| | Exhibit 300 (BY2010) for CMS ICD-10 InitiativePART ONE
OVERVIEW
- 1. Date of Submission:
- 2008-09-08
- 2. Agency:
- 009
- 3. Bureau:
- 38
- 4. Name of this Capital Asset:
- CMS ICD-10 Initiative
- 5. Unique Project Identifier:
- 009-38-01-02-01-2110-00
- 6. What kind of investment will this be in FY2010?
- Planning
- 7. What was the first budget year this investment was submitted to OMB?
- FY2009
- 8. Provide a brief summary and justification for this investment, including a brief description of how this closes in part or in whole an identified agency performance gap.
- The coding system for payment of claims used in the US is ICD-9; ICD codes are used to classify diagnoses across all providers, however ICD procedure codes are used in inpatient settings only. Developed 30 years ago, the code set has changed to keep pace with new diseases as well as medical technologies and innovations used to treat, screen, test for or diagnose disease. The code set has a structure that limits the number of physical codes that may be assigned, both overall and by chapter. CMS predicts that at the current rate of adding new medical procedures, the healthcare industry will run out of ICD-9 procedure codes by 2009. Once this occurs new procedures won't be assigned new codes, but instead be forced to use existing inpatient procedure codes for payment. This poses a great risk to proper and accurate payments, and could have a significant impact on health care financing. This project is dependent upon the 5010 project. 5010 is an update to the HIPAA suite of transactions, which provides for a standardized electronic format for data exchange; ICD-10 will be the first standard to use 5010 enhancements. CMS' current systems won't accept ICD-10 structure; thus unless CMS systems are changed for 5010, implementation of ICD-10 will not be possible. ICD codes exist where diagnosis and inpatient procedure information is required, processed and reported by CMS systems; thus, CMS is modifying existing systems, not building new ones. Once code conversion is completed this investment will end and maintaining the codes will resume within the respective shared systems investments responsible for Medicare Part A, B and Durable Medical Equipment (DME) claims processing operations according to the current O&M schedule/process. This project will identify where ICD codes are used within CMS processes and systems, assess the impact of transitioning to ICD-10, develop an implementation strategy and implement the transition to ICD-10. Although, 5010 will address the changes needed to accommodate the ICD-10 physical structure (which is very different from ICD-9), it will not address the numerous instances of algorithmic computations and analyses performed on data containing ICD codes, and used for quality, reporting, fraud and abuse detection. This project supports the PMA initiative of improper payments; an ICD-10 implementation will improve CMS' ability to accurately compensate Medicare providers, and reduce the incidence of improper payments.
- 9. Did the Agency's Executive/Investment Committee approve this request?
- yes
- 9.a. If "yes," what was the date of this approval?
- 2008-04-10
- 10. Did the Project Manager review this Exhibit?
- yes
- 11.a. What is the current FAC-P/PM certification level of the project/program manager?
- Waiver Issued
- 11.b. When was the Program/Project Manager Assigned?
- 2008-01-04
- 11.c. What date did the Program/Project Manager receive the FACP/PM certification? If the certification has not been issued, what is the anticipated date for certification?
- 2009-07-31
- 12. Has the agency developed and/or promoted cost effective, energy-efficient and environmentally sustainable techniques or practices for this project.
- no
- 12.a. Will this investment include electronic assets (including computers)?
- yes
- 12.b. Is this investment for new construction or major retrofit of a Federal building or facility? (answer applicable to non-IT assets only)
- no
- 13. Does this investment directly support one of the PMA initiatives?
- yes
- If yes, select the initiatives that apply:
| Initiative Name |
|---|
| Eliminating Improper Payments |
- 13.a. Briefly and specifically describe for each selected how this asset directly supports the identified initiative(s)? (e.g. If E-Gov is selected, is it an approved shared service provider or the managing partner?)
- ICD-10 provides a more robust, granular, modern, and accurate code set, and because of its increased specificity it will improve the accuracy of information reported on claims. ICD-10 will also improve quality monitoring, coverage, risk adjustment, research, and statistical reporting, all of which feed back into payment policy and operations. The benefits of ICD-10 will not be apparent for at least a couple of years post implementation due to the volume of data required for such an analysis.
- 14. Does this investment support a program assessed using the Program Assessment Rating Tool (PART)?
- yes
- 14.a. If yes, does this investment address a weakness found during the PART review?
- yes
- 14.b. If yes, what is the name of the PARTed program?
- 10000470 - Medicare Integrity Program
- 14.c. If yes, what rating did the PART receive?
- Effective
- 15. Is this investment for information technology?
- yes
- 16. What is the level of the IT Project (per CIO Council's PM Guidance)?
- Level 3
- 17. What project management qualifications does the Project Manager have? (per CIO Council's PM Guidance)
- (2) Project manager qualification is under review for this investment
- 18. Is this investment identified as high risk on the Q4 - FY 2007 agency high risk report (per OMB memorandum M-05-23)?
- yes
- 19. Is this a financial management system?
- no
- 20. What is the percentage breakout for the total FY2009 funding request for the following? (This should total 100%)
| Area | Percentage |
|---|
| Hardware | 0 | | Software | 0 | | Services | 100 | | Other | 0 |
- 21. If this project produces information dissemination products for the public, are these products published to the Internet in conformance with OMB Memorandum 05-04 and included in your agency inventory, schedules and priorities?
- n/a
- 22. Contact information of individual responsible for privacy related questions.
| Name | Maribel Franey | | Phone Number | 410-786-0757 | | Title | Privacy Officer | | Email | maribel.franey@cms.hhs.gov |
- 23. Are the records produced by this investment appropriately scheduled with the National Archives and Records Administration's approval?
- yes
- 24. Does this investment directly support one of the GAO High Risk Areas?
- yes
SUMMARY OF SPEND
- 1. Provide the total estimated life-cycle cost for this investment by completing the following table. All amounts represent budget authority in millions, and are rounded to three decimal places. Federal personnel costs should be included only in the row designated Government FTE Cost, and should be excluded from the amounts shown for Planning, Full Acquisition, and Operation/Maintenance. The total estimated annual cost of the investment is the sum of costs for Planning, Full Acquisition, and Operation/Maintenance. For Federal buildings and facilities, life-cycle costs should include long term energy, environmental, decommissioning, and/or restoration costs. The costs associated with the entire life-cycle of the investment should be included in this report.
All amounts represent Budget Authority
Note: For the cross-agency investments, this table should include all funding (both managing partner and partner agencies).
Government FTE Costs should not be included as part of the TOTAL represented. | Cost Type | Py-1 & Earlier -2007 | PY 2008 | CY 2009 | BY 2010 |
|---|
| Planning Budgetary Resources | 3.200 | 0.000 | 1.000 | 0.750 | | Acquisition Budgetary Resources | 0.000 | 0.000 | 15.600 | 18.000 | | Maintenance Budgetary Resources | 0.000 | 0.000 | 0.000 | 0.000 | | Government FTE Cost | 0.310 | 0.310 | 2.200 | 2.200 | | # of FTEs | 3 | 3 | 22 | 22 |
- 2. Will this project require the agency to hire additional FTE's?
- no
- 3. If the summary of spending has changed from the FY2008 President's budget request, briefly explain those changes.
- The costs in this chart reflect the IT cost estimates associated with this project assuming an implementation date of October 1, 2011.
PERFORMANCE In order to successfully address this area of the exhibit 300, performance goals must be provided for the agency and be linked to the annual performance plan. The investment must discuss the agency's mission and strategic goals, and performance measures (indicators) must be provided. These goals need to map to the gap in the agency's strategic goals and objectives this investment is designed to fill. They are the internal and external performance benefits this investment is expected to deliver to the agency (e.g., improve efficiency by 60 percent, increase citizen participation by 300 percent a year to achieve an overall citizen participation rate of 75 percent by FY 2xxx, etc.). The goals must be clearly measurable investment outcomes, and if applicable, investment outputs. They do not include the completion date of the module, milestones, or investment, or general goals, such as, significant, better, improved that do not have a quantitative measure.- Agencies must use the following table to report performance goals and measures for the major investment and use the Federal Enterprise Architecture (FEA) Performance Reference Model (PRM). Map all Measurement Indicators to the corresponding Measurement Area and Measurement Grouping identified in the PRM. There should be at least one Measurement Indicator for each of the four different Measurement Areas (for each fiscal year). The PRM is available at www.egov.gov. The table can be extended to include performance measures for years beyond FY 2009.
| Row | Fiscal Year | Strategic Goal Supported | Measurement Area | Measurement Grouping | Measurement Indicator | Baseline | Planned Improvement to the Baseline | Actual Results |
|---|
| 1 | 2008 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Higher Education | % of CMS components assessed for business process impacts | 10% | 100% | 80% | | 2 | 2008 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Training | % of CMS components identified for training | 10% | 100% | 80% | | 3 | 2008 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Costs | % of CMS components assessed for cost implications of transitioning to ICD-10 | 10% | 100% | 50% | | 4 | 2008 | Effective Management of Human Capital/Information Technology/Resources | Technology | Data Standardization or Tagging | % of CMS systems assessed for an impact of transitioning to ICD-10 | 10% | 100% | 80% | | 5 | 2009 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Health Care Administration | % of impacted CMS contracts that inlcude language or tasks that scope out work needed to transition to ICD-10 | 0% | 100% | TBD | | 6 | 2009 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Impact or Burden | % of outreach and education materials available to MACs/FIs/Carriers on the differences between ICD-9 and ICD-10 | 10% | 50% | TBD | | 7 | 2009 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Risk | % of impacted CMS components that initiated Business Process Redesign activities to plan changes needed due to the transition to ICD-10 | 10% | 60% | TBD | | 8 | 2009 | Effective Management of Human Capital/Information Technology/Resources | Technology | Data Standardization or Tagging | % of impacted CMS systems that initiated requirements gathering activities | 10% | 100% | TBD | | 9 | 2010 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Health Care Administration | % of impacted CMS components implementing changes to business processes and systems to accomodate ICD-10 | 30% | 75% | TBD | | 10 | 2010 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Training | % of impacted CMS components trained on the differences between ICD-9 and ICD-10 | 15% | 100% | TBD | | 11 | 2010 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Knowledge Management | % of coordination across CMS shared system maintainers | 0% | 50% | TBD | | 12 | 2010 | Effective Management of Human Capital/Information Technology/Resources | Technology | Data Standardization or Tagging | % of impacted CMS systems that initiated system testing | 0% | 75% | TBD | | 13 | 2011 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Health Care Administration | % of impacted CMS components monitoring issues encountered | 0% | 75% | TBD | | 14 | 2011 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Training | % of ICD-10 outreach and educational materials available on the CMS website | 50% | 95% | TBD | | 15 | 2011 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Compliance | % of impacted CMS Business Partners ready to submit ICD-10 codes | 0% | 75% | TBD | | 16 | 2011 | Effective Management of Human Capital/Information Technology/Resources | Technology | Data Standardization or Tagging | % of CMS systems ready to accept ICD-10 codes | 35% | 95% | TBD | | 17 | 2012 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Help Desk Services | % of provider inquiries due to coding questions | 75% | 25% | TBD | | 18 | 2012 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Impact or Burden | % of unpaid claims based on insufficient provider systems | 75% | 25% | TBD | | 19 | 2012 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Errors | % of improper claims | 75% | 25% | TBD | | 20 | 2012 | Effective Management of Human Capital/Information Technology/Resources | Technology | Internal Data Sharing | % of reports or file extracts to facilitate data sharing and quality across CMS | 50% | 80% | TBD | | 21 | 2013 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Population Health Management and Consumer Safety | % of claims data used in quality monitoring and reporting | 20% | 50% | TBD | | 22 | 2013 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Complaints | % of complaints directed at CMS resulting from unpaid claims | 60% | 40% | TBD | | 23 | 2013 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Errors | % of errors in internal processing of claims and payments utilizing ICD-10 codes | 40% | 25% | TBD | | 24 | 2013 | Effective Management of Human Capital/Information Technology/Resources | Technology | Standards Compliance and Deviations | % of CMS Business Partners in compliance with ICD-10 standards | 60% | 75% | TBD | | 25 | 2014 | Effective Management of Human Capital/Information Technology/Resources | Mission and Business Results | Population Health Management and Consumer Safety | % of claims data used in quality monitoring and reporting | 50% | 80% | TBD | | 26 | 2014 | Effective Management of Human Capital/Information Technology/Resources | Customer Results | Customer Complaints | % of complaints directed at CMS resulting from unpaid claims | 40% | 20% | TBD | | 27 | 2014 | Effective Management of Human Capital/Information Technology/Resources | Processes and Activities | Errors | % of errors in internal processing of claims and payments utilizing ICD-10 codes | 25% | 10% | TBD | | 28 | 2014 | Effective Management of Human Capital/Information Technology/Resources | Technology | Standards Compliance and Deviations | % of CMS Business Partners in compliance with ICD-10 standards | 75% | 100% | TBD |
Enterprise Architecture In order to successfully address this area of the business case and capital asset plan you must ensure the investment is included in the agency's EA and Capital Planning and Investment Control (CPIC) process, and is mapped to and supports the FEA. You must also ensure the business case demonstrates the relationship between the investment and the business, performance, data, services, application, and technology layers of the agency's EA. - 1. Is this investment included in your agency's target enterprise architecture?
- yes
- 2. Is this investment included in the agency's EA Transition Strategy?
- no
- 2.b. If no, please explain why?
- Investment identified after the most recent transition plan and will be included in the next release
- 3. Is this investment identified in a completed (contains a target architecture) and approved segment architecture?
- no
- 4. Identify the service components funded by this major IT investment (e.g., knowledge management, content management, customer relationship management, etc.). Provide this information in the format of the following table. For detailed guidance regarding components, please refer to http://www.whitehouse.gov/omb/egov/.
Component: Use existing SRM Components or identify as NEW. A NEW component is one not already identified as a service component in the FEA SRM.
Reused Name and UPI: A reused component is one being funded by another investment, but being used by this investment. Rather than answer yes or no, identify the reused service component funded by the other investment and identify the other investment using the Unique Project Identifier (UPI) code from the OMB Ex 300 or Ex 53 submission.
Internal or External Reuse?: Internal reuse is within an agency. For example, one agency within a department is reusing a service component provided by another agency within the same department. External reuse is one agency within a department reusing a service component provided by another agency in another department. A good example of this is an E-Gov initiative service being reused by multiple organizations across the federal government.
Funding Percentage: Please provide the percentage of the BY requested funding amount used for each service component listed in the table. If external, provide the funding level transferred to another agency to pay for the service. | Row | Agency Component Name | Agency Component Description | Service Type | Component | Reused Component Name | Reused UPI | Internal or External Reuse? | Funding % |
|---|
| 1 | ICD-10 Project Record Linking / Association Services | Defines the set of capabilities that support the correlation between logical data and information sets. | Records Management | Record Linking / Association | | | No Reuse | 25 | | 2 | ICD-10 Project Data Exchange Services | Defines the set of capabilities that support the interchange of information between multiple systems or applications; includes verification that transmitted data was received unaltered. | Data Management | Data Exchange | | | No Reuse | 25 | | 3 | ICD-10 Project Information Sharing Services | Defines the set of capabilities that support the use of documents and data in a multi-user environment for use by an organization and its stakeholders. | Knowledge Management | Information Sharing | | | No Reuse | 15 | | 4 | ICD-10 Project Information Retrieval Services | Defines the set of capabilities that allow access to data and information for use by an organization and its stakeholders. | Knowledge Management | Information Retrieval | | | No Reuse | 20 |
- 5. To demonstrate how this major IT investment aligns with the FEA Technical Reference Model (TRM), please list the Service Areas, Categories, Standards, and Service Specifications supporting this IT investment.
FEA SRM Component: Service Components identified in the previous question should be entered in this column. Please enter multiple rows for FEA SRM Components supported by multiple TRM Service Specifications.
Service Specification: In the Service Specification field, Agencies should provide information on the specified technical standard or vendor product mapped to the FEA TRM Service Standard, including model or version numbers, as appropriate. | Row | SRM Component | >Service Area | Service Category | Service Standard | Service Specification (i.e., vendor and product name) |
|---|
| 1 | Record Linking / Association | Component Framework | Data Management | Database Connectivity | Connect:Direct by: Sterling Commerce | | 2 | Data Exchange | Component Framework | Data Interchange | Data Exchange | File Transfer Protocol (FTP) by: The Internet Engineering Task Force | | 3 | Data Exchange | Component Framework | Data Interchange | Data Exchange | Connect:Direct by: Sterling Commerce | | 4 | Information Sharing | Component Framework | Data Interchange | Data Exchange | File Transfer Protocol (FTP) by: The Internet Engineering Task Force | | 5 | Information Sharing | Component Framework | Data Interchange | Data Exchange | Connect:Direct by: Sterling Commerce | | 6 | Information Retrieval | Component Framework | Data Interchange | Data Exchange | File Transfer Protocol (FTP) by: The Internet Engineering Task Force | | 7 | Information Retrieval | Component Framework | Data Interchange | Data Exchange | Connect:Direct by: Sterling Commerce |
- 6. Will the application leverage existing components and/or applications across the Government (i.e., FirstGov, Pay.Gov, etc)?
- no
PART TWO
RISK You should perform a risk assessment during the early planning and initial concept phase of the investment's life-cycle, develop a risk-adjusted life-cycle cost estimate and a plan to eliminate, mitigate or manage risk, and be actively managing risk throughout the investment's life-cycle.Answer the following questions to describe how you are managing investment risks. - 1. Does the investment have a Risk Management Plan?
- yes
- 1.a. If yes, what is the date of the plan?
- 2008-08-06
- 1.b. Has the Risk Management Plan been significantly changed since last year's submission to OMB?
- no
- 3. Briefly describe how investment risks are reflected in the life cycle cost estimate and investment schedule:
- While this investment is still in the planning stages, the cost estimates were developed based on input from experienced project managers whose areas will be affected by the implementation of ICD-10 codes. The project managers assumed low funding risks and applied inflationary factors to develop out year costs. A full risk analysis is under way which may impact cost estimates. Costs will be revisited once we have the complete results of the impact analysis.
COST & SCHEDULE
- 1. Does the earned value management system meet the criteria in ANSI/EIA Standard 748?
- yes
- 2. Is the CV% or SV% greater than ± 10%?
- yes
- 2.a. If yes, was it the?
- CV
- 2.b. If yes, explain the variance.
- Based on project delays and contractor performance, on February 25, 2008, a contract modification was signed essentially reducing the scope of work to be performed in the base year. Milestones 6, 7 and 10 were removed and milestones 8 and 9 were reduced in scope. The planned costs for milestones 6, 7 and 10 were reallocated to milestones 2-5 in a recent re-baseline. Thus, actual costs exceed planned costs for milestones 2-5. The actual end date of 2/25/08 for milestones 6, 7, and 10 represents the date when the modification was signed and these tasks were removed from the scope of the project; they were never initiated. Milestones 8 and 9 have been modified sufficiently due to issues around contractor conflict of interest, but their planned costs remain unchanged.
- 2.c. If yes, what corrective actions are being taken?
- Milestones 6 and 7 will be completed by another entity that will deliver on milestones 25 and 26. What is remaining on milestones 8-10 will not be executed; CMS will provide training to external entities within its normal protocol around rule making. Milestones 11-14 will not be executed.
- 3. Has the investment re-baselined during the past fiscal year?
- yes
- 3.a. If yes, when was it approved by the agency head?
- 2008-07-23
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