5 September, 2018
As CSBs begin to roll into the data exchanges which are necessary to transfer the Part I through Part IV from their EHR to WaMS (only a few have entered the data manually!) more providers will see the new WaMS configuration when they open the record to add an authorization. The experience so far has been that using the “modified use” choice, entering only the required fields,
and limiting the description of the activity to the bare minimum adds only 20 to 30 minutes in time it takes to complete the process. Not ideal, but far better than trying to enter the entire plan! The description of “Modified Use” appears on pages 33 through 37 of the User Guide linked above.
3 July, 2018
Three days from the target “go live” date and we are beginning to hear of authorization difficulties; in response to a question, we received the following:
The issue is that FEi put Change Request #73 into production yesterday. This is to enable the SA staff vs. support coordinators to have control over the enrollment date for new people because some DD waiver enrollment dates that were going over to VAMMIS preceded CCC Plus waiver end dates, which meant that CCC Plus waiver providers were not getting paid.
FEi did not implement this change request correctly, and the result was that all new SA requests have to be preceded by a Level of Care update in VAMMIS.
There is a work around, which SA staff are using, but that means staff have to perform an extra step (with minimal delay).
In a few instances, the work around is not working for some unknown reason; however, FEi have informed us that will fix the glitch– this whole problem– by the end of the day.
At the most, any stragglers will be resolved by Thursday AM (since tomorrow is a holiday).
While that may answer “a” question, it does not seem to fit with the explanation from the SA consultant that the provider had already received, but we will wait until Thursday to explore it further.
24 June, 2018
Six days from “go live” and the largest issues are:
- there has been no “end user” testing of the new system,
- it continues to be unclear if any (certainly not all) of the CSBs will have data exchange capability,
- CSBs have been consistent in their position that they will not do “double data entry” so those systems that will not exchange data will not have Part III entered in WaMS for a provider to use, and
- DBHDS continues to suggest that a Provider’s Part V may “be located in WaMS..”
The two most recent communiques from DBHDS are linked below:
5 April, 2018 Memo
22 June, 2018 Memo
This, sadly, feels a lot like the count down through the summer of 2016 when we knew that the roll-out was going to go poorly, but had no real idea how poorly until we tried to work with a system that was designed without any meaningful input or testing!
15 June, 2018
Two weeks from “go live” and the testing of the data exchange between the CSB’s EHR and the WaMS system has not been done. We also know that the “rumor” is that the entire process is roughly two months behind schedule and that, contrary to earlier expectations, the Part III will not be part on the data exchange. Given that the Part III is the shared planning, it is not possible to enter any part of a Part V without an “outcome statement” to attach it to!
CSBs seem intent on continuing to upload their documentation – and, presumably, that will be the procedure for the private sector also. If/when a new plan is “entered” in WaMS in a way that allows the Part V to connect and be typed using the “Modified Use” system, then we will talk further about the options and expectations. Training for “full use” which is not the alternative any would suggest is available, but too large to attach to this page.
8 March, 2018
The “negotiations” on what must be entered into the WaMS system manually by private providers has, apparently, at least partially paid off! While this is not perfect – it is a huge step in the right direction:
- Parts 1 -4 of the ISP, which are those produced by the Community Services Boards, are scheduled to be included in WaMS. The information will be extracted from the CSB’s electronic health record when a new ISP is developed following the final testing of the “interface” being developed now – the target start date is July 2018. All ISPs should, therefore, be included by July 2019.
- Part 5, which is the provider’s responsibility, can then be entered with activities “tagged” to the Outcomes available in the Part 3. Our concern has been the format, time and effort that this would take. We were pleased to hear today that there are now two options for manual entry of the Part 5 –
- “Complete use” – the provider can enter all of the requested information for each outcome – the description of the activity, frequency, etc. The staff “instructions” will have to be attached and uploaded separately. While we are assured that the plan for supports, as entered, will format and print, it will not be integrated with the staff “instructions.”
- “Modified use” – the provider can enter four items for each activity (the description of the activity would be a phrase beginning “detailed plan includes . . .” with one or two words following), frequency, target date and a radial button to indicate whether or not this activity is a skill building activity. The provider would attach the Part 5 and “upload” as they do currently.
- We do recognize that this is more complex and more time consuming than the current procedures – but it is far less complicated, and labor intensive than the what we had been advised to expect. We do appreciate that the DBHDS staff were willing to listen to our concerns and look carefully at exactly what data could be collected with the least amount of disruption!
- Regardless of the choice made by the provider, no changes will be made until a “new” ISP is entered b y the CSB during FY19.
- There is a separate initiative to capture changes made in any Plan for Supports during the course of the year; changes would reflect when the individual meets a goal, has a significant change of need, or decides that they are no longer interested in a specific activity, for example. This process now requires that the provider make the necessary changes in their plan for supports (Part 5) and forward the revised information to the Case Manager. The WaMS will now have the capacity for this communication to be done “online.”
More information including a timeline for implementation, user testing, and training will be forthcoming.
1 February, 2018
We are still “negotiating” with DBHDS through DMAS to eliminate the double entry that private providers would have to do if the WaMS Phase II proposal comes to fruition. We have proposed that DBHDS and DMAS list the five or six data elements which they feel they need to capture and provide check boxes for providers to use to give them the data which could then be verified by the Support Coordinator and/or SA through review of the uploaded plan document.
At this point, the interface for Parts I – IV to transfer information from the CSB’s record into WaMS is not complete and tested. No provider information can be entered until that is complete; providers have never been expected to enter plans for services already authorized, only for new plans.
15 September, 2017
We were able to preview the “test environment” yesterday – and have the following observations:
- They expect that all of the elements of a Part V (with the exception of the support instructions) will be entered in some fashion; in the version we saw, the screen formats (fields for data entry) are very challenging for the purpose of composing and editing text as you can only see a limited number of characters (25?) at a time.
- The “data” that can be captured through direct entry into the WaMS for Part V is minimal because the majority of the Part V will be text fields.
- Each outcome measure assigned to a provider requires an activity with a field for type of data to be recorded and the measurability whether the activity is or is not a skill-building activity.
- For residential providers who may have multiple activities under the outcome that supports the individual in being a “healthy, safe and valued member of his community” the data entry will be extremely cumbersome!
- For CE or CC providers for whom the very specific language of the support instructions must meet the expectations of the PA Consultants and the DBHDS staff, the data entered will not be sufficient and the support instructions will be required as a pdf upload.
Key to understanding this endeavor is the following:
- DBHDS repeatedly claims that this is a DOJ requirement; the more accurate interpretation may be that when the Independent Reviewer had concerns about the small sample of plans he reviewed, DBHDS saw the entry of the plans into their service authorization system as being the remedy. The fact is all of the plans are available now to the PA Specialists, but there would be effort to open and read a variety of formats which they apparently feel is burdensome. This shifts the burden to the providers, minimizes the oversight function of the CM and allows the PA Consultant greater ability to “micromanage” the supports plan development.
- The motivation is really evidenced in the fact that the “activities calendar” is a required element; activities can be entered in three categories:
- relationship – these are natural supports which are unpaid
- community – this is a bit unclear, because waiver services are not included
- eligibility based – all Waiver Services
- The “calendar” totals hours at the bottom of each day, allows for some activities to be all day (eg., behavior supports) but does not reflect any “hours” for those activities and will likely not create a “master” calendar which reflects the totality of the individuals life.
- The phrase “eligibility-based” was copied from the Missouri template, but what is concerning is the potential connection to the development of “Service Packages” which DBHDS continues to work toward.
25 August, 2017
We are still waiting for the test environment, but expect to see something by mid-September. There are three (of five or six) of the EHR vendors who work with the CSBs who are engaged in the development of the specifications which will enable the migration of the selected data elements to migrate from the CSB-EHR to WaMS. This will not, obliviously, be as seamless as was hoped, but no less so than might have been predicted.
Providers will not be expected to enter any additional data until the CSBs have their portion of the process in place. We continue to monitor the communication with CMS – to date, we can not find any absolute requirement on their part for the ISP to exist in WaMS nor is it in the regulations either existing or proposed!
20 July, 2017
We are waiting for a test environment for entering a Part V and continue to believe that there are still a number of issues to be resolved and questions to be answered. We are definitely not “there” yet.
We have reviewed the “commitment” that DBHDS/DMAS made to have ISPs more accessible for review by state staff for quality assurance purposes, but find nothing that specifies that uploading the plans as we currently do is insufficient.
In fact, it appears that the minimal information which is to be included in the system if the data is manually keyed will be far less and will provide a very limited amount of information to be reviewed.
30 June, 2017
Several clarifications were made at the Option 2 WaMS Meeting this afternoon:
- Not all of the five vendors who currently manage the EHR environments for the 40 CSBs have provided cost estimates for the work to allow exchange of data between the various EHRs and WaMS; DBHDS has, however, encumbered funds based on a limited estimate of approximately $2M.
- They hope that federal match will be available as the funds were designated for another purpose. DBHDS is, at least at this point, presenting this as having done a favor for the CSBs by eliminating the expensive and time consuming requirements of doing “double data entry” in both their EHR and WaMS.
- They continue to insist that all ISPs must be entered in WaMS by June 30, 2018 – instead of talking about data, this time they simply said they had made that commitment to CMS. We continue to try to find the documentation of that what the consequences will be if they are not successful.
The significant changes for the CSBs in the expectations since the last meeting are:
- For most (?) of the vendors it will take 6 to 9 months for them to be ready to implement
- The “go live” date will vary by CSB, as the work is completed the system will be live for that Board they are aiming for the system to be “live” on October 1, 2017
- Until then, uploaded PDFs will be permitted for all parts of the ISP
- There was confirmation that the “exchange” can reach back into the EHR and extract ISPs done at an earlier date; this eliminates the requirements for a CSB to go back to July 1, 2017 and re-enter information missed because of the delayed “go-live”
- There was some conversation about “keyed entry” starting sooner than October 1, 2017, but obviously little interest from the CSBs!
Significant issues for the private sector remain:
- They expect that Part V will be entered into WaMS which by default means “double data entry” as all providers have either an EHR (~40%) or a paper record (~60%)
- Until a CSB has “gone live” providers will continue to upload their plans as PDFs.
- The most significant finding of the VNPP survey so far is that almost all providers have layers of Quality Assurance in the process for developing/writing, reviewing/approving the Part V and entering the service authorization. The assumption that providers would just begin the process by entering Support Activities in WaMS is not supported by the data!
- We have seen a more recent version of the elements required; it is not clear that any have been removed. And there may be some additional technical “fixes” which would streamline the process – we have asked.
- We did, however, get an assurance that providers would not be expected to go back to July 1, 2017 and resubmit plans already authorized.
23 June, 2017
We have been advised that DBHDS “can’t accommodate an additional group right now;” in lieu of our being able to bring providers to the table to share concerns about the cost in time and effort that their proposal will require, we will collect the data necessary to support our position. The survey is available here
and will open at 5pm on 23 June.
21 June, 2017
We have expressed concern about the proposal to capture a few elements of the Part V in WaMS, both for the time it will take to do the data entry, the duplication of effort and/or the necessity for changing business practices. We still do no have a clear picture of the “why” as every data set we have seen seems to be captured with the current process.
We are appreciative that we have been able to meet with some DBHDS staff and think that there will be a larger “focus group” which we will help organize in the very near future. Stay tuned!
06 June, 2017
The “data” which is required by CMS and/or DOJ is the driving force behind the WaMS discussion which we deascribed below. Here is the list
provided by DBHDS of what those requirements are; we have asked for clarification about where they think the data resides!
30 May, 2017
We have known for months that the next phase of WaMS would be to incorporate limited ISP information so allow data to be collected for DOJ and/or CMS reporting. A workgroup was formed and has been working to develop the specifications to allow the critical elements to be drawn from the CSBs Electronic Health Record (EHR); from the beginning the CSBs have been adamantly opposed to doing double data entry!
While we have been part of the advisory group, the working group were “IT” representatives from several CSBs and DBHDS/FEI staff. Three things have recently come to our attention:
- The current configuration of this part of WaMS will not allowing for transfers from the EHR and uploading pdf ISPs or Plans of Care.
- DBHDS is trying to set a hard deadline of 13 September, 2017 for “go live.” And,
- DBHDS/FEI has made an assumption that private providers (and potentially the CSBs who have services and do a Part V) will manually enter the plan into WaMS.
We know a little, not enough, about the format which has been created in WaMS and some of the issues – too many to list.
This post is to alert you that we have responded to the multitude of concerns about what has been proposed.