PQRS Enhancement

Introduction

From the inception of the PQRS DV project, Arch Systems, LLC has continuously reviewed, assessed and implemented processes and systems to save costs and bring value to CMS. As a result, in the base year and OY1, Arch’s excellent project management saved CMS approximately $262,000 and $30,000 respectively.

1 Executive Summary

This Executive Summary provides high-level results of enhancements and process changes implemented in the program for the first quarter of OY2.

Arch Systems strongly believes in continuous improvement and strives to innovate processes and tools which will provide value to both CMS and the PQRS stakeholder community. In order to achieve these goals, we reviewed our existing Primary Source Validation (PSV) process and Case Management Tracking System (CMTS) application. As a result of our review and analysis, we implemented new PSV processes and based on internal user feedback, added additional functionality to CMTS.

We believe that these changes resulted in improved data quality, reduced issues and risks associated with data integrity, while achieving overall cost savings.

The primary changes done were to the Case Management Tracking System (CMTS) and Primary Source Verification (PSV) processes were:

  • CMTS application changes include process automation to upload sampling spares, generate documents, ability to select failure comments on a chart and finally the ability to generate 9 standard reports.
  • PSV process changes include performing initial outreach via email, initiate PSV process earlier, use of a contract resource to obtain HICN for GPRO’s, provide HICN to EP’s and adding documented reasons for failures in the Final Letter.

Application Enhancements and Process changes have resulted in resource cost reduction associated with manual processes, reduced errors associated with manual data input and report generation, reduced data integrity errors.

Primary Source Verification (PSV) process changes have resulted in increased participation via early outreach. Additionally, we have achieved cost reduction by automating processes, reduced errors associated with manual data handling.

2 System Enhancements

2.1 Case Management Tracking System (CMTS)

Case Management Tracking System is a web based application developed to assist nurse reviewers during the Primary Source Validation (PSV) process. CMTS is used during PSV to track status of medical review, analyze results and create reports.

Table below provides a list of changes made to CMTS Application between Base Year, OY1 and OY2.

Table 1. Case Management Tracking System (CMTS) Application Changes

Base Year, OY1 OY2 Benefits
Spares were manually uploaded into
CMTS throughout the year. This
process slowed PSV process as the
team had to wait for Dev Resources to
update the system
Spares are pre-loaded in the
application. If a provider is inactivated,
the application will provide a new
provider
Cost reduction associated with
development resources manually
uploading data. Reduction in errors
associated with manual data entry
Manual data entry of failure comments
by nurse reviewers.
CMTS application is pre-populated with
failure comments. Nurse reviewers can
select the appropriate failure reason.
Reduction in errors associated with
manually uploading data.
Nurse reviewers manually edited
introductory and final documents prior
to sending them to EP’s
Process automated to generate
introductory and final documents
package.
Reduction in error associated with
manual processes.
Nurse reviewers and development team
manually developed final reports
Application enhanced to generate the
following reports:
  • Participation Report
  • Reporting Error Summary
  • Measure error type summary
  • Reporting Option Error Report
  • EP error report
  • Casual Error report
  • Weekly Status Report
  • Total Report
Reduction in costs associated with
manual processes.

3 Process Improvements

3.1 Primary Source Validation (PSV) Process Improvements

During OY2, Arch Systems made the following process improvements to the PSV process.

Table 2. Primary Source Verification (PSV) Process Changes

Base Year, OY1 OY2 Benefits
GPRO contact information. Information
was retrieved from IDR, This was a
manual process and resulted in
erroneous data being generated
For OY2, Arch is utilizing a
contractor to generate this data.
Switching to a contracted resource has
resulted in cost savings, reduced
erroneous data getting generated.
Initial Outreach was done using USPS.
This process resulted in delays as team
had to wait for EP’s to receive
information and respond back
For OY2, initial contact is being done
via telephone.
Initial outreach via telephone has allowed
team to reach out to larger pool of EP’s.
Initial Outreach for OY1 started in
February resulting in a shorter window
to complete PSV
For OY2, initial outreach started in
January and decision was made to
breakdown PSV into 2 cycles.
Early start of PSV cycle has already
yielded improved results. Within the first
week, Arch team was able to complete 30
introductory calls and had scheduled 28
additional calls (32% of total sample).
EP’s had to locate HICN prior to
submitting data
Arch provides HICN to EP’s Reduced burden on EP’s and increased
participation rate.
Final letter did not include additional
teaching on error reasons
Final letter included additional
teaching information documenting
reasons for errors.
Provides EP’s with documented reasons
for errors.

MEDICARE LEARNING NETWORK® LEARNING MANAGEMENT AND PRODUCT FULFILLMENT SYSTEM (MLN)

Customer
(Agency)
Contract # POC Total
Contract
Value
Period of
Performance
Relevant
(Y/N)
Additional
Info
Centers for
Medicaid and
Medicare Services
(CMS)
HHSM-500-
2016-00005G
Mary Scott
This email address is being protected from spambots. You need JavaScript enabled to view it.
$7,500,000 12/17/15-
02/17/21
Y Prime

Description of Services/Supplies

Arch Systems provides technical support for the Medicare Learning Network (MLN) Learning Management (LM) and Product Fulfillment System; Collecting and maintaining user data and registration; Hosting web-based training courses; Hosting a test environment where web-based training courses can be tested prior to going live. Arch also provide troubleshooting and assisting MLN users for those issues MLN staff are unable to resolve. We maintain a pre-production site for pilot testing of web-based training courses. There is also maintenance of a live site for learner access to the Learning Management and Product Ordering System and Product fulfillment services include maintaining inventory, packaging and mailing MLN products to health care professionals.

Services include: (1) technical support for the MLN Learning Management System; (2) Collecting and maintaining user data and registration; (3) Hosting web-based training courses (4) Hosting a web-based test environment; (5) Troubleshooting and assisting MLN users for those issues MLN staff are unable to resolve; (6) Maintain a pre-production site for the pilot testing of web-based training courses; (7) Maintain a live site for learner access to the Learning Management and Product Ordering System (POS); and (8) Product fulfillment services include maintaining inventory, packaging and mailing MLN products to health care professionals.

Several key objectives to this project are to meet, fulfill and exceed the needs of the seven task areas with the MLN. These area are: Task 1 – Hosting Platform; Task 2 – Hosting Service; Task 3 – Technical Support; Task 4 – Medicare Learning Network (MLN) Product Fulfillment; Task 5 – Monthly Status and Cost Report; Task 6 – Annual Self-Assessment Report; and Task 7 – Work Plan. Each area is broken out broken below.

Task Areas of Relevancy

1. IT Services for Biomedical Research or Healthcare;
3. Imaging;
4. Outsourcing;
5. IT Operations and Maintenance;
6. Integration Services
7. Critical Infrastructure Protection and Information Assurance;
8. Digital Government;
10. Software Development

Relevancy Explanation

Size – NAICS 541511 comprises establishments primarily engaged in writing, modifying, testing, and supporting software to meet the needs of a particular customer. For a small business contract over $10 million, this project represents adequate size standard for task orders under $27.5 million for CIO-SP3

Scope – CMS created the Medicare Learning Network (MLN). The MLN is the products, services and activities that CMS and its MACs undertake to reach out to the health care professional community. The MLN includes web-based training courses and publications which are available to health care. Under this task order, Arch Systems provides product fulfillment services, hosting services, and technical support services for the MLN’s Learning Management and Product Ordering System. Arch meets the MLN seven task areas in the following ways:

Task 1 – Hosting Platform: Arch provides servers capable of hosting the current MLN LM/POS, which includes: 1) Platform/Operating System: Windows 2008 R2 (Application server); SQL Server 2008 R2 (Database)Platform/Operating System: Windows 2008 R2 (Application server); SQL Server 2008 R2 (Database); 2) Band Width: Reserved 3MB/S, Burstable 6 MB/S; 3) Programming Language: Microsoft .NET framework 4.0; and 4) Storage: Content storage 200GB, Database storage 200GB


Task 2 - Hosting Service: Arch provides a hosting service for the current inventory of web-based training courses as well as additional new and/or revised web-based training courses as they are developed and/or updated .Web-based training courses are made available 24 hours a day, 7 days a week. We provide a hosting service and database storage for the MLN LM/POS; provide service for up to 5,000 learners simultaneously; maintain a bandwidth – Reserved 3MB/S, Burstable 6 MB/S; provide storage - Content storage 200GB, Database storage 200GB; provide a hosting service meeting all CMS IT standards and security requirements; provide a hosting service that meets all Section 508 compliancy requirements; provide CMS staff with write access to both production and pre-production course files allowing CMS to load and download updated/revised files to production and pre-production through an SFTP site; and revise and maintain web-based training course quantities as needed throughout the life of this contract.

Task 3 - Technical Support: Arch provides technical and troubleshooting support for learners using the MLN Learning Management/ Product Ordering Systems (LM/POS) including help functions. Once we receive requests for various support needs from CMS, our action plan is to respond no later than the next business day after receipt of the learner’s request. Upon request, we follow actions to remedy the issue in a fastidious manner while attempting to not interrupt the day-to-day functions of the team. Under technical support we: (1) maintain the production and pre-production sides of the MLN LM/POS. The pre-production site mirrors the production site and is used to test system changes and new courses; (2) provide customizations to system for learner and administrative functions enhancements; (3) provide a testing site for beta testing and pilot testing of new web-based training courses; 4) prepare all necessary CMS clearance documents such as Office Of Management And Budget (OMB) clearances and CMS IT system security plans; (4) maintain the database containing the information necessary for CMS documentation required as an accredited provider of continuing education; (5) provide evaluation-reporting mechanisms for the existing learning management and product ordering system that will allow CMS to obtain evaluation data. (6) allow CMS or CMS authorized contractors to perform security scans of the system and penetration testing to ensure that the MLN LM/POS complies with CMS security requirements; (7) perform security and system upgrades and system maintenance; (8) perform routine Section 508 compliance testing of the MLN LM/POS (9) provide Ad Hoc Reporting such as (Provide a dedicated reporting database and server; Custom field for data Assist CMS in building and troubleshooting reports on an as needed basis; Mobile Module Licensing; ensuring unlimited users have access; and perform incremental annual maintenance.

Task 4 – Medicare Learning Network® (MLN) Product Fulfillment: Arch stores all MLN products in a facility located within the Baltimore/Washington DC Metropolitan Area where we provide all envelopes, boxes, and all appropriate packing materials and supplies. We also print mailing labels from the MLN LMSPOS and package, address and mail the MLN products.

Task 5 – Monthly Status and Cost Report: Monthly Status Reports are submitted electronically to the Contracting Officer’s Representative (COR), Alternate COR, and Contract Specialist. Arch provides a Monthly Status Dashboard in accordance with our CMMI Level 3 practices.

Task 6 – Annual Self-Assessment Report (SAR): The SAR is also submitted electronically to the COR, Alternate COR, and Contract Specialist, which captures a self-assessment of achievements and deficiencies. Included in the SAR are Quality of Product or Service, Cost Control, Timeliness of Performance, and Business Relations; We provide recommendations for areas that could be improved; Identification of problems not anticipated throughout the year; and Recommendations and insights into resolution of the unanticipated problems.

Task 7 – Work Plan: Arch provides a highly detailed work plan regarding our approach to hosting and maintenance of the MLN Learning Management and Product Fulfillment System. The work plan includes: our approach regarding day-to-day maintenance of the MLN LM/POS as well as our approach to updating the current MLN LM/POS to keep it abreast with technological advancements and timelines for all changes and modification/updates to the MLN.

Complexity – As this is a relatively new project (we are still performing our base year), Arch’s transition into the MLN program as the Prime contractor has been seamless with no interruptions in day-to-day services. There have been no issues/ occurrences for concern. On this contract, Arch performs 8 of the 10 task areas from the CIO-SP3 RFP. The project is complex because there are enhancements scheduled as business needs arise with emergency releases. Arch staff is involved with eight of the service task areas.

Cure Notices or Show Cause Letters – There have been no Cure Notices or Show Cause letters, to date, on this project.

Results Achieved In The Completion Of Actual Contracts And Task Orders - On the MLN project Arch provided guidance on, and accompanied the business owner on, a Technical Review Board (TRB) consultation. This purpose of this consultation was to explain the system architecture and design. The MLN contract is for Operations and Maintenance of the system. The TRB consultation was for analysis of the current design and to plan for the redesign of the system. That entire body of work is beyond the scope of the current contract. This added service positions the business owner to move forward in understanding the current design limitations and deficiencies, and to understand what needs to be considered in the redesign. Our representation of the business owner before the board is provided as a "value added" service.

Arch reviewed the findings recommendations and of the TRB and advised the business owner on how best to bring the system into compliance. These services are normally associated with development/redesign efforts, and were not in the original statement of work. By analyzing the consultation findings and recommendations, Arch was able to assist the business owner develop a plan to move to full compliancy with the agency's Technical Reference Architecture (TRA).

Arch is working with the business owner's team to navigate the process of preparing of a Security Controls Assessment (SCA) and obtaining Authority to Operate (ATO). Obtaining an ATO is typically part of the Systems Development Life Cycle (SDLC), and is done before a system goes into operation. Because this is a legacy system, it is undergoing this process after years of operation.

Recovery Audit Contractor Data Warehouse

Customer
(Agency)
Contract # POC Total
Contract
Value
Period of
Performance
Relevant
(Y/N)
Additional
Info
Centers for
Medicaid and
Medicare Services
(CMS)
HHSM-500-
2014-00361G
Sergey Mikhaylenko,
(410)-207-7846,
This email address is being protected from spambots. You need JavaScript enabled to view it.
$18,000,000 03/25/14-
03/25/19
Y Sole subcontractor
to Koniag
Services

Description of Services/Supplies

As part of the CMS Recovery Audit Contractor Data Warehouse (RAC-DW) project, Arch manages and maintains routine operations of the current system, and provides help desk support and disaster preparedness planning. We have implemented and continue to monitor system controls on user activities/uploads to ensure data quality, completeness and adherence with all RAC program/Data Warehouse policies and procedures. An ongoing requirement exists for IT development and enhancement services, as needed.

Services include: The conversion of existing code, implementation of Section 508 standards, and subsequent ongoing enhancement of the existing RAC Data Warehouse application’s functionality

Several key objectives to this project are: The performance of the user interface, accurate incorporation of user data needs and their systems, and migration to a data center.

Task Areas of Relevancy

1. IT Services for Biomedical Research or Healthcare;
4. Outsourcing;
5. IT Operations and Maintenance;
6. Integration Services;
7. Critical Infrastructure Protection and Information Assurance;
8. Digital Government;
9. Enterprise Resource Planning; and
10. Software Development

Relevancy Explanation

Size – NAICS 541512 Computer Systems Design Services: This U.S. industry comprises establishments primarily engaged in planning and designing computer systems that integrate computer hardware, software, and communication technologies. The hardware and software components of the system may be provided by this establishment or company as part of integrated services or may be provided by third parties or vendors. These establishments often install the system and train and support users of the system. For a small business contract over $10 million, this project represents adequate size standard for task orders under $27.5 million for CIO-SP3

Scope – On this project, Arch manages and maintains routine operations of the current system, performing basic system design, development, and engineering functions; executing other services include: converting legacy code from .NET and ColdFusion to Java; and implementing Section 508 standards. Arch participates in fully testing each release prior to delivery, including positive and negative unit, integration, system, and regression tests. Arch assists in supplying complete release documentation, including a list of changes, functional specifications, test cases/results, operational procedures and user guide updates. Arch works cooperatively with CMS and the Data Warehouse user community to analyze and implement new program requirements and enhancement requests. New features or enhancements are packaged into quarterly releases through a structured change management process.


Complexity – Arch’s contributions to the RAC-DW program as sole subcontractor are especially relevant to its bid for CIO-SP3. On this contract, Arch performs 8 of the 10 task areas from the CIO-SP3 RFP. The project is complex because there are enhancements scheduled as business needs arise with emergency releases. Arch staff is involved with eight of service task areas.

Cure Notices or Show Cause Letters – There have been no Cure Notices or Show Cause letters, to date, on this project.

Results Achieved In The Completion Of Actual Contracts And Task Orders - Arch has successfully implemented a total of 15 major as well as numerous minor system enhancement releases. Likewise, Arch staff continually addresses ad-hoc data requests that arise in conjunction with the warehouse. Arch’s Change Management work on RAC DW is also noteworthy insofar as a rigorous change tracking process is in place whereby Arch documents, prioritizes, and tracks all change requests received from CMS. Arch also continuously manages RAC-DW system security. The Enterprise Support Services provided include Agile Methodology and following the Expedited Life Cycle (XLC) framework, Technical Review Board presentations, Change Control Board participation, and all of the various reports required as part of contract management. Arch has performed the contract within budget, contractual terms, conditions and scope since the inception of the contract in 2014. Arch has successfully completed project tasks within the Firm Fixed Price (FFP) allocated budget for the contract. There are no cost over-runs on the project. Arch continues to deliver all requirements as per customer expectations and project schedule.

Past Performance

Arch has a portfolio of more than 20 healthcare IT projects—3 current and relevant CMS prime contracts (6 total Federal prime) and several subcontracts within three years—Arch is at the very top level of successful small businesses competing for the CIO-SP3 Ramp-On for small businesses as proven with the prestigious Top 100 Minority Business Enterprise (MBE) award received by Arch in 2014. Arch was selected from 500 nominations as a Top MBE in the “Innovator’s category.” In 2015, Arch received the Inc. 5000 award, ranked 994 out of 5000 fastest growing small businesses in the country! In 2016, Federal Health IT ranked Arch as the #1 HUBZone business and Top 10 small business at CMS, http://www.fedhealthit.com/2016/02/trending-cms-sb-primes-by-socioeconomic-category/.

Arch combines its healthcare-focused vision with a customer-centric mission and provides patient-centered services to fully support the CIO-SP3 IDIQ’s technological demands. Arch is a dynamic small business with excellent past performances. The vision of Arch is to constantly augment and improve our capabilities as well as satisfy business owners to the greatest extent possible, with highest quality of deliverables, service levels and collaboration. Over the past 10 years, Arch as an 8(a) HUBZone, woman-owned small business has a proven, rich past performance track record with excellent delivery metrics in quality of product and services, schedule, cost, business relations, and subcontractor management with CMS and other federal agencies.

Figure 1: GSA Survey of Past Performance and CMS CPARS Excerpt

Arch has a CMS-approved accounting system and financial adequacy which is imperative for the management of Firm Fixed Price, Cost Reimbursement, Indefinite Delivery Indefinite Quantity, and Time and Materials contracts.

Arch has resolved challenges for CMS business owners for over 10 years in the service areas of enterprise architecture, requirements analysis, systems development and support services such as working on very short timelines to accomplish project deliverables, developing solutions for automation, acting as an integrator to resolve problems and providing innovative workaround solutions to satisfy business needs. Arch has invested in building a clinical business line at Arch with experienced physicians and nurses, termed as the Arch Clinical Enterprise (ACE) Group. This staff helps Arch bridge the gap between clinical and IT knowledge that otherwise tends to exist in system development; our diverse teams are cooperative and synchronized and are consequently able to produce exceptionally comprehensive results. Their clinical and subject matter contributions towards the various phases of the Expedited Life Cycle (XLC) ensure that our solutions and services align with the healthcare needs of the Medicare and Medicaid beneficiary populations, providers, and insurance companies.

Arch’s Chief Medical Officer, Dr. William Rollow, a practicing Physician, has over 20 years of experience with HHS projects. Dr. Rollow has direct federal healthcare experience as Quality Improvement Director for CMS/Centers for Clinical Standards and Quality (CCSQ) for over 7 years from 2000 to 2007. He has led Arch’s ACE Group since 2013. Mr. Douglas Brown, Vice President of Program Operations at Arch, proposed as Program Manager for CIO-SP3, was Formerly Group Director at the Centers for Program Integrity (CPI) at CMS. Refer to resumes in Key Personnel.

Arch has also invested in Training Specialists for systems training, learning management, and education and outreach support services, so we are always able to provide up-to-date, state-of-the art educational experiences. Our Training Business Service augments our clinical and IT capabilities in projects such as the Unified Case Management System (UCM).

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