“The mission of the Mental Health Division is to promote recovery and safety."
External Quality Review Organization (EQRO) Requirements
Affecting Mental Health IT and Data Processes in Washington State
March 4, 2004 Draft
Overview
Federal (CMS) EQRO requirements related to Medicaid Managed Care waivers go into effect for Washington State's publicly funded Mental Health in March 2004. The Mental Health Division is currently in the contract procurement process to obtain External Quality Review services for the state system. One of the required EQRO Protocols (Validation of Performance measures) requires review of information systems, encounter/claims processing, and handling of enrollment data at the provider, RSN and MHD level. Appendix Z details this information system capacity assessment.
The protocol, Appendix Z, used by the reviewers is available as modified from the Department of Health and Human Services' Centers for Medicare & Medicaid Services Final Protocol version 1.0 dated May 1, 2002. These modifications were made by the Mental Health Division to make it directly applicable to Washington State RSNs functioning as PIHPs in the current State Medicaid Waiver approved by The Centers for Medicare and Medicaid Services regional office on April 7, 2004.
The following points about these Federal requirements may be of interest to RSNs, particularly their data and IT functions.
- RSNs and MHD will be asked to complete an initial self-assessment regarding their data and IT functions, probably in the fall of 2004. Each RSN as well as MHD IT and Research units are likely to be subject to a subsequent EQRO-conducted on-site review that will cover several areas, including Information system capacity. Appendix Z contains the initial self-assessment, as well as the on-site interview format the EQRO will likely use to follow up. This later document (starts on Page 46 of Appendix Z) indicates what the EQRO might be looking for and is of value as RSNs and MHD prepare for reviews.
- MHD has several questions for CMS regarding the applicability of certain sections within Appendix Z to the RSNs. Some of the items do not appear to apply to behavioral healthcare as currently written.
- MHD is currently considering alternate categories of service and categorizations of providers that might be more appropriate to RSNs than the language currently in Appendix Z. We are exploring with CMS whether these items can be modified/edited/excluded to make the document more appropriate to our public mental health context.
- In addition to the required EQRO protocols, CMS is requiring that Washington State to conduct an Encounter Validation Study. The EQRO Protocol for conducting encounter validations is one of the "optional" protocols and is also available at the website listed above.
