Response to IRR #4 Questions and Clarifications

Transcription

1 Response to IRR #4 Questions and Clarifications Deloitte Consulting LLP (Deloitte) is pleased to provide our responses to the questions and clarifications posed by the Department of Children and Families (Department) during our meeting with the Department s negotiation team on the Interim Revised Response #4 (January 11, 2013). We look forward to further discussions with the Department s negotiation team on our proposed approach, schedule, solution, and team, as well as the opportunity to continue working with the Department on this important transformation initiative. 1. Please update Section 2.3 of the Assumptions Document to clarify the items that were discussed in today s (January 11, 2013) meeting. Per the Department s request, we have updated the assumptions in Section 2.3 of the Assumptions Document to clarify the items discussed in the January 11, 2013 meeting with the Negotiation Team. Please refer to document Deloitte Vendor Assumptions ITN 03F12GC1 IRR #4_Revised for the updated assumptions document. Assumptions that have been added since IRR #3 are highlighted in green (i.e., added assumption text), assumptions that have been changed since IRR #3 are highlighted in yellow (i.e., changed assumption text), and assumptions that have been deleted since IRR #3 are highlighted in red and are further denoted with strikethrough text (i.e., deleted assumption text). 2. As discussed in today s (January 11, 2013) meeting, the Department requires as much no touch capability as possible for all Medical Assistance Program eligibility determination. Please include a brief descriptive narrative of the change in approach. We have an intimate understanding of the current challenges facing the Department. Some of these challenges include limited budget and staff headcount, while facing policy and programmatic changes that will likely drive increased applications and the resulting caseload increase for Florida. Our understanding of the Patient Protection and Affordable Care Act (PPACA) policies has been gained through our national integrated eligibility practice working closely with CMS and by also working closely with several states to drive their solutions solutions that span from enhancing legacy assets to replacing legacy assets with our NextGen solution platform. As a result, we understand the impending challenges that the Department faces better than any of our competitors. Combining this with Deloitte s deep understanding of Florida s policy, processes and technology assets is critical to being able to deliver a solution for Florida that meets the October, 2013 deadline imposed by PPACA. Response to IRR #4 Questions and Clarifications Page 1

2 Our approach leverages the Department s current technology assets optimally where additions and enhancements to the current environment are performed by a team that built and has been maintaining and enhancing these assets for over seven years; with many members of our team having over 20 years of hands-on experience with the Department systems. As part of our preparation activities to help our clients get a head-start, our national practice has developed the eligibility rules for MAGI based Medicaid based on CMS specifications of the MAGI rules. These rules are pre-loaded into the Business Rules Engine that we have proposed for Florida, which provides you a distinct advantage in terms of the project timeline and a reduced risk of meeting the timeline. In addition to the direct advantages that are stated above, our solution also eliminates the complexities and additional challenges that would be posed by a replacement solution involving a stand-alone system for MAGI based Medicaid separate from the current ACCESS Florida systems. The following Table 2.1 describes a list of the most critical challenges associated with this particular approach, all of which are avoided by Deloitte s Phase 3 approach. Challenge Workload Increase Staff Productivity Data Integrity Interface Challenges Two Medicaid Systems Description Need to create two cases one in the new MAGI Medicaid System and one in the ACCESS Florida system for the members of a household that are applying for MAGI based Medicaid and/or Non-MAGI Medicaid, SNAP, TANF or Refugee Programs Need for Department staff to use two distinct and disparate systems with different User Interfaces and Work Flows which will likely result in unnecessary complexity, increased training and re-training, and overall reduced productivity Data integrity challenges that result in potential data discrepancy between the two systems and an increased likelihood of eligibility errors in the absence of a complex and potentially error-prone interface between the two systems for data sync-up Interface challenges with the current interface partner agencies as a result of interface files originating from two distinct systems, as well as having to transmit files to both systems in the potential absence of sophisticated merge/consolidation and split processes Correspondence challenges that potentially negate the gains that the Department has accomplished in the recent years through consolidation of notices Table 2.1. Potential Challenges posed by a two system solution for MAGI Medicaid Implementation. As a result of the Affordable Care Act, the Department faces a substantial increase in the number of applications filed for Medicaid and/or other insurance affordability programs. With the increases in application numbers and caseload size, we understand it is imperative that the Department alleviates the chance of induced inefficiencies. Through our conversations with the Department through the IRR process, we understand that the Department has an in-depth understanding of these challenges and are looking forward not only to acquire the most effective solution with the lowest risk, but one that can support process efficiencies and no touch automation capabilities that eliminates or at least minimizes the need for worker intervention in processing applications and cases. Response to IRR #4 Questions and Clarifications Page 2

3 Deloitte s proposed solution for Phase 3 not only overcomes these challenges, our solution also supports and provides opportunities that allow for the addition of functions and features that further increase process efficiencies and automation for the Department. Our track record delivering for the Department proves this, as we have delivered proven no touch automation solutions within the current ACCESS Florida system. Our experience building automation and efficiencies at DCF Over the past seven years, Deloitte has worked with DCF side by side on all of your eligibility modernization efforts. The Department has made great strides in modernizing Public Assistance in Florida since the legislative action in 2003 initiating ESS Modernization which mandated greater efficiencies in the operation, administration, and delivery of Public Assistance programs. During this time, the program underwent mandated budget and staff reductions. The number of field delivery staff was reduced from a level of 7,200 in 2003 to 4,109 by July 2006, resulting in backlogs in processing applications and increased error rates. With no additional funding support available, the management and delivery staff worked to re-engineer the delivery model eliminating unnecessary and burdensome processes and utilizing Federal and State rules and waivers to the Department s advantage. Since 2006, Deloitte has worked hand in hand with the Department to implement IT solutions that support process re-engineering, automation, addition of new systems and to perform improvements to the legacy systems. Figure 2.1. ACCESS Florida Modernization and Automation Impact ACCESS Florida Modernization efforts have resulted in lower error rates despite increase in workload and decrease in staff. Response to IRR #4 Questions and Clarifications Page 3

4 Figure 2.1 illustrates the impact of these efforts in terms of the caseload size and the number of delivery staff who support the program. The process re-engineering, capabilities of the new systems, and improvements to the legacy systems not only helped weather the multi-fold caseload growth as a result of the economic downturn that started in 2008, but also helped Florida become the state with the least errors in processing SNAP benefits, resulting in multi-year bonuses from the Federal government that have reached nearly $40M all while increasing the overall customer satisfaction. Our prior experience and success helping the Department modernize the ACCESS Florida system and designing, developing and implementing multiple automated No Touch solutions is the corner stone of our approach to the No Touch solution described below. This experience is directly relevant to the task at hand and provides the Department confidence that our approach is the right one to deliver the right results and the business objectives on time and on budget. No Touch Solution We are proposing an enhancement to our original proposed Phase 3 solution that adds an additional No Touch capability for the processing of Medicaid applications. As depicted in Figure 2.2 below, the Department will continue to receive applications for Medical Assistance through multiple channels, including the newest one, the Health Insurance Exchange (HIX). A large portion of the applications that are received through the ACCESS Self Service portal are anticipated to be applications for MAGI based Medicaid and are expected to be verified through the Federal Data Services Hub. Referrals received from the HIX are also expected to be falling in to this category. This provides the opportunity to have an automated Application Processing, Eligibility Determination and Authorization process that can be completed without case worker intervention. Our solution does not require the conversion of Standard Filing Unit (SFU) rules to the Rule Engine. However, during our meeting with the Department s negotiation team on the Interim Revised Response #4 (January 11, 2013), the Department had enquired about the feasibility of converting the business rules that create the SFU groups of categories in to the Rules Engine. We would like to confirm that it is feasible to convert the SFU rules into the rules engine and it is recommended to do so. However, we do not recommend this conversion in Phase 3 for the following reasons: 1. Our approach and proposed solution for implementing No Touch capabilities does not require the conversion SFU rules in to the Rules Engine as depicted in Figure 2.2 below 2. The complexity of the SFU Rules and the large number (over 90) of FLORIDA Medicaid categories increases the risk of delivering Phase3 scope on time and on budget 3. In our experience in other states implementing the SFU rules in the Rules Engine we have found that the appropriate time to implement the SFU Rules in the Rules Engine is at the time when the rules for all benefit programs are implemented. Response to IRR #4 Questions and Clarifications Page 4

5 4. The entire SFU module will be replaced as part of Phase 4A project. A significant amount effort and cost will be duplicated Figure 2.2. No Touch automation for processing Medicaid Cases in the ACCESS Florida System. Applications that are submitted through the current channels and through the HIX are collected and accumulated within the ACCESS database. Currently, e-signed applications are routed into the inboxes of various Administrative Units within AMS for processing by staff. As part of the No Touch solution, this process will be modified to identify and validate applications that are complete and with the necessary verifications (from Federal Hub and other approved electronic verification sources) that can be processed without worker review or intervention. Deloitte will collaborate with DCF staff to define and implement the selection criteria for No Touch applications that do not require worker reviews. Applications that pass the validation for the No Touch automated process will go through a Data Preparation sub process that will ready the application data for case processing. The automated No Touch process will subsequently execute a systematic process that will invoke transactions in the AMS and FLORIDA systems to perform the Client Registration and Clearance, Application Entry, Standard Filing Unit (SFU), Eligibility Determination and Benefit Calculation (ED/BC) and Authorization Transactions using the application and verification data. Upon completion of the Response to IRR #4 Questions and Clarifications Page 5

6 Authorization transaction, the Work Item in AMS will be disposed if no manual action is required on the case or application. Applications that do not successfully undergo all the necessary transactions or sub processes are routed to an exception process. Workers are expected to complete the processing of applications in the exception queue. The No Touch solution will be developed using Java and Oracle technologies and will simulate actions by the Department s case workers. The process executes the same transactions that are executed by case workers to complete the processing of applications in the ACCESS Management System (AMS) and the legacy FLORIDA system. This approach helps ensure that every application and case undergoes the same eligibility determination process regardless if it is executed by a case worker or through the No Touch automated process. It also helps ensure that the system creates the appropriate triggers that generate client notices and interface actions. Table 2.2 below provides descriptions of key functions and features of our proposed No Touch solution. Function Identify and Validate Applications Data Preparation Perform Client Registration Perform Application Entry Perform SFU and EDBC Perform Authorization Perform AMS Update Description This sub process identifies Medicaid applications that are complete and have the necessary verifications that do not require review by workers. Applications that meet all requirements for No Touch process are selected and routed to the automated process. Applications that do not meet the conditions are routed as usual to the appropriate Administrative Unit inboxes in AMS for processing by workers. This process validates the necessary data elements that are required for the Automated Processing and assigns appropriate default values in places of missing data elements (data that is not necessary for the processing of Medicaid Eligibility but are required by the system) to complete transactions and processes. Deloitte will collaborate with DCF staff during fit-gap to define the appropriate default values that are allowed to be used in places where data is not available in the application or in other sources (For example: Federal Hub). The process is designed and developed after a careful and close analysis of the data element requirements for transactions that constitute the FLORIDA processes. Client Registration is the first business function that is executed by the No Touch process on the FLORIDA system. The process will invoke the Client Registration transactions and will use the individuals demographic information, address and program selections to initiate and complete Client Registration transactions. Exception records will be generated if and when the tool is unable to complete Statewide clearance due to missing or conflicting Demographic data in the FLORIDA system. Upon successful completion of Client Registration, the process will systematically invoke the Application Entry transactions and will complete the data entry using application data and verifications from the client submitted application and verification sources. Upon completion of data entry in the Application Entry screens, the process will invoke and execute the SFU and ED/BC transactions and programs. Depending upon the program selections, household composition and technical conditions, this process may build MAGI based Medicaid, Non-MAGI Medicaid and/or other programs such as SNAP and TANF. Upon successful completion of the SFU and EDBC execution, the process invokes the Authorization Transaction. Assistance Groups that PASS eligibility (all verifications in place) are approved. Any other Assistance Groups that include SNAP, TANF or Refugee processes will be left pending and added to the exception queue to complete processing by workers. During fit-gap, Deloitte will collaborate with DCF staff to define the rules for Authorizing/Not Authorizing Assistance Groups and the appropriate reason codes to be used. The Work Item Update process updates AMS Work Item details to help ensure that the work item is disposed in the case of successful process completion or to update the progress in Response to IRR #4 Questions and Clarifications Page 6

7 Function case of exceptions. Description Perform Exceptions Reporting Applications that are selected for No Touch process could potentially encounter issues that prevent the automated process from completing all the necessary actions for application processing. Potential reasons include data discrepancy between the new information in the application and already existing data in the FLORIDA system. During fit-gap, Deloitte will collaborate with DCF staff to define the exception rules and the exception reporting functions within AMS or the Exception Management System. Table 2.2. Critical functions that support the automated No Touch process. We understand that the State of Florida has not decided if it is planning to expand Medicaid as recommended by the Affordable Care Act. In case the State decides to expand Medicaid, there will only be minimal changes that will be required for the No Touch solution. This is accomplished as a result of the modularity of our solution that executes the core Client Registration, Application Entry, SFU/EDBC and Authorization transactions. Project Schedule and Timeline Figure 2.3 below depicts our project schedule approach for delivering the required SDLC activities for the No Touch enhancement as part of Phase 3A (MAGI implementation scope). However, to minimize the risk and impact to the Phase 3 effort for MAGI which we all agree is extremely time sensitive, we are proposing design, development and implementation activities of No Touch to be performed as a second wave within Phase 3A. In this approach, the fit-gap and development phases overlap with MAGI activities while the Acceptance Testing and Deployment phases are standalone and independent. Figure 2.3. Modified Timeline for Phase 3 Including No Touch capabilities. 3. Please confirm and/or update your O&M (Legacy & New) approach and costs to reflect standalone pricing and schedules. Legacy O&M: We confirm that our Legacy Operations & Maintenance (O&M) approach and costs previously provided reflect standalone pricing and schedules. As requested by the Department in IRR #3, our proposed hours and resources for Legacy O&M are based upon a standard of 27,000 Response to IRR #4 Questions and Clarifications Page 7

8 hours of effort per year. These estimates are for standard O&M only and do not include hours for enhancements including the 5,000 hours of legislative enhancements as identified in the ITN nor do they include hours for training, as training has not been historically performed as a part of O&M services. Our proposed approach to Legacy O&M is structured as a standalone effort to support the ACCESS Florida systems as identified within the ITN and pricing is based upon providing services from February 7, 2013 (contract start date) through December 31, 2016 (contract end date that coincides with the completion of the warranty period for our proposed Phase 4A). New O&M: We confirm that our approach and costs for New O&M reflect standalone pricing and schedules. As described in item #2 above, our proposed approach to Phase 3 the implementation of a Web Portal and New Eligibility Rules engine for all Medical Assistance Programs involves modifying and enhancing the current ACCESS Florida systems and adding a Business Rules Management System (BRMS) and Enterprise Service Bus (ESB) to the solution stack. As this approach builds upon the current ACCESS Florida systems, our proposed approach to operations and maintenance activities post-phase 3 does not duplicate the resources and activities already performing Legacy O&M services on the ACCESS Florida systems. Rather, our proposed approach to New O&M, shown in Figure 3.1 below, focuses on operating and maintaining the BRMS and ESB implemented as a part of Phase 3 and providing knowledge and support on the modified and enhanced components of the legacy ACCESS Florida systems to the Legacy O&M team that is already supporting those applications. Phase 3 Feb 2013 to Jan 2014 New O&M 7,400 hours Oct 2013 to Sep 2014 Operating & Maintaining BRMS and ESB Knowledge & Support on Modified and Enhanced Components Legacy O&M 27,000 hours/year Feb 2013 to Dec 2016 Apr 2013 Jul 2013 Oct 2013 Jan 2014 Apr 2014 Jul 2014 Oct 2014 Jan 2015 Apr 2015 Jul 2015 Oct 2015 Jan 2016 Apr 2016 Jul 2016 Oct 2016 Feb 2013 Dec 2016 Figure 3.1. Approach to Legacy O&M and New O&M. Our proposed approach to New O&M is structured as a standalone effort to support the activities identified above from October 1, 2013 (Phase 3 implementation) through September 30, At the completion of this period, responsibility for ongoing support for the BMRS, the ESB, and other components modified or enhanced as a part of the Phase 3 project will be the responsibility of the Legacy O&M team. Should another vendor be awarded Legacy O&M services, our proposed approach provides transition support in conjunction with knowledge transfer and support activities Response to IRR #4 Questions and Clarifications Page 8

9 so that they could continue to provide long-term operations and maintenance support for the Phase 3 components moving forward. 4. Please clarify your approach for using resources that overlap projects based on the direction from the Department of not sharing resources. Deloitte is committed to delivering a highly qualified and experienced team to plan, manage, execute, and implement the ACCESS Florida System Replacement project. As detailed in the Personnel section of our response to the ITN, our approach to staffing and resourcing the project is based upon a number of important attributes and qualifications that our team members should possess to not only meet your requirements, but also to deliver a successful project and the outcomes expected. These attributes include: Practitioners who you know and who know your program and its technology environment Hands-on experience with Integrated Eligibility systems and solution delivery Understanding your goals and objectives and committed to your success Full life-cycle implementation experience with large-scale technology transformation initiatives Strong track record of success and results Resources who understand the impacts that a new solution has on eligibility workers People who have hands-on experience with the HHS NextGen platform People who represent our core values of client service and commitment Our approach to staffing resources on project assignments is based upon a number of factors that include the technical skills and capabilities required for the role, the business knowledge the role requires, the size and duration of the project role, and the context of the role and its responsibilities across the program. For example, individuals assigned to application developer roles or tester roles on a project are frequently dedicated to that initiative from the start date of the assignment until its completion, while individuals assigned to management, technical lead, or configuration management roles are often shared across the program, as their responsibilities are to plan and manage activities across multiple initiatives (e.g., application builds, application deployments, software patches, release management). We have employed this approach over the last seven years in working with the Department and have successfully delivered each project including operations and maintenance on-time and on-budget. As we staff resources in project roles for the ACCESS Florida System Replacement, we will work collaboratively with the Department to understand current priorities, including other in-flight projects and ongoing operations and maintenance, which will continue to require knowledgeable functional and technical resources to execute and complete as per their approved plans. We will work together to balance the resources that can transition from current projects to the ACCESS Florida System Replacement and be backfilled with other qualified practitioners; resources that must remain on current projects given skill, knowledge, and experience requirements; and Response to IRR #4 Questions and Clarifications Page 9

10 resources who can split time across multiple initiatives given the requirements of each project s role. Throughout this process, we will also evaluate the start date and end date of assignments as not all roles for the ACCESS Florida System Replacement will need to be staffed on the first day of the project. This collaborative approach is the same as what we currently perform with the Department when new project initiatives are identified such as the recent Identity Verification and Electronic Benefits Transfer New Vendor Interface projects. As we work to staff positions, we will leverage our deep bench of over 2,000 Health and Human Service (HHS) practitioners - individuals who have dedicated their careers to delivering projects similar to the ACCESS Florida System Replacement. We will also look to leverage our HHS "Guest Star" program, where practitioners with deep functional or technical experience in specific areas of Integrated Eligibility provide knowledge and expertise to the project across the project life cycle in areas including requirements validation, functional design, technical design, training, and change management. Per the Department's request, resources assigned to Phase 3 of the ACCESS Florida System Replacement project will be dedicated solely to that effort. Similarly, our proposed team for Legacy O&M will be dedicated to operations, preventative maintenance, and corrective maintenance activities associated with the ongoing support of the legacy ACCESS Florida systems. However, as both of these initiatives as well as other in-flight projects are each designing, developing, and implementing fixes and enhancements on the same set of applications and in the same application environments, coordination and collaboration across the program will be required. Resources on each project, as well as project management and Department staff, will need to participate in meetings, tasks, and activities across other initiatives to help ensure high-quality, on-time delivery of all projects. In doing so, we will work with the Department across the program to plan and manage these activities and to confirm and verify that time and effort required by one project does not affect the progress and delivery of another. 5. Please update your Phase 3 standalone cost replies and assumptions to reflect any changes in pricing for this ITN. Per the Department s request, we have provided updated standalone costs for Phase 3 based upon the revised approach described above. Please refer to Excel workbook DCF14- APPENDIX XI-IRR4-Cost Reply Forms-v0 02_Deloitte_Revised for updated pricing information. In addition, we have provided updated assumptions per the questions and clarifications and our revised approach. Please refer to document Deloitte Vendor Assumptions ITN 03F12GC1 IRR #4_Revised for the updated assumptions document. Assumptions that have been added since IRR #3 are highlighted in green (i.e., added assumption text), assumptions that have been changed since IRR #3 are highlighted in yellow (i.e., changed assumption text), and assumptions that have been deleted since IRR #3 are highlighted in red and are further denoted with strikethrough text (i.e., deleted assumption text). Response to IRR #4 Questions and Clarifications Page 10