Exchange Death Notifications
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- Sheena McGee
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1 Use Case Summary Name of UC: Sponsor(s): Exchange Death Notifications MDHHS Date: July 30, 2015 The purpose of this Use Case Summary is to allow Sponsors, Participants, and other readers to understand the purpose of the Use Case (UC), the value proposition the UC represents, and what the Use Case does, requires, and how the UC operates at a high level. The summary is intended to assist the HIE and HIT Community in understanding where this UC fits within the overall roadmap for statewide sharing of health information. This UC Summary has several sections allowing readers to understand the impact of this UC in the following areas: health outcomes, regulation, cost and revenue, implementation challenges, vendor community, and support. Executive Summary In this section provide a brief (3-5 sentence) summary of the UC s function and purpose. Also include a brief description of the importance and highlight the expected positive impact from implementation of this UC. There are approximately 90,000 deaths annually in Michigan, a death rate of almost 0.1 percent. Roughly 75% of these deaths are residents over the age of 65 who are likely to have been Medicare beneficiaries. Notifying healthcare organizations timely when a death occurs can help reduce waste and prevent fraud. Fraudulent insurance claims from deceased beneficiaries cost Medicare millions of dollars annually 1 and taxpayers have funded over a billion dollars in unnecessary payments to deceased persons for many federal programs beyond Medicaid. 2 Medical supply companies often continue shipping expensive and non-returnable supplies for weeks or months before learning a person is deceased those shipments result in hard-dollar waste in the millions of dollars all preventable. When a physician deceases, it is not uncommon for criminals to successfully falsify and fill fake prescriptions using the identity of the dead doctor. Most importantly, without knowledge of a death, organizations involved in healthcare often initiate uncomfortable communications with grieving families by trying to reach the deceased as if still living. The purpose of this Use Case is to distribute timely and accurate death notifications to improve awareness of the event, avoid unnecessary and wasteful spending, preclude falsified insurance 1 In 2011 Medicare paid $23 million to deceased patients ( A Georgia Doctor billed $2M in fraudulent claims ( The identities of about 200 beneficiaries received $9.6 million worth of Medicaid benefits subsequent to the beneficiary s death, based on our matching Medicaid data to SSA s full DMF 2 Federal Programs to Die For American Tax Dollars Sent Six Feet Under by Senator Tom Coburn, eu&sig=3d-vydwiwbbpxeiu3rwbwsekwws&hl=en&sa=x&ved=0ce4q6aewbmovchmig-wowi3rxgivcxe- Ch2IpQkJ#v=onepage&q=cost%20of%20medical%20supplies%20sent%20to%20dead%20patients&f=false 1
2 claims, and stop dispensation of prescribed medications. Death notifications may also indicates that the deceased was a doctor or healthcare professional to help pharmacies avoid filling counterfeit prescriptions. Other potential benefits of this use case are: Informing researchers of a death if the person is involved in a study Identifying intervention opportunities for suspected fraud and/or substance abuse Improving home health, rehabilitation, and hospice organizations ability to reallocate resources and scheduling availability Enabling better synchronization between State and Local Vital Records registries Diagram In this section, provide a diagram of the information flow for this UC. The diagram should include the major senders and receivers involved and types of information being shared. There are seven data sharing scenarios expected under this Use Case: 1. Send electronic death notification to Payers 2. Send electronic death notification to current Providers 3. Send electronic death notification to Provider Specialists and former Providers (up to 10 years back, oncologists, cardiologists for research) 4. Send electronic death notification to Supply Companies 5. Send electronic death notification to Pharmacies 6. Send electronic death notification to County Vital Records/Local Registries with accompanying electronic death record information 7. Submit Electronic Death Records to Electronic Death Registration System (EDRS) from hospitals, Skilled Nursing Facilities, and county coroners, etc. Scenarios 1-6 are illustrated in Figure 1. The abbreviation EDN is used for electronic death notification. 2
3 Figure 1 Data sharing scenario #7 is illustrated in Figure 2 below: Figure 2 3
4 Regulation In this section, describe whether this UC is being developed in response to a federal regulation, state legislation or state level administrative rule or directive. Please reference the precise regulation, legislation, or administrative act such as Public Law (Affordable Care Act), Public Law 111-5; Section 4104 (Meaningful Use), 42 CFR 2 (substance information), MCL (Newborn Screening), PA 129 (standard consent form), etc. Additionally, provide information if this UC allows Eligible Professionals/Providers (EP) or Eligible Hospitals (EH) to meet an attestation requirement for Meaningful Use. Legislation/Administrative Rule/Directive Yes No Unknown The State of Michigan developed a revised death certificate to be used for all deaths that occur on or after January 1, The revision was necessitated by a change to the national standard death certificate issued by the Centers for Disease Control (CDC). Michigan law M.C.L requires the national standard form be followed as nearly as possible. For more information on the national standard forms please see "Revisions of the U.S. Standard Certificates of Live Birth and Death and the Fetal Death Report," National Center for Health Statistics, National Vital Statistics System. <other relevant regulations will be added> Meaningful Use: Yes No Unknown Stage 1 and 2 of MU are not impacted by this Use Case. It is anticipated that data sharing scenario #7 may support Stage 3, but this cannot be determined until Stage 3 is finalized. Cost and Revenue In this section provide an estimate of the investment of time and money needed or currently secured for this UC. Be sure to address items such as payer incentives, provider incentives, revenues generated (e.g. SSA transaction payments) or cost savings that can be realized (i.e. reduction of administrative burden). As information is known or available, provide information on the resources and infrastructure needed to move this UC into production
5 Costs: There are two costs associated with this Use Case. The first is the cost to implement this Use Case, which uses existing infrastructure. The cost to implement this Use Case is estimated to be in the low six figures. The other cost for this Use Case is the cost of not implementing it. The cost to not implement this Use Case is in the hundreds of millions or possibly billions of dollars in waste and fraud that exist today as cited in the Executive Summary. The waste and fraud described in the Executive Summary can be greatly reduced or in some cases possibly eliminated. The Return On Investment (ROI) for successfully implementing and adopting this Use Case is very high a six-figure investment for an eight- or nine-figure return. Implementing this Use Case can also reduce the annual costs for maintaining and supporting a statewide electronic death record system which can be in the range of a million dollars per year. Revenues: The cost savings achieved by adjusting services upon receipt of electronic death notifications should prompt stakeholders to subscribe to this notification service. The Social Security Administration presently pays a premium to be notified within seven (7) days of a death occurrence. Together with MDHHS, MiHIN is preparing a pricing model for subscriptions to sustain this notification service. The pricing model will likely vary by recipient and may be similar to a data plan offered by a wireless carrier. This would include a base fee for a certain number of notifications with additional per transaction fees for notifications beyond that baseline on a monthly basis. Different stakeholders who may wish to receive electronic death notifications include but are not limited to: Payers Pharmacies (especially interested in dead doctor notifications) Medical Supply Companies Providers Hospitals Specialists (for research) Home Health Care / LTPAC / Skilled Nursing Facilities Rehabilitation Centers It is possible that different stakeholders may ascribe higher value to certain kinds of notifications. For example pharmacies may be willing to pay a premium for dead doctor notifications, and researchers may also be very interested in receiving all notifications for death from certain causes related to their research. The full revenue model for this Use Case has not been finalized but this section will be updated when it is. Implementation Challenges In this section, as information is known or available, describe challenges that may be faced to implement this UC. Be sure to address whether the UC leverages existing infrastructure, policies and procedures, ease of technical implementation, or impacts current workflows (short term and long term). 5
6 Data sharing scenarios #1-6 of this Use Case are straightforward to implement on the existing Michigan Health Information Network Shared Services (MiHIN) platform as illustrated in Figure 1. Essentially the electronic death notifications would be sent from the EDRS through the MDHHS Data Hub to MiHIN which would then route the notifications to subscribers at their chosen electronic address (stored in the statewide provider directory). This workflow takes advantage of existing processes for reporting deaths to EDRS, the existing highly secure Virtual Private Network (VPN) connection between MiHIN and the MDHHS Data Hub, the Active Care Relationship Service, and the statewide Health Provider Directory all of which are already in full production. Some new development will be required to identify subscribers. The workflow for death notification data sharing scenario #7 will require organizations that report a death to do so via a Trusted Data Sharing Organization connected to MiHIN, or directly to MiHIN using Direct Secure Messaging. MiHIN will then send the death notification to the MDHHS Data Hub which will route the notification to EDRS. If Direct Secure Messaging is used, the amount of effort required is not much more than giving out an id and password, plus identity verification and some training. This small investment can help evolve the preferred direction to promote use of the more secure, standard electronic connection between MiHIN and the MDHHS Data Hub instead of the non-standard, less secure legacy method of direct entry into EDRS. Submitters may be incentivized to adopt this reporting mechanism through reduced rates for subscribing to receive death notifications. It is MDHHS goal to increase the percentage of organizations submitting death notifications electronically. Vendor Community Preparedness In this section, address the vendor community preparedness to readily participate in the implementation of this UC. Speak to whether this UC utilizes current or future technical capabilities of the vendor products. If this UC requires new functionality at the vendor level provide information as known to the timeliness of when product updates may be available and any potential costs to the HIE community. The readiness of vendors to receive death notifications in systems like EHRs is unknown. However every type of stakeholder listed in the Costs/Revenues section can easily receive electronic death notifications that are attached to Direct Secure Messages just as easily as receiving with attachments. Support Information In this section, provide known information on the support for this UC. Support can come from multiple levels (Governor, Federal or State Legislative, MI HIT Commission, Michigan State Departments, CMS/ONC/CDC, MiHIN Board, Qualified Organizations, Payer Community, Interest Group [ex: MSMS, MHA], or Citizen support). 6
7 Please note any concerns or oppositions with the Use Case Political Support: Governor Michigan Legislature HIT Commission MDHHS or other SOM Department CMS/ONC CDC MiHIN Board Other: Concerns/Oppositions: None identified Sponsor(s) of Use Case Who are the major sponsors of the Use Case? MDHHS, MiHIN Metrics of Use Case In this section, define metrics for the Use Case to be successful. Metrics to measure the success of the Use Case include: Volume of death notifications received from MDHHS by MiHIN Number of subscribers to the Death Notification Service Volume of Death Notifications sent from MiHIN to subscribers Volume of Death Notifications received by MiHIN Change in volume for total electronic death notifications received by MDHHS/EDRS 7
8 Other Information This section is to afford the sponsor(s) an opportunity to address any additional information with regard to this UC that may be pertinent to assessing its potential impact. N/A 8
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