............as always, send email for any corrections or add-ons.
LACDMH has been holding regular CPTT meetings to address Contract Provider, EHRS vendor, and FFS Provider questions regarding the imminent July 1st GO-LIVE for their new IBHIS system. Since many providers aren't sure what to ask, I have been reviewing all the materials provided and compiling questions on your behalf.
The questions below I have provided to LACDMH and hope to see written responses via their FAQ page HERE, and/or updates to the companion and technical guides posted HERE. Be sure you collaborate with your EHRS vendor to address each topic below.
1.
Web
Services
a.
What is the Client data exchange contingency
plan if a vendor’s Web Services solution is not ready in time for Go-Live? (This
is a new function and interface that must be developed by each EHRS vendor;
without this interface functioning, on either the providers EHRS end or the
IBHIS end, providers cannot open/update clients in IBHIS to enable claims
processing.)
–
A:
b.
What is back-up plan if the Web Services
solution goes down, on either end, after Go-Live? Can the Provider Connect portal be used in
some way for this? e.g. for manual look up of clients, for manual client data
updates?
–
A:
c. Since the IBHIS procedures include more
stringent and less forgiving claims validation procedures, i.e. the comparison
of claims data to IBHIS data and the PRM comparison to NPPES and claims…. Can DMH make some recommendations for the
timing and sequence of Web Services client data updates (the sequence of “gets and puts”), PRM updates, and claims submission, for
the most effective and accurate claims submitted by providers EHRS’?
–
A:
Although no answer on this as yet, see my thoughts under #5 in an updated previous article
HERE
2. IS Client Data migration to IBHIS
a.
When and
how will client data be moved into IBHIS from the IS, and when and how will we
have access to begin updating client data in IBHIS?
–
A: Data was migrated
from the IS, and de-duplicated. There will not be another migration, although
new clients opened in the IS will be opened in IBHIS. Providers must use Web
Services to update their data, and this access will not be available until after provider GO-LIVE. see DMH
FAQ Q23
for details.
–
Note: This means providers will need to use Web
Services to update client data prior to issuing claims to IBHIS, so should hold
claims until this can be completed.
b.
For COS
clients, should we set-up a universal client in IBHIS for these claims;?
–
A: No, DMH already
created COS episodes for all clients with LE’s that have these in their
contract;
3.
Practitioner
Registration Maintenance Application (PRM)
a.
When will we be given access to update Practitioner
data prior to our Go-Live? How will
access be obtained, via RSA Card and IS Logon ID?
–
A: Just prior to each
provider Group’s IBHIS testing phase, i.e. during the Group’s Provisioning
phase, after your Readiness meeting; i
–
A: If you already had PRM access in June, you may need only to
have your password reset, no application needed. Otherwise an application for
access must be submitted.
–
Note: this means that once you have this access and can begin updating
practitioner records in PRM, you must arrange for staff to manage the triple
data entry in your EHRS, the IS, and IBHIS, until your FY13-14 IS claims
processing is completed.
b.
Will there be a Practitioner taxonomy date
history maintained in IBHIS to match to the date of service for each claim?
–
A: No, developers working on this, but not ready
for Go-Live!
–
Note: at GO-LIVE you may have to time your taxonomy updates in PRM
and claims submissions, to synch with any providers taxonomy changes, IBHIS
does not track by date of service… yet.
c. How
often is the PRM data moved into IBHIS, and how is it moved?
–
A: it is manually
entered by DMH Provider support office, POS staff,
weekly, no timeline commitment can be given.
d.
Will we receive an electronic file of all practitioners in PRM that
have been marked “pending” or show a mismatch with NPPES? Will we be able to
print a report showing all practitioners “pending”?
–
A:
4.
PATS
prescriptions
a.
Please clarify what we need to do in the IS for indigent
medication clients being served after IBHIS GO-LIVE on 7/1/14 when PATS is being used.
–
A: Until PATS is
decommissioned, now delayed until at least December 2014, clients must be
opened with an active episode in the IS in order for PATS to authorize the
medication. (PATS is connected to the IS, not to IBHIS);
–
Note: Do not close
episodes in IBHIS or IS if using PATS for that client.
b.
Should providers continue to open new clients
and episodes in the IS for PATS authorized medications, and these clients must
also be opened in IBHIS via Web Services? However, if they are opened in the
IS, and also opened in the provider’s EHRS and pushed to IBHIS via Web
Services, won’t the client have two different client ID’s, one in IS and one in
IBHIS? How to avoid this? e.g. open the
client in the IS only (this enables the PATS medication to be authorized), and
wait for the new client to be pushed from the IS to IBHIS and an ID created
there. Then use this ID in your EHRS for claiming. How often will the new
client records be pushed from IS to IBHIS?
–
A: if you are live in
IBHIS, and you have an indigent client using PATS, you must create an episode
in the IS and in IBHIS for claiming;
c.
If a provider implements an e-prescribing
solution, can they avoid using PATS before it is decommissioned? or does DMH
need their PBM implementation first, to replace PATS, DMH FAQ’s:
–
For DMH directly operated programs, PATS functionality will
ultimately be replaced by a combination of OrderConnect (ePrescribing) and a
Pharmacy Benefits Manager for indigent client (PBM for formulary management,
claims adjudication, etc). Once a PBM is implemented, pharmacies dispensing
medications for indigent clients prescribed by an LACDMH contracted agency will
leverage the PBM service in lieu of PATS to determine eligibility.
–
A: No, providers must
continue to use PATS until DMH has a PBM in place.
5. Program P- Auths
a.
Please clarify the structure and use of these authorization
codes in each claim. i.e. the 2400 loop states “Report the Provider, Member or
Fee-for-Service Authorization # in the Prior Authorization field”, does
that mean we only report the M-Auth, and if no M-Auth we report the P-Auth, or
do we include both here? what is the format, string length, separator to be
used, etc?
–
A: P-Auth include a “P”
+ 4-5 digits; they should not exceed 5 digits;
a.
When will we receive our P- Auths codes for FY14-15, specifically? i.e., during
provisioning phase so we can test them? Or, will we need to hold claims on
7/1/14 until they are provided and can be entered in the EHRS, so we will need
to test with dummy codes?
–
A: DMH will provide
these for Go-Live (no date specified) and then annually at start of the fiscal
year. A cross walk between current IS plans and IBHIS P-Auths #’s is being
developed by Zena. We can also provide an example.
–
Note: you cannot send
claims to IBHIS until you have these P-Auths in your EHRS and in every claim.
6. Member M-Auths
a. How will access be provided
to ProviderConnect?
–
A:
b. Please
clarify how we will determine if a client is being seen for Day Treatment at
another Legal Entity (LE) prior to enrolling them in concurrent MH services,
which we understand would require an authorization for concurrent services
using the ProviderConnect portal.
–
A: Web Services should
be used to determine if the client is enrolled in Day Treatment and requires a
M-Auth request be issued via the ProviderConnect portal, for concurrent
services. You will not be able to use this portal to see if clients are
enrolled in a Day Tx program.
c. Will
we be able to export the Auth data electronically, to import into our EHRS, or
must we manually type it from the screen?
–
A: The Provider Connect
response will be on the screen in Provider Connect and must be manually
recorded in your EHRS to enable it to be pulled into the 837 claim files.
d. How
long will it take to receive the approval for the M-Auth in Provider Connect?
–
A: commitment is one
week, but we expect it to be within one day.
e. Please
confirm that we will not need to use this application if we do not deliver Day
Tx services and do not deliver concurrent services to a client receiving Day Tx
elsewhere.
–
A: yes, this is correct
for the current fiscal year. FY14-15 is TBD, and may require this system for
other authorization types to be determined.
f.
When will this be determined for FY14-15, and
will it be implemented retroactively if announced after GO-LIVE?
–
A:
7. Claims Denials based on data validation against IBHIS (client and PRM)
a. Will
every data element sent in each 837 claim be validated by comparison to the
data in the client and practitioner records in IBHIS? If not, which data will be used for
comparison? Will the comparison / matching algorithm call for an exact match of
every data element being compared, in order for the claim to be processed
further? What can cause the match to fail? Will claim with these mismatches result in
a rejection or a denial or something else?
–
A: see updated
companion guide.
b. Which
data elements required in the claim transaction will be pulled from the client
record in IBHIS and put into the 837 file by IBHIS? Will this only occur on
Medi-Cal claims? We need to understand this in order to refine our data entry
and Web Services workflows to assure they enable accurate claims.
–
A: see updated
companion guide.
–
Note: no reference to Medi-Cal in the 837; do not send the
Medi-Cal info in claim, only the Medi-Cal
P-Auth code. DMH will pull Medi-Cal data into your claims before
forwarding to the state.
c.
Will Claims consistency checks be performed
against PRM Practitioner data? Which elements will be used to compare? i.e. NPI#,
NPPES data, discipline, category, name, taxonomy. Will claims be unable to be processed if these data elements
in IBHIS / PRM do not match what is in the claim? Will claim result in a
rejection or a denial or something else?
–
A: see updated companion
guide.
8. Claims Cut-off schedule
Can we submit claims to IBHIS, for
service dates July 2013 forward (FY13-14), if not sent to IS already? (there was a slide that eluded to this)
–
A: no, you cannot send
claims with date of service (DOS) prior to 7/1/14 to IBHIS;
9. Share of Cost (SOC)
Is this process changing with
IBHIS? for example, will SOC amounts collected be included in financial client
data in IBHIS, updated via Web services in client record?, or via the
claim….please clarify
–
A: no changes in SOC;
used with Medi-Cal P-auths only; UMDAP
data is updated with Web Services.
10. Location of a service
Has the decision been made for providing
the location of a service? If this
is required, how will we provide this, in the 837? if so, will the companion
guide ned to be updated and vendors will need to make development changed to
the 837?
–
A: HIPAA requires that
each claim include the location of service, so you should be collecting this
data and transmitting it in each claim; DMH does not yet have the ability to
validate that this was sent, but we will in the future.
11. EBPs
Please clarify this EBP change in the 837….i.e. Do providers
need to make any clinical, service delivery, or service recording / workflow
changes for this EBP claim element?
–
per DMH slides: IBHIS 837 contains single State CSI EBP/SS or
LACDMH-specific EBP
–
A: With IBHIS you can
only send one EBP with each IBHIS claim; There are 3 state reportable EBP’s , and if you are not delivering one of
these 3, but are delivering one of the MHSA DMH endorsed EBPs, then this is
your EBP priority; if none of these, report a service strategy , or 99.
12. Reports
a. How long will DMH maintain the IS archival
data and reports and how long will we have access to it?
–
A:
b. Will
providers be able to pull reports for FY13-14 and prior, as well as FY14-15
from the same database? or will this require two different databases be
accessed to get FY13-14 vs 14-15?
–
A: data will be
combined and you will be able to pull bot IS and IBHIS data from the same
source.
13. COS HIPAA claims
a. Since the decision was just announced on
1/21 that the COS files will not be via a pipe delimited format, but rather via
837…. when will we received the companion guide as our vendor has already begun
development work on the other format? A: posted in
site.
b. Will we receive the HIPAA 277 response file,
or just a 999 and 835 for COS, as stated in the recent IBHIS alert? A: Yes, same as all other EDI claims.
c. Will
we have a new testing schedule timeframe issued for COS via 837 since our
vendors have not yet been able to start development? A:
No
d. Will these claims use the same FTP site and
digital key as the other IBHIS 837 files?
–
A:
e. How
will the 837 work when there is no specific client for the service. Does
the 837 allow for no client? i.e. will
DMH be assigning a MIS/IBHIS number? do we need to use a fake client as we do now in the EHRS (Eg -
COS_FSP, etc.)?
–
A: DMH already created
COS episodes for all clients with LE’s that have these in their contract; the companion
guide specifies the universal text to use to specify these clients.
14. HIPAA EDI claims
a. Will there be a 277 companion guide issued,
as was for the IS? if not, what format assumptions do we make, IS or National
standards?
–
A: no 277 companion
guide will be issued, use the national standard format, do not use the IS
companion guide.
b. Must all Duplicate Override codes now be
assessed and included by EHRS, rather than IBHIS? i.e. IBHIS will not include
any duplicate override codes in the claims on behalf of the provider.
–
A: TBD
c. Will Medi-Cal Claim transaction flow change,
e.g. will we receive an “approved” 835 before the state adjudicates claim, and
then a second denied 835 if the state then denies the claim during
adjudication? i.e. Will we receive two 835’s for state denials?
–
A: Yes, you will
received an “approved” 835 before the state has adjudicated your claims, then
you will received a “denial” 835 if state denies the claim; if state approved
the claim, you will not receive another 835.
15.
TPA application and digital keys for testing
a. How long will it take for us to receive our
approved TPA once we are permitted to submit it? Is this required to receive
the testing keys?
–
A: it took
approximately 1.5 months for the Pilot 1B provider to receive their TPA
approvals. You cannot submit your TPA application until your Group is enabled
to do so, however, DMH will provide you with the keys and access for testing as
scheduled. It took only a few days for Group 3 to receive their approved TPA.
–
Note: approval for Group 3 was fast, ~ one day.
b. Must
we have the approved TPA prior to receiving the production digital keys to
allow us to begin submitting claims after 7/1/14? i.e. we cannot GO-LIVE until
approval is received.
–
A: correct, you cannot
go-live without an approved TPA and the production digital keys that come with
it.
16. Testing and Lessons learned in Pilot
a. What information and learnings will be
shared with non-Pilot providers and vendors, from the Pilot providers and
vendors? I.e. what did they learn and
would have done differently?
–
A:
b.
Will we be cut-off from IBHIS testing on our
testing end date? What if we have further testing of fixes to do, will
exceptions be made and access provided?
–
A:
c.
What Practitioners will we use to test if we do
not have access to the Client data via Web Services until after Go-Live?
–
A: we have a testing
environment called “sandbox” which was loaded with the initial PRM providers
entered in June, and approved for services (meaning NPPES match), these should
be used for testing.
17. OMA
Will the OMA data entry procedures change with the changes in IBHIS
episodes?
–
A:
18. FORMS
a. Will
clinical forms requirements be changing for IBHIS GO-LIVE?
–
re DMH FAQ: As long as the Providers print view has
the data elements noted in the Organizational Provider’s Manual page 1-11
(http://file.lacounty.gov/dmh/cms1_159846.pdf) then it is approved. … It is up to the Provider to ensure it has the required
data elements …..
–
A: not initially,
required forms continue to be required with IBHIS, but requirements will change
to allow for providers to print out their EHRS data for each form, as long as
the required data is on the form and in the required sequence, however, a
required sequence has not been issued.
b. The
DMH forms meetings have been verbally announcing form changes, but nothing has
been communicated in writing or give to the IBHIS CPTT groups, when and what
should we plan for?
–
A:
19. Surviving Client ID
a.
If a New client
comes to a contract provider A who is part of IBHIS Pilot 1 for the first
time. Client is created in IBHIS with and IBHIS client ID. Same client
later comes to another contract provider B, who creates the client in IS
with an IS Client ID. Will the nightly push from IS to IBHIS discover the
duplicate? If so, what will occur? Will it notify us, or just not
migrate the IS client into IBHIS? Can we modify the client ID in the IS to
be the IBHIS ID instead of that generated by the IS? Or will DMH do the
AKA match automatically for us?
–
A:
20. Missing Documentation
When will these be available please:
a. Requirements for 837P – residential claims, A: more info end of March
b. 835 - Claim adjustment reason codes; A:
c. 277CA – Claim status codes; A:
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