming MAC.
The term “provider” is used in the broad sense of the word, meaning anyone providing a Medicare service; i.e., institutional provider (hospital, skilled nursing facility, rural health clinic, federally qualified health center, or home health agency), physician, non-physician practitioner, or supplier.
The term “contract” is used in a generic sense and refers to the Title XVIII Part B carrier contract or the Title XVIII Part A Plan subcontract agreement with BCBSA.
The term “biweekly” means every two weeks.
Goals of a Successful Workload Transition
All of the organizations involved in a workload transition have a responsibility to ensure that the transition is conducted properly and that their contractual obligations are met. While each participant has different roles and responsibilities during a transition, the goals remain the same:
· There is minimal disruption to beneficiaries;
· There is minimal disruption to providers, physicians and suppliers;
· There is no disruption of claims processing and Medicare operations;
· The transition is completed on schedule within the required time period;
· Actual costs represent effective and efficient use of resources; and,
· All parties with an interest in the transition (whether direct or indirect) are kept informed of the transition’s status and progress.
In order to accomplish these goals, there must be proper project planning and management by the Medicare Administrative Contractor, maintenance of existing Medicare operations by the outgoing carrier or intermediary, and comprehensive oversight by CMS. All parties involved in the transition must cooperate fully and communicate constantly with all other parties at every level. This handbook will help the carrier/intermediary achieve the above-mentioned transition goals and meet its contractual obligations as it closes out its Medicare operations and contract.
Chapter 1: Introduction
CMS ORGANIZATION
CMS will have a number of individuals responsible for overseeing the closeout activities of the carrier/intermediary and the implementation activities of the incoming MAC. Listed below are the individuals that the carrier/intermediary will have ongoing contact with regarding its closeout work, along with a description of their responsibilities. Also discussed are the individuals who will be responsible for monitoring the incoming MAC’s implementation. A CMS administrative organizational chart for the MAC contracts is shown in Exhibit 2, MAC Contract Administrative Structure.
CMS Contract Administration Personnel – Carrier/Intermediary Contracts
The following are the key CMS individuals (along with the Implementation Lead discussed in Chapter 2.2.3) who will monitor the closeout activities of the outgoing carrier/intermediary.
Carrier/Intermediary Contracting Officer The carrier/intermediary Contracting Officer (CO) has the administrative responsibility for the outgoing contractor’s Title XVIII Medicare contract. The CO has overall responsibility for the carrier/intermediary’s activities involving the transfer of Medicare data, files, and operations to the incoming MAC and the activities associated with the closeout of its Medicare contract.
Carrier/Intermediary Contractor Manager The Contractor Manager (CM) is the CMS individual responsible for monitoring the day-to-day operational activities of the outgoing carrier/intermediary. He/she will be responsible for ensuring that the carrier/intermediary continues to maintain its overall operation and performance during the closeout period. The Contractor Manager will work closely with the CMS Implementation Lead (see Chapter 2.2.3 below) to ensure that the carrier/intermediary cooperates with the incoming MAC during the transition and that all Medicare data, records, and files are successfully transferred to the MAC.
Business Function Lead A Business Function Lead (BFL) may be called upon to assist either the outgoing Contractor Manager or the incoming MAC Project Officer, depending on the transition activity. BFLs are normally located in CMS Central Office and will assist the Contractor Manager/Project Officer in the administration of the carrier/intermediary and MAC contracts on an as needed basis. The BFL acts as the technical representative for their specific business function within the Medicare claims processor contracts. They will assist the Contractor Manager/PO with specific functional inquires and technical issues. They may also monitor technical progress, analyze deliverables, and perform technical evaluations and inspections. In addition, BFLs will review monthly invoices and vouchers pertaining to their functional area and make payment recommendations to the PO. BFLs do not have the authority to provide technical direction or make any contractual commitments or changes on behalf of CMS.
Technical Monitor Technical Monitors (TMs) may be designated to work with the BFL and/or the Contractor Manager/Project Officer on an as needed basis to monitor and evaluate specific activities within an overall functional area. TMs are Regional Office personnel who may provide information on contractor performance and help the Contractor Manager or Project Officer resolve issues, particularly those from beneficiaries and providers. The TM may assist the BFL in performing technical evaluations and inspections and may also provide input to monthly and quarterly contract administration meetings. In addition, Technical Monitors may perform the on-site validations of the outgoing carrier/intermediary’s accounts receivables reconciliation for the workload that will be transferred to the incoming MAC.
CMS Contract Administration Personnel – MAC Contracts
The following individuals will be responsible for monitoring the implementation and/or operational activities of the incoming MAC. They will also interact with the carrier/intermediary in various meetings and workgroups.
MAC Contracting Officer The MAC Contracting Officer (CO) has the overall responsibility for the incoming MAC and is the only person authorized to enter into and bind the government by contract. He/she is the individual that negotiates and prepares the MAC contract document, modifies any terms or conditions of the contract, accepts delivered services, and approves vouchers for payment.
MAC Project Officer The MAC Project Officer (PO) serves as the first point of contact for the incoming MAC. He/she is the focal point for the exchange of information and the receipt of programmatic approvals on deliverables and other work under the MAC contract. The PO is the technical representative of the MAC Contracting Officer and provides technical direction to the MAC, as necessary, for all of the business functions contained in the MAC statement of work. He/she also monitors the contract performance of the MAC and reviews payment vouchers. The PO may designate various business function leads (BFLs) and technical monitors (TMs) to support the administration of the MAC contract. The Project Officer position is also known as the Contracting Officer’s Technical Representative (COTR).
Implementation Lead (IL) The Implementation Lead (IL) will be the incoming Project Officer’s representative for the incoming MAC’s implementation and will serve in a specialized technical capacity to the PO. As a representative of the incoming PO, the IL will provide technical guidance and direction on implementation activities to the incoming MAC. The IL will manage CMS’s oversight of the transition and will coordinate incoming MAC implementation activities with the carrier/intermediary Contractor Manager and the functional contractors’ Project Officers. The Implementation Lead will also work with the Medicare Implementation Support Contractor (MISC) to monitor and oversee the progress of the incoming MAC’s implementation and the related activities of the functional contractors involved in the transition. He/she will also resolve issues involving the various segment transitions within the jurisdiction.
The IL will work with Business Function Leads (BFLs) or Technical Monitors (TMs) concerning implementation issues. He/she will also coordinate implementation activities with the Project Officers of the functional contractors involved in the MAC implementation. The Implementation Lead will conduct problem solving/trouble shooting during the transition and be responsible for reporting to senior management. In addition, he/she will review vouchers for jurisdiction implementation activities and provide recommendations to the incoming Project Officer and the MISC Government Task Leader, if requested.
Medicare Implementation Support Contractor Because of the number of implementations and the limited staff available for oversight, CMS has entered into a contract with Chickasaw Nation Industries (CNI) for a Medicare Implementation Support Contractor (MISC). The MISC will provide the project management support and the oversight services needed by CMS to monitor the implementation activities of the MACs and functional contractors.
The MISC will assign a business analyst (BA) assigned to each implementation. The business analyst’s primary responsibility will be the segment implementations. The Medicare Implementation Support Contractor will have direct access and interaction with the MAC and will also interact with the outgoing contractor staff involved in the implementation. The BA will be a member of transition workgroups and attend all meetings associated with those workgroups. He/she will also attend general jurisdiction status meetings and teleconferences. The BA will work closely with the Implementation Lead and will be the point person for segment implementation activities.
The MISC will share comments, concerns, and recommendations directly with the incoming MAC when appropriate. However, the MISC does not have authority to provide technical direction to the carrier/intermediary or MAC.
Chapter 2: CMS Organization
GETTING STARTED
Award Notification
The CMS Contracting Officer will contact each of the carriers and intermediaries within a MAC jurisdiction immediately after the MAC is informed of its contract award for that jurisdiction. This will begin the closeout phase of the carrier/intermediary’s transition. If the carrier/intermediary has been awarded the MAC contract there should be relatively few workload closeout activities that will need to be performed. The extent of those activities will be dependent upon the MAC statement of work requirements of the new contract. However, there will always be some closeout activities to be performed, generally in the financial area and contract closeout.
If the carrier/intermediary was not awarded the MAC contract, then additional closeout activities will commence. The CO will discuss the general aspects of the incoming MAC’s proposal and the transition schedule. The CO will provide the carrier/ intermediary with the MAC’s proposed implementation timeline and determine if there are any initial problems with the schedule. The anticipated ending date of the contract will be provided, and the CO will discuss upcoming activities, the jurisdiction and segment kickoff meetings, and CMS expectations for the transition. The CO will also provide any information regarding the MAC’s proposal for utilizing any carrier/ intermediary personnel should they be available for employment after contract end.
Carrier/Intermediary Contract Notification
After the MAC award has been made, the CO will provide official contract notification that CMS (or the Blue Cross and Blue Shield Association if the outgoing contractor is a Blue Cross Plan) is either terminating or non-renewing the carrier/ intermediary’s Medicare contract or Plan agreement. There will also be an initial discussion about the financial requirements for transition and termination costs. The CO will request that the carrier/intermediary begin to prepare a budget for those costs. See Chapter 8, Financial Processes.
CMS will also send the carrier/intermediary a letter requesting a copy of current personnel policies, including severance and related payments. The letter will include information on transition and termination costs and CMS’ policy on retention bonuses and severance pay. See Exhibit 3, Financial Information for Outgoing Contractors.
Public Announcement
CMS may issue a press release regarding the award of the MAC jurisdiction contract. The carrier/intermediary may also wish to issue a press release regarding the cessation of its Medicare claims processing operation in the jurisdiction. The announcement should include assurances that the outgoing contractor will work closely with the incoming MAC during the transition to insure that service to Medicare beneficiaries and providers will not be disrupted. Any press notification should be reviewed by CMS prior to release.
Initial Contact with Incoming MAC
After CMS has publicly announced the contract award and implementation schedule, the incoming MAC will be placing calls to the carriers and intermediaries within its jurisdiction. These contact calls will normally be made by upper management and will serve as an introduction to the new MAC. The MAC’s proposal may be discussed in general terms, especially if the MAC has interest in the outgoing contractor’s staff and/or facilities. Other areas of discussion may include communication, commitment of the organizations, the transition schedule, and any immediate problems or issues that need to be addressed before the kickoff meeting.
Employee Notification
After the carrier/intermediary is aware of the general provisions of the MAC’s proposal, it should schedule a meeting with all of its affected Medicare employees. The purpose of this meeting is to provide information about the transition and to inform employees about the status of their jobs.
If the MAC has indicated that it would like to hire some or all of the outgoing contractor’s staff, employees should be provided with as much information as is known about the MAC’s intentions. Employees should also be informed about any jobs that may be offered in other Medicare or non-Medicare areas of the carrier/intermediary’s organization. Should jobs not be available in other areas, or if employees will not have jobs offered to them by the new contractor, information on severance pay, retention bonuses, outplacement services, and other corporate benefits should be provided as soon as possible.
Closeout Project Team
The outgoing contractor will need to form a project team that will be responsible for closeout activities. The team’s purpose is twofold: 1) to work directly with the MAC to accomplish the orderly transfer of Medicare data, records, and functions to the MAC; and 2) if the carrier/intermediary will not be continuing as a Medicare contractor, take the necessary steps to close out its Medicare contract. The team should be comprised of a Closeout Project Manager and experienced personnel representing the various functional areas of the carrier/intermediary’s Medicare operation. Closeout team staff will be assigned to participate in the transition workgroups that will be formed (see Section 3.8).
Once assignments have been made, an internal meeting with all team members should be held in order to plan and prepare for the closeout and upcoming kickoff meetings. An organization chart and contact list should be developed. Initial discussion should also take place regarding the development of the carrier/intermediary’s Closeout Project Plan. In addition, administrative details and procedures for meetings and communications should be finalized.
Jurisdiction Kickoff
The jurisdiction kickoff represents the formal start of the process of moving the outgoing carrier/intermediary’s Medicare data, files, and operations to the incoming MAC.
General Jurisdiction kickoff is composed of 3-5 separate meetings conducted over a several day period. Jurisdiction kickoff is intended for all parties involved in any of the segment transitions that will occur within the jurisdiction, but not all parties will attend every meeting. There will be a minimum of three meetings held at kickoff: the incoming MAC pre-meeting, the outgoing carrier/intermediary pre-meeting, and the general jurisdiction kickoff meeting. Kickoff may also include a segment kickoff meeting if a segment implementation is scheduled to begin at contract award. In addition, the post-award orientation conference conducted by the incoming MAC Contracting Officer may be held as part of the kickoff if it has not already been held. The outgoing contractor will only need to attend the outgoing contractor pre-meeting and the general jurisdiction kickoff meeting. It will also attend the segment kickoff meeting if one is scheduled and it pertains to the carrier/intermediary’s segment.
Jurisdiction kickoff is generally held within 30 days of contract award. The meetings will normally be held in the Baltimore, Maryland metropolitan area, unless CMS determines that another location would be more appropriate. The MAC will be responsible for providing facilities for all of the jurisdiction kickoff meetings that will take place, providing toll-free phone lines for off-site participants, developing an agenda (with input from other participants), and notifying potential attendees. In the unlikely event that the meetings are held at a CMS facility, then CMS would be responsible for the facilities and telecommunications. Meeting minutes and an attendance sheet/contact list shall be prepared by the MAC and sent to all those in attendance. Normally, each of the jurisdiction kickoff meetings can be completed in a half day (3-4 hours of concentrated meeting time).
Outgoing Contractor Pre-Meeting This meeting is conducted by CMS with the outgoing contractor and is normally held prior to the general jurisdiction kickoff meeting. Since the outgoing contractor will be present to attend the jurisdiction kickoff meeting, the pre-meeting provides an opportunity for CMS to discuss topics of importance related to a contractor leaving the Medicare program or losing a portion of its workload. The meeting could be conducted with all outgoing contractors or there could be individual meetings with each carrier and intermediary. The meeting will be conducted by the CMS legacy contractor Contracting Officer and attended by the CMS Contractor Manager, and various CMS transition staff.
Topics for discussion include:
· Anticipated transition schedule, possible modifications based on legacy contractor’s circumstances, and cutover date;
· Possible employment of carrier/intermediary employees by incoming MAC;
· Transition/termination cost policy and advanced agreements;
· Staffing issues and incentive pay/retention bonus/severance pay policy (contractor-specific discussions could be held if there are individual carrier/intermediary meetings);
· Operational issues;
· Development of a Closeout Project Plan;
· CMS project reporting and meeting requirements;
· Medicare Implementation Support Contractor (MISC);
· CMS Workload Closeout Handbook;
· Waiver policy;
· Performance of contractual obligations; e.g., completion of audits;
· Workgroups and legacy contractor representation;
· Accounts receivable review;
· Workload reduction plans;
· Deliverables list from incoming MAC;
· Incoming MAC due diligence/on-site visits;
· Disposition of assets;
· File storage and transfer procedures;
· Lessons learned from previous MAC transitions;
· Post-cutover financial and workload reporting; and
· Areas of immediate focus: communications/provider relations, operational continuity, asset inventory, file transfer, cutover, etc.
MAC Pre-Meeting The MAC pre-meeting is conducted by CMS with the incoming MAC. The Medicare Implementation Support Contractor (MISC) is also in attendance. The meeting deals with information that pertains exclusively or primarily to the incoming contractor and will be held before the general jurisdiction kickoff meeting. The meeting will review the project schedule and cutover, discuss issues that have arisen since contract award, emphasize CMS’s expectations and administrative requirements for the project, and make final preparations for the conduct of the jurisdiction kickoff meeting.
Jurisdiction Kickoff Meeting While the other kickoff meetings will have limited audiences, the jurisdiction kickoff meeting is intended for all parties involved in any of the segment transitions that will occur. This meeting is sometimes referred to as the general kickoff meeting.
Purpose
The purpose of the jurisdiction kickoff meeting is to understand, organize, and coordinate activities among all parties involved in the transition. It provides the opportunity for all parties to meet face-to-face to discuss the approach to the MAC jurisdiction transition, go over the schedule, review roles and responsibilities, and address any concerns about the upcoming segment transitions. While there may be some detailed technical discussion, the meeting is not intended to be at the level that would require all of the individuals assigned to the various transition workgroups in which the carrier/intermediary will participate; those individuals would be expected to attend the segment kickoff meeting. Normally, the Closeout Project Manager and a limited number of closeout project team members, such as the IT lead, would attend the jurisdiction kickoff meeting.
Participants
All parties directly involved in the jurisdiction transition will be invited to attend the jurisdiction kickoff meeting. This includes CMS, the MISC, appropriate incoming MAC personnel, the outgoing carriers and intermediaries, the Blue Cross and Blue Shield Association (for fiscal intermediaries with Plan agreements), applicable data centers, any front-end contractor, shared system maintainers, and functional contractors such as the Program Safeguard Contractor (PSC), Qualified Independent Contractor (QIC), and the Beneficiary Call Center (BCC). Attendance may be in person or via teleconference. Toll-free teleconference lines will be available for individuals or organizations that cannot attend in person. CMS will work with the incoming MAC to develop the list of individuals/organizations that should be invited to the meeting.
Topics of Discussion
The jurisdiction kickoff meeting will give a high level overview of the transition project.
It will also address transition issues that may need immediate attention, such as human resources, connectivity, provider communications, and file transfer/storage. The MAC will be requested to make a corporate introduction, describe its Medicare organization, and discuss its implementation team and structure. The MAC’s Jurisdiction Implementation Plan (JIPP) will be distributed and an overview of the plan will be presented. The outgoing carrier/intermediary will make a similar presentation regarding its organization, Closeout Project Plan, and transition team structure. The MAC may ask the carrier/intermediary to provide an overview of any pilot projects, unique workloads or working relationships they may have with other entities. Other entities involved in the project may also be asked to provide an overview of their transition activities and interactions with the MAC. In addition, CMS will discuss its implementation expectations, review reporting and meeting requirements (Chapters 4.10 and 4.11), and present its transition team organization.
It is critical that the incoming MAC and the carrier/intermediary coordinate their project plans to ensure that all transition tasks are covered, responsibility is acknowledged, and that there are no date or task schedule conflicts.
The MAC’s due diligence review of the outgoing carrier/intermediary will be discussed, as will the deliverables that are being requested from the outgoing contractors. Proprietary issues regarding the MAC’s interaction with the outgoing carriers/ intermediaries should also be addressed. The incoming MAC may have developed a preliminary Deliverables List that will be distributed to the outgoing contractors. The Deliverables List will serve as documentation for all of the information the incoming MAC is requesting from the carrier/intermediary in order to facilitate the transfer of the Medicare workload (see Chapter 6.4). The coordination of communication activities will also be discussed.
Transition workgroups will be a key topic of discussion at the meeting (see Chapter 3.8). The MAC will work with the outgoing contractors and other attendees to establish jurisdiction-wide transition workgroups and agree on their basic responsibilities. These jurisdiction-wide workgroups and their functions should be in place for the entire jurisdiction implementation. However, in a number of transitions, some or all of the workgroups and their remaining activities have been consolidated into the cutover workgroup when the cutover period gets underway. This expanded cutover workgroup then addresses all remaining issues and tasks as the workgroup coordinates the remaining cutover activities.
All outgoing contractors involved in the transition will have to structure their closeout activities utilizing the appropriate workgroups. Therefore, it is critical that agreement be reached with all of the outgoing contractors as to what workgroups will be established and the major responsibilities for each. The incoming MAC will request a workgroup contact list (name, telephone number, e-mail address, office location, etc.) from the outgoing carrier/intermediary and any other organization that will have membership in a transition workgroup.
Any deliverable, action item, or issues log that is developed or added to an existing document as a result of the kickoff meetings will be distributed to the outgoing contractor as soon as possible. After all of the jurisdiction kickoff meetings are completed, the carrier/intermediary should review its Closeout Project Plan and schedule, and make any appropriate revisions based on the discussions that took place.
Segment Kickoff Meeting The segment kickoff meeting may or may not be a part of the jurisdiction kickoff. If it is, it will represent the formal start of the process of moving Medicare data, records, and operations from an outgoing carrier or intermediary to the MAC. It will be similar to the jurisdictional kickoff meeting in concept, but will be focused on the detailed technical and functional activities required for a specific segment transition.
Purpose
The segment kickoff meeting allows all parties involved in a segment transition to meet face-to-face to review the project expectations, discuss roles and responsibilities, and to organize and coordinate activities. The meeting will also help ensure that there is agreement among all participants regarding the tasks involved, project assumptions, and schedule. In addition, any segment-specific emerging issues and/or changes that have occurred since contract award will be discussed, as will any lessons learned from prior segment transitions within the jurisdiction or other jurisdictions. Organizations that cannot attend in person may do so by teleconference.
Preparation
The MAC will be responsible for setting up the kickoff meeting for each segment implementation within its jurisdiction and shall consult with CMS regarding the time and location of such meetings. Generally, the meetings will be held at the proposed operational site, corporate headquarters of the MAC, or by teleconference.
The first segment kickoff meeting(s) normally will be held as part of jurisdiction kickoff, but there may be circumstances that dictate that the meeting(s) be held at a later time. The kickoff meetings for segments that will begin after the first round of segment kickoff meetings should take place within 10 days of the scheduled start date of that segment implementation.
All MACs will have to conduct multiple segment implementations in order to become fully operational. It is possible that there will be more than one segment implementation starting in the same month. If this occurs, the MAC will coordinate the scheduling of the kickoff meetings with CMS and the outgoing contractors of the segments. Normally, each segment implementation will require its own kickoff meeting; however, it is possible that the integration of segments in the project plan would allow for one kickoff meeting to cover multiple segment implementations. If there is HIGLAS involvement in the segment, there will normally be a HIGLAS kickoff meeting that will occur relatively close to the segment kickoff meeting.
The MAC will be responsible for setting up the facilities for the segment kickoff meeting, providing toll-free phone lines for off-site participants, developing an agenda (with CMS input), and notifying attendees. Meeting minutes and an attendance/contact list shall be prepared by the MAC and sent to all those in attendance.
Participants
All parties directly involved in the segment transition will be invited to attend: CMS (including the Medicare Implementation Support Contractor), appropriate technical and operational MAC personnel, the outgoing carrier/intermediary for the segment, representatives from the applicable data center(s), shared system maintainers, the Blue Cross and Blue Shield Association (for fiscal intermediaries with Plan agreements), any front-end contractor, IT services companies, and functional contractors (e.g., PSC, QIC, BCC). Attendance may be in person or via teleconference. Key members of the carrier/intermediary’s closeout project team should be in attendance including anticipated workgroup members.
Since detailed information and operational procedures may be discussed, attendance at the segment kickoff meetings should include more technical and functional experts than necessarily would be in attendance at the jurisdiction kickoff meeting. The outgoing contractor must have representatives present with the authority to establish project commitments and approvals on behalf of the organization.
Topics of Discussion
The MAC will be requested to make a corporate introduction, describe its Medicare organization, and discuss its implementation team and structure. This presentation would be similar to the one made at the jurisdiction kickoff meeting, but geared to the specific segment implementation. The Segment Implementation Project Plan (SIPP) should be distributed and an overview of the plan and the MAC’s implementation approach provided. Input from attendees will be used by the MAC to prepare the “baseline” SIPP that will be submitted to CMS within 30 days of the meeting.
The outgoing contractor will make a presentation regarding its organization, closeout plan, and project team. The carrier/intermediary should also discuss any pilot projects, unique working relationships or workloads, and situations where there are processing regions and files contain commingled data for states in multiple jurisdictions. Other involved parties will provide an overview of their activities and participation in the transition. CMS will discuss its transition organization and team and review reporting requirements (see Chapters 4.10 and 4.11). The meeting should also cover areas of the transition that need immediate attention, such as human resources, connectivity, and industry/provider communications.
The jurisdiction kickoff meeting will have already established the individual transition workgroups and the scope of their functions. During the segment kickoff meeting, there should be breakout sessions of the various workgroups with as many members as possible. If there are not enough workgroup members available, a date and time should be agreed upon for the group to initially meet and organize.
The breakout session will provide the opportunity for workgroup members to begin brainstorming, discuss transition strategy, and address any immediate issues. The group should also review implementation documents such as the JIPP and SIPP, deliverables that have been requested, dependencies, and any action items already identified in order to better define and develop the direction of the workgroup. Members should also discuss methods for accomplishing their workgroup tasks. The group should try to reach agreement on administrative details such as each organization’s designated points of contact and workgroup meeting/teleconference dates and times, if possible.
After the meeting, the carrier/intermediary should review its Closeout Project Plan and schedule to make any appropriate revisions based on the discussions that took place during the meeting. The MAC will distribute any Deliverables List, action item list or problem/issue log that is developed. The Deliverables List will serve as documentation of the information the MAC is requesting from the outgoing contractor in order to facilitate the transfer of the Medicare workload (see Chapter 6.4).
Transition Workgroups
Transition workgroups are the basic organizational structure for conducting the day-to-day activities of the transition. They have proven to be the key to a successful workload transition.
General Transition workgroups are established to facilitate the process of transferring the outgoing contractor’s Medicare workload to the MAC. The scope of a particular workgroup may vary from one workload transition to another for a variety of reasons, including the MAC’s business structure, the jurisdiction project plan/approach, and outgoing contractor considerations. However, agreement must be reached with all of the outgoing contractors and the MAC regarding what workgroups will be established jurisdiction-wide and what their specific responsibilities will be. Workgroups are generally established for infrastructure activities (facilities, hardware, human resources, telecommunications, etc.), functional program areas (MSP, audit and reimbursement, medical review, etc.), and overall project administration tasks (project management, financial, etc.).
Since there could be a number of segment implementations occurring simultaneously, the MAC may find that it is necessary to have separate segment workgroups established within the overall jurisdiction-wide workgroup. Functional areas such as MSP, MR, or communications may have individual workgroups established for each segment implementation within the jurisdiction. If there are separate segment workgroups, the overall workgroup head must coordinate the activities of each to ensure consistency and schedule compliance.
Participants Experienced staff from the MAC, the outgoing contractor, and other involved organizations will be assigned to the various workgroups. Of course, members will only be assigned if the organization has some involvement with a particular workgroup’s function.
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