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MECT 2.3: More guidance, more documentation

08.13.18

Here we go again! With the 2018 Medicaid Enterprise System Conference (MESC) underway, we have another Medicaid Enterprise Certification Toolkit (MECT) Release. On July 31, 2018, the Centers for Medicare and Medicaid Services (CMS) issued the MECT Version 2.3. Historically, CMS has updated their certification toolkit and lifecycles iteratively on a near yearly basis. With increasingly rapid technological advances and initiatives, CMS’ iterative releases of the MECT are provided in an effort to stay current with federal regulations and industry priorities.

Last year’s MECT update (version 2.2) brought a slew of certification checklist updates, with somewhat comprehensive changes to the certification criteria. Although there were still a few updates to the checklists, this year’s release focused more on updating the required documentation and processes, than revamping the checklists.

Many states are beginning work on Medicaid Information Management System (MMIS) modular procurements, to replace outdated or poorly functioning enterprise and legacy systems. States are continuing to conform the certification process to modern procurements; however, there is still gray area and differences in approach amongst states across regions. Certification teams eagerly await MECT updates as the Toolkit becomes more aligned with new modular procurements. Will MECT 2.3 accomplish that? Let’s look over some of the core certification elements, and consider the impacts. Are we collectively there yet, or do we still need to continue growing through the modular implementation pains?

CMS Certification Checklist Updates

The most impactful update to the certification checklist includes the comprehensive removal of the Medicaid Information Technology Architecture (MITA) Business Area Checklist Set. This removal is a nod to the ever changing Medicaid environment, where MITA-guided procurements are being replaced by modular business function mappings. Additional changes to the checklists include:

  • Provider and Pharmacy checklists now include guidance tabs
  • Program Integrity checklist now includes 6 additional certification criteria for Electronic Visit Verification (EVV) certifications
  • Criterion TA.SP.75 was removed from the Access and Delivery checklists, and added to the Programmatic checklist in the IV&V Progress Report
  • Two criteria, TA.DC.5 and TA.DC.6, were removed from the Intermediary and Interface checklists

Appendix D: MMIS IV&V Progress Report Updates

  • Section instructions have been updated for all sections to include more detail and guidance

  • General Information now includes fields for submitter company name and if/when the Project Partnership Understanding (PPU) document was sent to CMS. Activity 1 Consult Date and RFP release fields have been removed

  • Summary of Project Progress and Status (formerly Executive Summary) instructions now direct the submitter to provide project-wide information, not just planned modules and/or seeking a Milestone Review

  • Budget & Schedule Metrics (formerly Life Cycle Status and Schedule) now includes the ability to identify project and module state-specific metrics to report variance

  • Life Cycle Status and Schedule replaced the MITA-Aligned Modules with Additional Modules to allow states to identify up to five (5) custom modules

  • Risks and Recommendations instructions have been updated to direct the submitter to include project-wide information, not just planned modules and/or seeking a Milestone Review

  • Programmatic Checklist now includes a “partially meets” assessment option

Required Artifacts (Appendix B) Updates

  • One new artifact: New Medicare Card Program’s (NMCP) State Medicaid Agency Readiness Report (R1, R2, and R3)

  • No removed artifacts

  • One artifact with updates: Production Screenshots, Reports, and Data (R3)

Updates to the MECT Appendices

  • Multiple updates to Appendix H: PPU Template, including updates to the section names, removal of multiple sections, and additional guidance on the use of this document

  • Addition of Appendix K: Map of MITA Business Areas to Criteria (This document maps all of the MECT checklist criteria outside of the five core checklists to their appropriate MITA business area)

  • Addition of Appendix L: Milestone Review Preparation Guide (This document explains how milestone reviews are conducted and how states can readily prepare for milestone reviews)

Additional Updates

  • Updates to the Medicaid Enterprise Life Cycle (MECL)

  • Updates to the MECL and At-a-Glance Sheets

  • Additional recommendations for Independent Verification and Validation (IV&V) vendors, including when and how IV&V can provide advice to states

  • Minor updates to additional MECT appendices

From initial assessment of the MECT 2.3 release, it is clear that CMS continues to take strides to align the certification process to support our new modular Medicaid enterprise world. Keep in mind that MECT 2.3 is the latest round of a continuous cycle. Though it will likely not be the answer to all states’ issues and needs, this release does make great strides in adapting to the ever-changing Medicaid landscape. As we reported last year with the release of MECT 2.2, CMS continues to foster and support an environment for states to better align their procurement and certification efforts with the new modular enterprise industry.

Topics: MESC 2018, Medicaid

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification or modernization efforts.

You can listen to the companion podcast to this article, Organization development: Shortcuts for states to consider, here: 

Over the last two years, the Centers for Medicare and Medicaid Services (CMS) has undertaken an effort to streamline MES certification. During this time, we have been fortunate enough to be a trusted partner in several states working to evolve the certification process. Through this collaboration with CMS and state partners, we have been in front of recent certification trends. The content we are covering is based on our experience supporting states with efforts related to CMS certification. We do not speak for CMS, nor do we have the authority to do so.

What organization development (OD) shortcuts can state Medicaid agencies consider when faced with competing priorities and challenges such as Medicaid modernization projects in flight, staffing shortages, and a retiring workforce?

The shortcuts include rapid development and understanding of the “why”. This requires the courage to challenge assumptions, especially around transparency, to allow for a consistent understanding of the needs, data, environment, and staff members’ role in impacting the health of the people served by a state’s Medicaid program. To rapidly gain an understanding of the “why”, state Medicaid agencies should:

  1. Accelerate the transparency of information and use of data in ways that lead to a collective understanding of the “why”. Accelerating a collective understanding of the why requires improved communication mechanisms. 
  2. Invest time to connect with staff. The insistence, persistence, and consistency of leaders to stay connected to their workforce will help keep the focus on the “why” and build a shared sense of connection and purpose among teams.
  3. Create the standard that planning involves all stakeholders (e.g., policy, operations, systems staff, etc.) and focus on building consensus and alignment throughout the organization. During planning, identify answers to the following questions: What are we trying to achieve, what are the outcomes, and what is the vision for what we are trying to do?
  4. Question any fragmentation. For example, if there is a hiring freeze, several staff are retiring, and demand is increasing, it is a good idea to think about how the organization manages people. Question boundaries related to your staff and the business processes they perform (e.g., some staff can only complete a portion of a business process because of a job classification). Look at ways to broaden the expectations of staff, eliminate unnecessary handoffs, and expect development. Leaders and teams work together to build a culture that is vision-driven, data-informed, and values-based.

What are some considerations when organizations are defining program outcomes and the “why” behind what they are doing? 

Keep in mind that designing system requirements is not the same as designing program outcomes. System requirements need to be able to deliver the outcomes and the information the organization needs. With something like a Medicaid Enterprise System (MES) modernization project, outcomes are what follow because of a successful project or series of projects. For example, a state Medicaid agency looking to improve access to care might develop an outcome focused on enabling the timely and accurate screening and revalidation for Medicaid providers. 

Next, keeping with the improving access to care example, state Medicaid agencies should define and communicate the roles technology and staff play in helping achieve the desired outcome and continue communicating and helping staff understand the “why”. In Medicaid we impact people’s lives, and that makes it easy to find the heart. Helping staff connect their own motivation and find meaning in achieving an outcome is key to help ensure project success and realize desired outcomes. 

Program outcomes represents one of the six major categories related to organizational health: 

  1. Leadership
  2. Strategy
  3. Workforce
  4. Operations and process improvement 
  5. Person-centered service
  6. Program outcomes

Focusing on these six key areas during the analysis, planning, development, and integration will help organizations improve performance, increase their impact, and achieve program outcomes. Reach out to the BerryDunn’s Medicaid and Organization Development consulting team for more information about how organization develop can help your Medicaid agency.
 

Article
Outcomes and organization development, part II

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification or modernization efforts. 

The companion podcast to this article, Organization development: Preparing for Medicaid Enterprise Systems (MES) modernization, can be found in our virtual library.  


What is organization development (OD)? 

The purpose of OD is to improve organizational performance and outcomes. OD focuses on improving an organization’s capability through the alignment of strategy, structure, people, rewards, systems, metrics, and management processes.  

OD is a science-backed, interdisciplinary field rooted in psychology, culture, innovation, social sciences, quality management, project management, adult learning, human resource management, change management, organization behavior, and research analysis and design, among others.  

OD typically starts with a clear sense of mission, vision, and values that answers the question “what we are trying to be?” OD develops the culture and behaviors that reflect the organizational values.  

OD facilitates the transformation of the workplace culture to become strategic, meaning: vision-driven, values-based, and goals-aligned. This may include talent development for leaders and staff and redesigning organizational infrastructure. 

What is the scope of an OD effort? 

OD efforts are most effective when they encompass the entire organization becoming the basis for a strategic plan. OD can be just as effective when applied to a MES modernization project. In this application of OD, we facilitate stakeholder engagement with the intent of person-centered service, concurrent design for operations, processes, and training side-by-side with the systems design and development. This approach is also referred to as human-centered design (HCD).  

Regardless of the scope, OD reinforces benchmarks of high-performance organizations including: 

  • Transparent and data-informed decision making 
  • Developed leadership building connections with consistent expectations 
  • Culture of continuous improvement and innovation 
  • Team-based success and ownership for outcomes 
  • Person-centered service 

What does OD look like in action? 

We facilitate leaders to assess their organization through the eyes of stakeholders, particularly staff and people served. Collaboratively, with no blame or shame, the leaders articulate where they are today and where they need to be in the future, and build a roadmap or strategic plan to get there. In the assessment and roadmap we use the following six focal points of the organization:  

  • Excellent leadership 
  • Effective strategy 
  • A workforce that is confident, competent, consistent, and compassionate 
  • Quality operations and process improvement 
  • Person-centered service that results in a positive client experience 
  • Quality program outcomes for the communities served 

The roadmap or strategic plan typically includes talent development, and redesign of the infrastructure, including structure, processes, communication mechanisms, performance management processes, deployment of resources, and job skills development approaches.  

Talent development ensures that your leaders are aligned, prepared, and most importantly leading and inspiring their people toward that vision and the development of the workforce. Talent development provides staff with the skills, knowledge, and abilities needed, and reinforces positive attitudes, beliefs, and willingness to work together towards common goals. This might also include restructuring business process redesign, it might include expanding roles or shifting roles.  

Principles of lean are an important component of organization development when redesigning processes and helps organizations, such as state Medicaid agencies, do more with the current resources. With so many constraints placed on organizations, the lean approach is a critical component of optimizing existing resources and finding cost savings through changing “what we do” and “how we do it”, as opposed to cutting “what we do” or “changing who does it”. Resource optimization is just one of the benefits of organization development. 

Why is it important to redesign your organization and develop your staff when you're implementing a new technology system, such as a new Medicaid Enterprise System module? 

For state Medicaid Agencies, the organization goal isn't to modernize a system, the goal is for competent and compassionate staff serving clients and providers to improve health and wellness in our communities. Our goal is streamlined processes that improve accuracy and timeliness. Look at the outcomes of the program, then design the systems that enable business processes and the people who make that process happen every single day. We go back to why we are doing anything in the first place. Why do we need this change? What are we trying to accomplish? If we're trying to accomplish better service, a healthier community, and streamline processes so we are cost effective, then it leads us to modernizing our enterprise system and making sure that our people are prepared to be successful in using that system. Aligning to the organizational goals, or what we call the North Star, sets us up for success with the enterprise efforts and the human efforts. 

What can clients do to navigate some of the uncertainties of a modernization effort, and how can they prepare their staff for what's next? 

First articulate the goals or why you want the modernization, and build a foundation with aligned, and effective leaders. Assess the needs of the organization from a “social” or people perspective and a technical or systems perspective (note: BerryDunn uses a socio-technical systems design approach). Then, engage staff to develop a high-performance, team-based culture to improve lean processes. Design and develop the system to enable lean business processes and concurrently have operations design standard operating procedures, and develop the training needed to optimize the new system.  

Leaders must lead. If leaders are fragmented, if they are not effective communicators, if they do not have a sense of trust and connection with their workforce, then any change will be sub-optimized and probably will be a frustrating experience for all.  

If the workforce is in a place where staff live with suspicion or a lack of trust, or maybe some dysfunctional interpersonal skills, then they are not in a place to learn a new system. If you try to build a system based on a fragmented organizational structure or inconsistent processes, you will not achieve the potential of the modernization efforts and will limit how people view your enterprise system. The worst thing you can do is invest millions of dollars in the system based on a flawed organizational design or trying to get that system to just do what we've always done. 

By starting with building the foundation of engaging employees, not just to make people feel good, but also to help them understand how to improve their processes and build a positive workplace. Do we have the transparency in our data so that we understand what the actual problems are? Can employees articulate the North Star goals, the constraints, the reasons to update systems, then the organizations will have a pull for change as opposed to a push.

Medicaid agencies and other organizations can create a pull for change by engaging with their resources who can identify what gets in the way of serving the clients, i.e., what gets in the way of timeliness or adds redundancy or rework to the process. The first step is building that foundation, getting people leaning in, and understanding what's happening. By laying the foundation first, organizations help reduce the barriers between operations and systems, and ensure that they're working collaboratively toward organizational goals, always keeping the ‘why’ in mind and using measures to know when they are successful. 

How does a state focus on organization development when they are facing budget and staffing constraints? 

It is too easy to say, "invest in your people". In reality, the first thing that state Medicaid agencies or other organizations need do is redefine their sense of lean. Many inaccurately believe that lean means limited resources working really hard. Lean is tapping into the potential creativity and innovation of each staff member to look for ways to improve the process. Organizations should look at everything they do and ask “Does this add value to the end recipient of our service?” Even if I'm processing travel reimbursement requests, I still have a customer, I still have a need for timeliness and accuracy. If state Medicaid agencies can mobilize that type of focus with every single employee in their organization, they can achieve huge cost savings without the pain of cutting the workforce.   

In one state where BerryDunn’s organization development team provided this level and type of organizational transformation, there was a very deliberate focus on building this foundation prior to a large-scale system modernization.

By developing the leaders and training the employees in how to improve their processes, improve teamwork and trust, and align to the goal of a positive client experience, they were able to effectively implement the new system and seamlessly move to remote pandemic conditions. Once the state Medicaid agency had aligned the technical systems and the people systems to the organizational goals, they were successful and more resilient for future changes.   

You can learn more in Part II of our Outcomes and Organization Development podcast and article

If you have any questions, please contact our Medicaid consulting team. We're here to help.

Article
Outcomes and organization development 

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification or modernization efforts.

You can listen to the companion podcast to this article now:


Over the last two years, the Centers for Medicare and Medicaid Services (CMS) has undertaken an effort to streamline Medicaid Enterprise System (MES) certification. During this time, we have been fortunate enough to have been a trusted partner in several states working to evolve the certification process. Through this collaboration with CMS and state partners, we have been in front of recent certification trends. 

What is outcomes-based certification (OBC)? 

OBC (or streamlined modular certification) is a fascinating evolution in MES certification. OBC represents a fundamental rethinking of certification and how we measure the success of system implementation and modernization efforts. The prior certification approach, as many know it, is centrally focused on technical capability, answering the question, “Can the system perform the required functions?” 

OBC represents a shift away from this technical certification and toward business process improvement, instead answering the question, “How is this new technology enhancing the Medicaid program?” Or, put differently, “Is this new technology helping my Medicaid program achieve its desired outcomes?” 

What are the key differences between the MECT and OBC? 

To understand the differences, we have to first talk about what isn’t changing. Technical criteria still exist, but only so far as CMS is confirming compliance with core regulatory and statutory requirements—including CMS’ Standards and Conditions. That’s about the extent of the similarities. In addition to pivoting to business process improvement, we understand that CMS is looking to generalize certification under this new approach, meaning that we wouldn’t see the same Medicaid Information Technology Architecture (MITA)-tied checklists like Provider Management, or Decision Support Systems. Instead, we might expect more generalized guidance that would allow for a more tailored certification. 

Additionally, OBC introduces outcomes statements which serve as the guiding principles for certification. Everything, including the technical criteria, roll-up into an outcome statement. This type of roll up might actually feel familiar, as we see a similar structure in how Medicaid Enterprise Certification Toolkit (MECT) criteria rolled up into critical success factors. 

The biggest difference, and the one states need to understand above all else, is the use of key performance indicators (KPIs). These KPIs aren’t just point-in-time certification measures, they are expected to be reported against regularly—say, quarterly—in order to maintain enhanced funding. Additionally, it’s likely that each criterion will have an associated KPI, meaning that states will continue to be accountable to these criteria long after the Certification Final Review. 

How are KPIs developed? 

We’ve seen KPIs developed in two ways. For more strategic, high level KPIs, CMS develops a baseline set of KPIs heading into collaborating with a state on an OBC effort. In these instances, CMS has historically sought input on whether those KPIs are reasonable and can be easily reported against. CMS articulates what it wants to measure conceptually, and works with a state to ensure that the KPI achieves that within the scope of a state’s program.  

For KPIs specific to a state’s Medicaid program, CMS engages with states to draft new KPIs. In these instances, we’ve seen CMS partner with states to understand the business need for the new system, how it fits into the Medicaid enterprise, and what the desired outcome of the particular approach is. 

What should states consider as they plan for MES procurements? 

While there might be many considerations pertaining to OBC and procurements, two are integral to success. First—as CMS noted in the virtual MESC session earlier this month—engage CMS at the idea stage of a project. Experience tells us that CMS is ready and willing to collaborate with—and incorporate the needs of—states that engage at this idea stage. That early collaboration will help shape the certification path. 

Second, consider program outcomes when conceptualizing the procurement. Keep these outcomes central to base procurement language, requirements, and service level agreements. We’re likely to see the need for states to incorporate these outcomes into contracts. 

What does this mean for MES modularity and scalability? 

Based on our current understanding of the generalization of certification, states, and subsequently the industry at large, will continue to refine what modularity means based on Medicaid program needs. Scalability represents an interesting question, as we’ve seen OBC scaled horizontally across smaller, discrete business areas like pharmacy or provider management. Now we’re seeing the beginnings of vertical scaling of a more streamlined certification approach to larger components of the enterprise, such as financial management and claims processing. 

The certification landscape is seemingly changing weekly as states wait eagerly for CMS’ next guidance issuances. Please continue to check back for in-depth analyses and OBC success stories. Additionally, if you are considering an OBC effort and have questions, please contact our Medicaid Consulting team

Article
Considerations for outcomes-based certification

Read this if you are a State Medicaid Director, State Medicaid Chief Information Officer, State Medicaid Project Manager, or State Procurement Officer—or if you work on a State Medicaid Enterprise System (MES) certification effort.

Measuring performance of Medicaid Enterprise Systems (MES) is emerging as the next logical step in moving Medicaid programs toward modularity. As CMS continues to refine and implement outcomes-based modular certification, it is critical that states adapt to this next step in order to continue to meet CMS funding requirements.

This measurement, in terms of program outcomes, presents a unique set of challenges, many of which a state may not have considered before. A significant challenge is determining how and where to begin measuring program outcomes―to meet it, states can leverage a trusted, independent partner as they undertake an outcomes-based effort.

Outcomes-based planning can be thought of as a three-step process. First, and perhaps most fundamental, is to define outcomes. Second, you need to determine what measurements will demonstrate progress toward achieving those outcomes. And the final step is to create reporting measurements and their frequency. Your independent partner can help you answer these critical questions and meet CMS requirements efficiently by objectively guiding you toward realizing your goals.

  1. Defining Outcomes
    When defining an outcome, it is important to understand what it is and what it isn’t. An outcome is a benefit or added value to the Medicaid program. It is not an output, which is a new or enhanced function of a new MES module. An output is the product that supports the outcome. For example, the functionality of a new Program Integrity (PI) module represents an output. The outcome of the new PI module could be that the Medicaid program continuously improves based on data available because of the new PI module. Some outcomes may be intuitive or obvious. Others may not be as easy to articulate. Regardless, you need to direct the focus of your state and solution vendor teams on the outcome to uncover what the underlying goal of your Medicaid program is.
     
  2. Determining Measurements
    The second step is to measure progress. Well-defined Key Performance Indicators (KPIs) will accurately capture progress toward these newly defined outcomes. Your independent partner can play a key role by posing questions to help ensure the measurements you consider align with CMS’ goals and objectives. Additionally, they can validate the quality of the data to ensure accuracy of all measurements, again helping to meet CMS requirements.
     
  3. Reporting Measurements
    Finally, your state must decide how―and how often―to report on outcomes-based measurements. Your independent partner can collaborate with both your state and CMS by facilitating conversations to determine how you should report, based on a Medicaid program’s nuances and CMS’ goals. This can help ensure the measurements (and support information) you present to CMS are useful and reliable, giving you the best chance for attaining modular certification.

Are you considering an outcomes-based CMS modular certification, or do you have questions about how to best leverage an independent partner to succeed with your outcomes-based modular certification effort? BerryDunn’s extensive experience as an independent IV&V and Project Management Office (PMO) partner includes the first pilot outcomes-based certification effort with CMS. Please visit our IV&V and certification experts at our booth at MESC 2019 or contact our team now.

Article
Three steps to measure Medicaid Enterprise Systems outcomes