ACA Compliance

What is being mandated for T-MSIS and State Medicaid agencies and Children’s Health Insurance Programs and how can you achieve compliance?

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T-MSIS, State Medicaid agencies, CHIP programs and health plans

The mandate

T-MSIS, which stands for Transformed Medicaid StatisticalInformation System, is an expansion of the existing Centersfor Medicare & Medicaid (CMS) MSIS extract. T-MSIS ismandated by CMS and the Affordable Care Act (ACA), and is a natural extension of current Decision Support Systems (DSS) and data warehouse solutions in state agencies today.

As part of the CMS plan to improve and expand upon itsMedicaid data repository, states are required to augment the current MSIS data extracts. States may delegate the T-MSIS reporting requirement to health plans providing Medicaid or Children’s Health Insurance Program (CHIP) coverage.

Historically, each state (or designated health plan),submits five MSIS extracts to CMS on a quarterly basis. These data are used by CMS to assist in federal reporting for the Medicaid and CHIP. Several reasons culminated in the CMS mission to improve the repository, including incomplete data, questionable results, multiple data collections from states, multiple federal data platforms and analytic difficulties in interpreting and presenting the results. In addition, timeliness issues have prompted CMS to re-evaluate its processes and move toward a streamlined delivery, along with an enhanced data repository.

The new T-MSIS extract format and frequency areexpected to further CMS goals for improved timeliness,reliability and robustness through monthly updates and anincrease in the amount of data requested.

Fortunately, IBM® Watson Health™ has extensive experience in this area and can support states and delegated health plans, in achieving compliance with federal requirements.

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Achieving complianceThe IBM Watson Health experience and expertise can help states and delegated health plans meet the T-MSIS federal requirements efficiently and allow for ad-hoc modifications as needed. We have assisted several other states with the existing MSIS quarterly submission process, including verifying error tolerances and distributions of valid values. Additionally, our experience with MSIS expands beyond the individual state level; we are helping other delegated health plans meet the T-MSIS requirements and have completed a number of MSIS projects for CMS, including projects to help the agency improve the quality of managed care encounter data submitted by the states.

Specifically, IBM Watson Health can support your organization in delivering the new T-MSIS extracts by:

– Designing and developing new extracts. We can help your organization ensure that the data required for T-MSIS is captured and stored according to CMS specifications. CMS has expanded the field list from approximately 400 fields to more than 1,000 to support more comprehensive and robust reporting. Plus, modifications continue to be made to the T-MSIS data dictionary. You can utilize our knowledge of state program data and T-MSIS modifications to help enable efficient execution while supporting your organization’s investment and strategy.

– Providing monthly extracts. With T-MSIS, the frequency of updates will move from quarterly to monthly. Additionally, CMS will incorporate automatic data quality checks and provide real-time feedback to the states and delegated health plans. IBM Watson Health can not only support these monthly updates, but will also work with CMS to review and correct any data quality issues.

– Delivering outbound files to CMS. IBM Watson Health can work with CMS (or its designated vendors) to validate and document file transmission requirements. (We will also update and maintain the specifications over the life of our contract). Additionally, we can develop and apply data quality and validity checks for the output file, incorporating the appropriate business rules. We are also skilled at establishing submission processes with built-in controls and checks to assure complete delivery.

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– Expanding the dataset to include eight files and additional data elements. The T-MSIS extracts will increase from five to eight files. IBM Watson Health will provide extracts for eligibility and claims (including inpatient, long-term care, outpatient and pharmacy) data, along with the new data requirements—third- party liability provider and managed care plan. With the expanded field list and ongoing data dictionary modifications, IBM Watson Health can work with you to evaluate any new or missing data elements.

– Attending CMS-sponsored teleconferences. IBM Watson Health can attend CMS teleconferences, as available, to understand requirements, assist in defining submission criteria and to identify questions and/or issues.

– Developing mapping documents. The CMS data dictionary outlines data elements that will be standardized across all states for submission. Mapping documents are needed to align state program- specific data elements to these fields for complete and accurate data extract submission. We can work with the state or delegated health plan, CMS and the current MMIS vendor (if needed) to develop mapping documents that capture the data accurately and meet CMS requirements to support consistent reporting across states.

– Working with you to adjust processes and align with future changes. To accommodate future requirements and modifications, IBM Watson Health is poised to work with states and delegated health plans to determine the scope of work associated with these changes via strategic change management processes.

– Helping you respond to T-MSIS-related federal mandates. IBM Watson Health can help your organization respond to T-MSIS-related federal mandates, as appropriate. A sample of existing T-MSIS- related mandates and how we can assist you are briefly described on the following page.

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Requirements Description IBM Watson Health Analytics SupportBBA Section 4753(a) Requires states to submit electronic claims data transmission

consistent with the MSIS as of 1/1/1999Deliver T-MSIS extracts electronically

ACA Section 6402(c)

Provides for withholding federal matching payments for medical assistance to states that fail to report enrollee encounter data in the Medicaid Statistical Information System (MSIS) in a timely manner

Deliver T-MSIS extracts in a timely manner, report all managed care encounter data provided by the managed care organizations (MCOs) and passed to the DSS and continue to work with the state, the MMIS contractor (if needed) and the MCOs to make continued improvements in encounter data quality and completeness

ACA Section 6504(a)

Data submitted to CMS after 1/1/2010 must include the elements CMS determines necessary for program integrity, program oversight and administration in order for the state to receive Federal Financial Participation (FFP)

Meet the current T-MSIS requirements and work with the state to meet future requirements as needed

ACA Section 6504(b)

Mandates that a service entity provide sufficient patient encounter data to the state to identify the physician who delivers services to patients and that the provision of such data to the state is at a frequency and level of detail to be specified by CMS

Ensure T-MSIS extracts provide sufficient patient encounter data as defined in the requirements

ACA Section 402(c) Provides for improvement to the timeliness of reporting and analyzing of data related to enrollment and eligibility of children under Medicaid and CHIP

Deliver T-MSIS extracts in a timely manner, consistent with federal requirements

ACA Section 4302 Mandates identifying, collecting and evaluating health disparities data under Medicaid and CHIP on the basis of race, ethnicity, sex, primary language and disability status

Ensure T-MSIS extracts contain all available data and work with the state to obtain any data elements not currently available to support T-MSIS requirements

ACA Section 2602 Mandates that states support the office specifically established under ACA for providing federal coverage and payment coordination for dual-eligible beneficiaries

Ensure dual-eligibles are included in T-MSIS extracts as defined in the requirements

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