Chapter 8 - CMS Certification Milestone 6: Certification Visit

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Primary Guidelines Medicaid Enterprise Certification Roadmap, Chapter 3, Third Protocol
Primary Methodology State- or Vendor-specific Methodology
Input MECT Checklists, (linked to solution proof points and certification artifacts)
Primary Activities Familiarizing state and CMS teams with the Medicaid solution via ReadyCert, preparing state and CMS teams for pre-certification meeting and onsite visit
Output Final MECT Checklists, (linked to solution proof points and certification artifacts, updated if applicable with information to aid state and CMS teams)
Downstream Activities Supported CMS Certification Visit

Introduction

The Medicaid Enterprise Certification Roadmap culminates with the onsite certification visit. The purpose of the visit is for the CR Team to evaluate the new or replacement Medicaid solution and make a certification decision. The majority of the steps in this protocol describe how the CR Team conducts the site visit, makes its recommendations and prepares its findings.

Figure 6-1: States must achieve 6 CMS certification milestones to receive federal funds for their IT investments

While the pre-certification meeting may be conducted via web or telephone conference, the final certification visit is conducted onsite. The Medicaid Enterprise Certification Toolkit, Chapter 3, Third Protocol, provides the guidelines for the certification visit.[1]

During this visit, ReadyCert is used by the CR Team to evaluate the Medicaid solution. It enhances the certification experience by providing an easy way for the CR Team to view as many SRC as desired and validate the functionality of them.

The state shows the CR Team how to trace the MECT Checklist SRC back to the To-Be assessment from the SS-A. This step provides an enhanced level of review as the CR Team is able to view the solution as part of a MITA maturity continuum. ReadyCert allows the CR Team to evaluate the level of maturity planned, (as defined in the To-Be assessment), and determine if the deployed solution delivers the To-Be functionality.

The traceability from the SRC to the To-Be assessments is especially valuable for certifying the Medicaid solution against the Seven Conditions. The Seven Conditions attributes for each business process are automatically linked to the applicable SRC, allowing the CR Team to evaluate the SMA’s compliance with the Seven Conditions for enhanced FFP.

ReadyCert eliminates the need to repeat like-work activities. Completed MECT Checklists have been finalized as part of Milestone 5, Pre-Certification Visit. These carry forward to Milestone 6 and require no additional work activity. The proof points have been linked to the MECT Checklist SRC and all required fields have been filled in.

This section of ReadyCert 6CM is organized in accordance with the steps in the Third Protocol of Chapter 3 of the Medicaid Enterprise Certification Toolkit. The approach for using ReadyCert in each of these steps is described. The overall project management methodology is used to direct the total work effort.

Conduct Entrance Conference (Third Protocol, Step 9)

The CMS onsite visit begins with an entrance conference. The state and CR teams meet to review the schedule, the expectations for the visit and the process the CR Team will use to conduct the visit. The Medicaid Enterprise Certification Toolkit, Chapter 3, Third Protocol, provides the guidelines that the CR Team will follow.

The state team creates a Certification Review copy of ReadyCert and adds CR Team-specific fields to the MECT Checklists. The Certification Review copy is used throughout the remainder of this milestone. The following CR Team-specific fields are used in the next step.

  • Yes/No
  • Comments
  • Action Items
  • Strong Points
  • Weak Points

The state provides an overview of the ReadyCert tool and how to use it to evaluate the MECT Checklist items that comprise the Medicaid solution.

Evaluate the Medicaid Solution (Third Protocol, Step 10)

The CR Team performs a hands-on evaluation of the new or replacement Medicaid solution. The protocol details certain expectations that CMS has for this step, including interviewing members of the state team. The overall project management methodology and the agreements made between the state and CR Team during the pre-certification meeting guide the overall process.

CMS requires evidence that the Medicaid solution:

  • Fills gaps between the As-Is and To-Be states, as described in the Gap Analysis;
  • Enhances the State Medicaid Enterprise's maturity, as described in the MITA Maturity Roadmap;
  • Achieves the state’s goals and objectives for the procurement, as described in the APD;
  • Functions as intended, as described in the APD and RFP.

One of the most important requirements in this step is to create “folders” for the CR Team. The folders are intended to demonstrate, in the opinion of the state, that each applicable criterion of each applicable Checklist is satisfied.

ReadyCert takes the place of folders. All of the information captured in ReadyCert up to this point is available to the CR Team to perform its evaluation. The certification visit is conducted using the results of the work activities that came before it. The CR Team views the same information that is available to the state team. There is no need to re-create information or use a different tool to record findings. Additionally, the ability to trace evaluated MECT Checklist SRC back to the SS-A leaves no room for interpretation. The deployed solution’s functionality is clearly linked to the planned level of maturity.

The CR Team assigns specific sections to individual reviewers. Each reviewer has access to ReadyCert, as well as to state staff assigned to support the evaluation of specific business areas. (The process for selecting MECT Checklist items for review is developed and managed by the CR Team). The reviewer selects a MECT Checklist item, examines the SRC and views the artifacts and evidence associated with the SRC to determine if the Medicaid solution is compliant with the SRC. When the determination is made, the reviewer takes the following actions:

  • Yes/No– enter an indication of compliance with the SRC in the MECT Checklist
  • Comments– if “No” is entered in the field above, describe the nature of the failure
  • Action Items– enter free form text if more information is required before a determination can be made
  • Strong Points– enter information about features and functions that may be beneficial to other states
  • Weak Points– enter information about features and functions that should be avoided by other states[2]

This process is repeated for all of the MECT Checklist items assigned to the reviewer. If additional information is required, the reviewer may seek it during the onsite visit or wait until Step 12, Analyze Data.

Conduct Exit Conference (Third Protocol, Step 11)

The state and CR Team meet at the end of the evaluation step and formally conclude the onsite visit.

Analyze Data (Third Protocol, Step 12)

After the CR Team returns from the onsite visit, the team reviews the data collected. ReadyCert is used as the primary tool during this step.

Standard reports are generated via ReadyCert to identify the “No” and “Action Item” entries. The reports identify each unsatisfactory SRC by MITA business process, business objective and MECT Checklist number. The CR Team analyzes the unsatisfactory results and determines if more information is needed from the state before a final decision can be made.

The CR Team produces a Corrective Action Plan for those items that need to be modified before the CR team renders a certification decision. The CR Team assigns the Corrective Action Plan items via ReadyCert. They are automatically moved to the state team’s “inbox” for action.

Resolve Issues (Third Protocol, Step 13)

The state team accesses the CAP items in ReadyCert and prepares sub-plans to correct each deficiency noted. The date that corrective action is expected is entered in ReadyCert and tracked as part of the overall PMP by the PMO.

The state corrects the problems identified by the CR Team. This is an iterative process between the state and CR Team. ReadyCert is updated whenever an action is taken and new artifacts or evidence are available to support the corrective action.

When all CAP items are resolved, the CR Team re-evaluates the MECT Checklists SRC using ReadyCert and updates its decisions.

Make Certification Decision (Third Protocol, Step 14)

The CR Team meets and evaluates each MITA business process area. The team looks for problems that may prevent certification. If none are found, the CR Team moves on to the next business area. When all business areas have been reviewed and adjudicated, the CR Team is ready to make a certification decision. ReadyCert is used to summarize, detail, display and otherwise report MECT Checklists evaluation results that influence and inform the certification decision.

Prepare Final Certification Review Report (Third Protocol, Step 15)

The results of the certification are documented in a report that outlines the areas assessed, information reviewed and the results of the evaluation. The CR Team may use reports generated via ReadyCert in the final report or may provide a Certification review copy of ReadyCert in the final report.

The report contains the decision to approve, conditionally approve, disapprove or approve the Medicaid solution on a date later than that requested. The CR Team Lead submits the final report to the appropriate CMS Director for review and approval.

Prepare Response to the State (Third Protocol, Step 16)

The CR Team Lead writes a formal response, to be signed by the appropriate CMS Director, to communicate the certification decision to the appropriate RO. The response and final certification report are transmitted to the RO Deputy Regional Administrator, who, in turn, communicates the decision and sends the report to the state.

Conclude the Process

The CR Team completes the national profile for the state Medicaid solution evaluated, gathers all of the records used in the evaluation and files them in the designated area. A Certification review copy of ReadyCert is filed as part of this step. Once the CR Team completes this step, the appropriate CMS Director disbands the CR Team and the Medicaid Enterprise Certification Roadmap is concluded.

It begins again when the state requests approval and funding for a new or replacement Medicaid solution.

Notes

  1. http://www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/MMIS/Downloads/mectchapter3.pdf
  2. Note: strong and weak points do not indicate that SRC have or have not been satisfied. They are used by CMS to advise and inform future decisions and interactions with states.