Feedback to Regional Healthcare Partnership (RHP) Anchors and Performing Providers

from HHSC’s Initial Review of Pass 1 Projects

Steps in Feedback

  1. HHSC is providing this immediate guidance to all RHPs based on a high level review of the DSRIP projects that have been submitted.
  2. HHSC plans to provide each RHP preliminary feedbackin the next one to two weeks on Executive Summary (Section II) and DSRIP Projects (Section V) based on its high level review. (See end of document.)
  3. HHSC will provide official feedback(full technical review of projects and review of the RHP plan as a whole) within 30 days of the full RHP Plan submission as specified in Program and Funding Mechanics (PFM) Protocol.

Immediate Guidance

HHSC appreciates that this is a new initiative and that RHPs are working under tight deadlines with many diverse participants. Although some projects are well presented, the high level review of projects has revealed substantial incompleteness in many project descriptions. It has been challenging for the reviewers to determine the scope of the project (e.g. current activities vs. new, how many served), intervention and expected patient benefits of the projects. HHSC is concerned that without revisions, many Pass 1 projects may not be approved by the Centers for Medicare and Medicaid Services (CMS) or approval may be delayed.

HHSC is providing this immediate guidance so that RHPs can work in December to get their projects in the best shape possible for full plan submission by December 31, 2012. This will facilitate HHSC and CMS review and approval of the plans.

Summary Information Requested for Every Category 1 and 2 Project

It is important that project narrativesclearly describe the project intervention to support the value of the project. HHSC requests that for the full RHP plan submission, all projects (including Pass 1 projects)includethe following key project information at the beginning of the Section V Project Description. (You may use up to one additional page for this information.)

  • A brief description of the provider, including the provider’s size and role as a provider in the region’s health care infrastructure
  • Clearly state the intervention(s).
  • A brief description of the need for the project including data as appropriate
  • Who is the target population for the project, including:
  • Number of patients the project will serve
  • How Medicaid and/or indigent patients will benefit from the project
  • Clearly state the expected benefit of the project to patients based on:
  • Category 1 or 2 milestones
  • Category 3 outcome measures

Summary Information Example:

  • Provider: Hospital ABC is a 40-bed hospital in CDF Town serving a25 square mile area and a population of approximately 21,000.
  • Intervention(s): This project will implement telemedicine to provide patient consultations by a pharmacist after hours and on weekends to reduce medication errors.
  • Need for the project: We currently only have a pharmacist onsite 40 hours per week and have noticed an increase in inpatient admissions, many of which are related to medication errors.
  • Target population: The target population is our patients that need medication consults after hours. Approximately 50% of our patients are either Medicaid eligible or indigent, so we expect they will benefit from about half of the consults.
  • Category 1 or 2 expected patient benefits: The project seeks to provide 200 telemedicine consults in DY4 and 400 in DY5.
  • Category 3 outcomes: IT-X.X Our goal is to reduce the 30-day potentially preventable all-cause readmission rate from X% currently to X% by DY5. (If more than one outcome, use sub-bullets.)

Correcting Common Problems with Pass 1 Projects

In addition, HHSC has identified a number of common issues with Pass 1 projects that should be corrected for the full plan submission. Please highlight substantive changes between your initial plan submission and full plan submission to facilitate review of the changes.

HHSC will not be providing project-specific guidance for the below issues with the preliminary feedback, but encourages anchors to work with performing providers to strengthen projects where needed for the full plan submission.

  • Consistent with the summary information requested above, the project narrative should state as clearly as possible what the project does, and whether it is a new project or an expansion of an existing initiative.
  • Many projects have an insufficient description of implementation of required core components. Often, the narrative is copied directing from the RHP Planning Protocol without information on how core components will be implemented for the specific project.
  • Many projects do not explain how the project will benefit the Medicaid and/or indigent populations. While projects may benefit other patients as well, there must be a clear benefit to Medicaid and the low-income uninsured.
  • Almost all projects have CQI as a required core component, but many projects barely mention CQI, either stating that it will be done or referring only to a regional learning collaborative.
  • At least one Process Milestone and one Improvement Milestone must be included for each Category 12 project.
  • Milestones should clearly tie back to the project.

What to Expect in Preliminary Feedback

  1. For each RHP, HHSC will provide high level preliminary feedback on specific projects in the following instances. These projects will not move forward to the technical review phase until corrections are made. The corrections should be included with the full plan submission.
  • The narrative is not consistent with the project option selected from the RHP Planning Protocol.
  • For higher value projects, the narrative does not clearly describe what the project is doing. (As noted above, while HHSC only will be providing this specific feedback on higher value projects, anchors and performing providers should review all projects to ensure they clearly describe the intervention.)
  • The community need does not sufficiently justify the project, especially for higher value projects.
  • The required core components identified in the RHP Planning Protocol are not included or addressed, including Continuous Quality Improvement (CQI) where required.
  • Project implementation does not begin by DY 3 (i.e. DY 3 contains planning milestones only.) For example, a gap analysis should not be the only milestone in DY3. This does not mean that an improvement milestone is required in DY 3. Start-up activities such as process milestones related to hiring staff are acceptable for DY 3.
  1. Remaining projects, including ones for which HHSC has flagged issues, will move on to technical review and feedback will be provided with official feedback for the full plan.

Thank you for your continued work to help move forward DSRIP projects to support healthcare transformation in Texas.

November 30, 20121