A Review of Requests for Proposals Used by the Division of Medicaid and University of Mississippi Medical Center to Procure Electronic Health Records Systems
Executive Summary
Introduction
Given the increased interest and movement in health information technology implementation, the Mississippi Legislature recognized the importance of a coordinated approach to this issue. The Legislature’s means of addressing such coordination was the enactment of H. B. 941 during the 2010 Regular Session.
Section 10 of H. B. 941 required the PEER Committee to make a report to the Chairmen of the Senate and House Public Health and Welfare/Medicaid committees regarding the Division of Medicaid’s and the University of Mississippi Medical Center’s procurement and implementation of electronic health records systems. Specifically, the section required PEER to:
The scope of this review includes only an evaluation of the request for proposals documents used by DOM and UMMC to procure electronic health records systems, not a review of the entities’ evaluation of proposals received or the award decisions. Also, because DOM’s and UMMC’s health information technologies are in their early stages of implementation, PEER did not review the operations of such technologies.
Each of the next three sections of this summary addresses one of the above-listed requirements of Section 10, H. B. 941, 2010 Regular Session. The final section consists of PEER’s recommendations related to this issue.
Evaluation of RFPs Used by the Division of Medicaid and University of Mississippi Medical Center to Procure Electronic Health Records Systems
What are the legal requirements for these entities’ procurement of information technology and services?
The Department of Information Technology Services (ITS) has statutory authority to promulgate regulations for the procurement of information technology and services by state agencies and institutions. MISS. CODE ANN. Section 25-53-25 (1972) allows ITS to exempt certain procurements from its oversight; both the DOM and UMMC received such exemptions for their health information technology projects.
What criteria did PEER use to evaluate RFPs used by the Division of Medicaid and University of Mississippi Medical Center to procure health information technologies?
From procurement requirements of ITS, the Personal Service Contract Review Board, and the American Bar Association, PEER developed a “best practices” list of RFP components to be used as criteria in its evaluation of RFPs issued by the Division of Medicaid and University of Mississippi Medical Center.
Did the Division of Medicaid comply with procurement “best practices” when developing an RFP to select a vendor to design and implement its e-health records and e-prescribing system?
The Division of Medicaid contracted with Fox Systems, Inc., to assist with a self-assessment to determine progress toward meeting guidelines of the Medicaid Information Technology Architecture Initiative. The contractor also assisted in developing a request for proposals for an e-health records and e-prescribing solution. PEER determined that the division’s RFP fully complied with the components PEER considers to be “best practices” for an RFP.
Did the University of Mississippi Medical Center comply with procurement “best practices” when developing an RFP to select a vendor to design and implement its health care information system?
UMMC contracted with Kurt Salmon Associates to assist the medical center’s Health Care Information System Committee and staff in developing the request for proposals for an enterprise health care information system. While UMMC’s RFP basically complied with the components PEER considers to be “best practices” for an RFP, the document provided less than complete information in the areas of legal and contractual information and proposal evaluation.
Although DOM’s and UMMC’s requests for proposals were exempted from requirements of the Department of Information Technology Services for information system RFPs, would ITS have considered these RFPs to be fair to potential proposers?
At PEER’s request, the Department of Information Technology Services offered an informal third-party opinion regarding whether each of the RFPs was fair to potential proposers. Although the department’s staff acknowledged that the two entities’ RFPs followed different models, they concluded that neither RFP appeared to be unfair to potential proposers.
Evaluation of Proposed Expenditures by the Division of Medicaid and University of Mississippi Medical Center to Implement Their Electronic Health Records Systems
What are the proposed expenditures and funding sources for the Division of Medicaid’s electronic health records and e-prescribing system?
The Division of Medicaid initially estimated the six-year lifecycle cost of its electronic health records and e-prescribing system at $28.5 million; the division’s consultant later projected the cost to be less than $10 million. The division plans to use Hurricane Katrina Stabilization Grants, Medicaid Transformation Grants, ARRA funds, and its own funds to fund the expenses of the system.
What are the proposed expenditures and funding sources for the University of Mississippi Medical Center’s health care information system?
The University of Mississippi Medical Center initially estimated the five-year lifecycle cost of its health care information system to be approximately $50 million, but later revised the cost to be approximately $70 million. The medical center plans to use revenues generated from patients and ARRA funds that UMMC anticipates receiving to fund the expenses of the system.
Evaluation of the Use of ARRA Funds Available for Implementation of Electronic Health Record Systems in Mississippi
What types of ARRA incentive payments are available for health care providers?
The federal American Recovery and Reinvestment Act of 2009 provides more than $19 billion to states for Medicare and Medicaid health information technology incentives over five years. Types of incentives are Medicare payments for eligible professionals, Medicare payments for hospitals, Medicaid payments for health care providers, and grants to states and state-designated entities.
Because ARRA incentive payments became effective for hospitals on October 1, 2010, and will become effective for other health professionals on January 1, 2011, it is not yet possible to know the portion of the $19 billion in ARRA funds that Mississippi providers will receive.
Recommendations
Also, the Legislature should amend MISS. CODE ANN. Section 25-53-25 (1972) to require the department to co-sign information technology and services contracts for agencies’ purchases that have received an exemption from the department’s procurement oversight.