Acheiving the vision of HAAD for a reformed health system can be best pursued by a mixture of financial amd medical incentives. In my opinion, any new payment system should be linked to the practice of Evidence-based Medicine (EBM). Hence I am one of the supports of the fourth payment model suggested by the report (website attached below). This approach carries the benefit of providing better incentives to those provides who provide better healthcare standards.

Thank you


http://www.boozallen.com/publications/article/39134722?gko=b82c4

Comments from Rahba & Mafraq Hospitals

Adoption of the proposed coding standards will help us to maintain highly specific and descriptive patient care data and classifications for aggregate reporting that can be reliably captured, encoded, exchanged, and interpreted and it will make the basis for creating a complete form of electronic claim transactions to the payers. In addition to ICD 9 CM, which has already been adopted by most of our facilities and used for inpatient coding process, Introduction of CPT with HCPCS level II for procedures & supplies, National Drug Codes, USC&LS for Dental procedures and LOINC for observations will surely create a robust health information system in our emirate and undoubtfully, these selected code standards are presumed to be of highly suitable to our context of coding & reimbursement process in the region. We highly appreciate this initiative taken by HAAD.

It is suggestible that the consultation draft to include a brief summary on the study done by HAAD for the adoption of the selected coding standards, with information about other coding schemes and a comparison with the selected standards in terms of technical richness, licensing and reliability etc; it is also desired to include names of benchmarked countries as it will give all private & public stakeholders a broader understanding on the new standards and for HAAD, by providing more clarity on the rationale of proposing the adopted standards. (Why CPT 4 and why not ICD 10 PCS or CPT 5, why LOINC and why not SNOMED CT, Read, Medcin etc.)

In our perspective, we believe that the implementation is the big piece of the puzzle. As manual coding process is considered to be expensive and inefficient, our plan would be to engage the available qualified coders in using computer assisted coding/mapping technologies as it will be good in yielding better productivity and consistency. For this, we will be requiring the needed software applications and to achieve this, it is also sought to have a standardized guidelines, a framework model of information system to be part of the consultation document.

Data Standards Panel: (Page No. 32)

It is suggested that to include more responsibilities for the data standards panel viz. 1. Consensus on coding standards adoption 2. To deal with issues related to licensing, Technology, Integrity and maintenance requirements. 3. Create roadmap for future information system. 4. To develop guidelines and disseminate to the stakeholders etc. It is also suggestible that a group of members consisting 3-4 members to separately represent private sector as well as public sector facilities. And at least two members from the clinical coding committee will also be useful.

Diagnosis Coding (Page No. 7)

The International Classification of Diseases, 9th Revision, Clinical Modification, Sixth Edition, Volumes 1, 2 & 3 (ICD‐9CM) to be written as Volumes 1 & 2 Only. Volume 3 covers alphabetic and tabular index of procedures and therefore not relevant in this section.

Medical Services and Procedures: (Page No. 8)

In the standard statement, it has been implied yet, not mentioned specifically that CPT is to be applied in both Inpatient & Outpatient procedure coding.

As most of our facilities uses ICD 9 CM volume III for procedure coding for inpatient procedures, more clarification on this part will be useful; whether to replace ICD 9 CM volume III with CPT or to continue ICD 9 CM in parallel with CPT. In our perspective, the later is seemed to be more ideal as ICD 9 CM procedure codes are required to calculate DRG’s. Therefore, the possibility of mapping ICD 9 CM procedures with CPT is to be recommended. Otherwise, the coders will have to perform procedure coding in both coding schemes.

Standards and Procedures Guidance Consultation and KEH Consultation:

SKMC agrees with the Standards and Procedures Guidance Consultation and KEH Consultation. We support the efforts to bring efficiency and transparency to activity reporting and billing.



SKMC currently uses several different registration systems, the Great Plains billing system and a home grown coding system (none of which are integrated). Although there are significant system challenges to collect and integrate all of the data elements required, we believe that these can be overcome.



As SKMC currently codes only Inpatient and Surgical Daycare cases (utilizing ICD-9 coding) and only processes billable transactions, there will be considerable resources required to bill all transactions and to code all transactions with ICD-9CM and CPT codes. Staff will have to be hired and trained and processes amended. Our ability to hire appropriate staff and train them will be the rate limiting step for adoption of the data submission standards. In addition, changes to the registration and coding processes will have to be implemented.



We are fully committed to reaching the end goal, yet the reality of achieving the proposed timeline is of great concern to us. Ultimately, as a provider of the SEHA Hospital Network, the changes planned this year in our clinical and administrative systems will provide the tool and integration which will aid in achieving compliance with the proposed standards.

COMMENTS FROM ADNIC
1. How to assure the Integrity and validity of the member taking treatment and the medical practitioner giving the treatment in the absence of signature of the member and signature and stamp of the medical practitioner.

2. How exactly the pre-authorization transactions are to be executed electronically.

3. How often the provider can submit e-claims to insurer (weekly, fortnightly or monthly or as and when) and is there a time frame to process and settle the claims and make the payment.

4.How exactly the HAAD wants Electronic transfer of claim data to occur? Is it like the way the data upload of U/W and CLAIM data being currently done to HAAD Website by all the providers and insurers? OR Can the file that contains the data, which is supposed to be in the data format specified by HAAD, be transferred using alternate methods like Couriering/Hand delivering the data in a CD/Floppy/Flash drive etc. to the insurers? OR the file be mailed to a valid email id provided by the insurers?

5.When we tried to convert a CSV file of size 2.6MB to an XML file using EXCEL (File Save As...), the resultant file created exceeded 15 MB in size (In place of a single upload now it requires more than 5 uploads to complete the upload. Is it acceptable?). Does HAAD suggest any other method of convertig a CSV file to XML?

6.Does HAAD provide the various set of codes like the CPT Codes, Pharama Codes, Dental Procedure Codes, Rejection Codes etc. to the insurers so that they can rely on the integrity of the codes they are using?