Tips for Ensuring Quality Encounter Data Submission in Medicaid Managed Care Programs

One area of data management within the healthcare industry that is getting new emphasis and interest from regulators is a focus on encounter data. Today, the majority of Americans receiving healthcare services funded through the Medicaid program are enrolled in some form of managed care. Under this scheme, states contract with MCOs that take on responsibility for providing Medicaid services in exchange for a fixed capitation payment. This approach is in contrast to the traditional fee-for-service (FFS) program where providers submit claims directly to the state for payment. 

It is widely recognized that the FFS approach to provider payment creates perverse incentives for delivery of unnecessary services and uncoordinated care.  Medicaid managed care gets away from this by providing a fixed capitation amount to the Medicaid MCOs, giving them incentives to more effectively manage care.  The MCOs often pass along those same incentives by paying certain providers using capitation as well. 

Notwithstanding the undesirable incentives that FFS creates, one area where FFS excels is the collection of timely and complete data about the services rendered to each patient and information about the price of those services. Because FFS claims are essentially invoices, this approach offers strong incentives for providers to submit claims in a timely manner (for timely payment) and to ensure those claims are a complete reflection of services rendered (for complete payment).  

Under capitation, the payment mechanism is decoupled from the data collection process.  In lieu of claims, MCOs must collect encounter data from their providers and then submit that data to the states. Unfortunately, this takes away the direct financial incentives providers have for timely and complete data submission. As a result, many states have struggled to collect credible information about the services delivered under Medicaid managed care. Such data is essential for important activities such as rate setting and program management. 

Viewing submission of encounter data as an MCO function, many states have implemented strict contractual requirements coupled with tough performance guarantees and financial penalties to motivate MCOs to improve the quality and timeliness of the encounter data they submit. Failure to perform can have significant consequences for MCOs including financial penalties, corrective action plans, bad press, and even contract termination. Based on our experience working with states and MCOs to help improve encounter data quality, we have identified a few things that can help improve the results:

1. Evangelize the Importance of Encounter Data among Providers. Once decoupled from the payment process, it can be hard to convince providers of the importance of collecting and reporting encounter data.  Ensuring that these constituents understand the value of encounter data, and are submitting complete and timely information is key for MCOs to meet their contractual obligations to the state. Regardless of how strong the processes are within the MCO to ensure complete and timely submission, if the source information coming from providers is incomplete, what goes to the State will also be incomplete.  In addition to including encounter data requirements in their provider contracts, MCOs should include encounter data as a topic in their provider communication/education plans, and evangelize its importance whenever they can.
    
2. Develop Clear Submission Requirements, Definitions, and Data Specifications. In any situation where data is being submitted to a third party, lack of agreement and understanding of the actual submission requirements, definitions, and data specifications is a set-up for downstream conflicts. Among states, the requirements for submission often vary, and sometimes change during the term of a contract. States and MCOs should engage in a collaborative process to ensure that all parties are working from the same guidance and interpretation of the submission requirements. 
    
3. Establish an Inter-Disciplinary Team. Many MCOs view encounter data submission as one department’s responsibility (typically, finance, operations, or information systems). In reality, it takes skilled and knowledgeable resources from throughout the organization to drive a high quality process and result. MCOs should establish an inter-disciplinary team that brings together the experts and makes everyone involved accountable for the outcome. That team may be led by someone from one of those primary departments, but requires support from others.
    
4. Implement Automated Data Validation and Reconciliation Processes. Submitting encounter data typically involves collecting data from multiple sources, transforming it into a new format, and then submitting it to the State. There are many opportunities for errors along the way. To provide an early warning of potential errors and facilitate root cause assessment when errors are identified, MCOs should implement data validation and reconciliation processes that run parallel with the encounter submission preparation process.  Often states will have internal processes they run on the data when they receive it; mirroring these processes can proactively reduce error rates. In addition, where possible, it makes sense to reconcile financial information against financial systems such as the general ledger, not just what’s in the claim system. 
    
5. Track and Resolve Errors Timely and Completely.  When submitting encounter data, some errors are unavoidable and thus both MCOs and states must have resources and processes in place to support timely and complete resolution of those errors. Errors can be caused by changes in the way data is collected within the MCO, changes in the state’s internal validation processes, or simply anomalies in the data.  Regardless of the reason, each error should be tracked and resolved to completion. Root causes should also be identified to allow for error prevention.

As states have made the transition from FFS to managed Medicaid, the quality of utilization and cost data they receive has eroded. With the majority of Medicaid beneficiaries today receiving healthcare services through managed care plans, this makes it more difficult for states to perform effective oversight of these programs. Multiple encounter data improvement initiatives have emerged as this has become an area of focus for both states and the Federal government. MCOs should expect this scrutiny to continue, but should also recognize that through a systematic approach to managing and reconciling data, and a collaborative posture with their state partners, many of these challenges can be overcome.