Medicare Providers Still Aren't All Ready For Y2Kgreenspun.com : LUSENET : TimeBomb 2000 (Y2000) : One Thread |
LinkLack of comprehensive Year 2000 preparedness throughout the providers surrounding the Medicare program could prove an "enormous" problem for the healthcare industry come Jan. 1, 2000, the General Accounting Office (GAO) reported yesterday in a joint House subcommittee hearing...
[snip]
Testifying before the Commerce Subcommittees on Oversight and Investigations and Health and Environment, GAO Y2K watchdog Joel C. Willemssen said that since Medicare plans to process more than 1 billion claims and pay $288 billion in benefits, Year 2000 failures could wound the healthcare sector significantly.
Willemssen said the Health Care Financing Administration (HCFA) under the Department of Health and Human Services indeed had made some readiness improvements, but that internal and contractor-based preparation problems still exist...
[snip]
The members said that after reviewing Year 2000 progress in Medicare, its contractors, HCFA and other parts of the Health and Human Services Department, "the committee has become increasingly concerned about the continuity of healthcare service at the turn of the century in the event that HCFA, its contractors or its providers are not Y2K- compliant."
[end snip]
-- regular (zzz@z.z), April 29, 1999
This is the report to watch for ...Year 2000 Computing Crisis: Readiness of Medicare and the Health Care Sector, by Joel C. Willemssen, Director of Civil Agencies Information Systems Issues, before subcommittees of the House Committee on Commerce. GAO/T-AIMD-99-160, Apr. 27.
http:// www.gao.gov/new.items/newtitle.htmDiane
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
APRIL 27, 1999 . . . 18:00 EDTHCFA, GAO square off over Y2K
By ORLANDO DE BRUCE (odebruce@fcw.com)
http://www.fcw.com/pubs/fcw/1999/0426/web-hcfa-4-27-99.htmlA top administrator at the Health Care Financing Administration today told two House subcommittees that she is "relatively optimistic" that the Medicare provider payment systems will be free of Year 2000 computer failures, but she cannot be so sure about medical devices.
HCFA administrator Nancy-Ann DeParle told a joint hearing of the Health and Environment Subcommittee and the Oversight and Investigations Subcommittee that Medicare claims are expected to be paid "promptly and accurately'' after Jan 1, 2000, based on surveys received from participating health care providers.
"Providing quality care goes beyond billing and claims processing,'' DeParle said. "It depends on doctors, hospitals and other service providers ensuring that their medical equipment will work and their offices remain open. It also depends upon pharmaceutical and medical supply chains continuing to operate uninterrupted."
Joel Willemssen, director of the Civil Agencies Information Systems office in the Accounting and Information Management division at the General Accounting Office, said his office is less optimistic about HCFA's payment systems and medical devices. Willemssen said HCFA has not been "rigorous enough" in testing its payment systems to accurately determine if they are Year 2000-compliant.
"The health care sector has not made adequate progress regarding Y2K," Willemssen said. "HCFA lacks a detailed end-to-end testing plan. I'm more pessimistic. The heath care sector is not in good shape because of what we don't know."
According to HCFA, nearly 100 percent of Medicare Part B claims providers and more than 90 percent of Part A claims providers filed Year 2000-compliant forms this month with eight-digit date fields. DeParle said HCFA is working with industry trade groups to bring the compliance rate to 100 percent for Part A and Part B claims.
Willemssen said medical devices such as magnetic resonance imaging systems, X-ray machines, pacemakers and cardiac monitors still appears to be vulnerable to the Year 2000 computer problem.
"Patient care is important, and that's the side of it we are all concerned about," DeParle said. "I'm dealing with the financing end of it."
Representatives from the Food and Drug Administration and the medical device industry declined to attend the joint hearing, according the members of the subcommittees.
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
"Willemssen said medical devices such as magnetic resonance imaging systems, X-ray machines, pacemakers and cardiac monitors still appears to be vulnerable to the Year 2000 computer problem."I thought pacemakers were given a clean bill of health? My mother-in-law and grandmother have pacemakers. Can someone please give definitive answers on this?
-- regular (zzz@z.z), April 29, 1999.
regular,Found the testimony available at (perhaps the pacemaker info is buried in their statements) ...
The House Committee on Commerce
http:// www.house.gov/commerce/welcome.htmlApril 27, 1999
Joint Hearing by the Subcommittee on Health & Environment and the Subcommittee on Oversight & InvestigationsRegarding: Y2K and Medicare Providers: Inoculating Against the Y2K Bug
Available Witness Lists, Member Statements and Other Documents
http:// com-notes.house.gov/cchear/hearings106.nsf/Witnesses?OpenView& StartKey=E325FEECF45F975585256758007C3D5F(Lots of testimony reading at that link -- 9 people involved -- time for more coffee -- Groan!)
Diane
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Diane--- I love the "sigh" but the "groan" coming from you could make me real nervous. Your imput is tremendous, thanks. With all the gibberish on this forum wouldn't it be great to get inside your head and get your read on all of this.
-- thinkIcan (thinkIcan@make.it), April 29, 1999.
thinkIcan,Just because Health Care is so Y2K mission-critical, IMHO, (right up there with water & the food supply), I'm taking the time to read each testimony and posting the relevant snips.
Slow process. That's what the *Groan* is about.
Diane
One down ...
Statement of Ms. Nancy-Ann Min DeParle
Administrator
Health Care Financing Administration
04/27/99
http://com- notes.house.gov/cchear/hearings106.nsf/ 768df0faa6d9ddab852564f1004886c0/ 77450b8896b54a6d85256760005fd554?OpenDocument[begin snip]
... Our systems will be able to accurately and timely process and pay claims, but providers must be able to generate and submit legitimate claims to our contractors. We are, therefore, engaged in an unprecedented outreach effort to raise awareness of the need to be Year 2000-ready and provide information to health care providers and other parts of the health care system where we have little authority and control. As a part of our broad provider outreach effort, we have:
mailed a letter on the importance of the Year 2000 and how to achieve compliance to each of our 1.3 million providers;
established a website (www.hcfa.gov/y2k) with information and checklists on what providers must do to meet their Year 2000 responsibility;
held Year 2000 Action Week conferences in 12 cities across the nation to raise provider awareness of Year 2000 issues;
created a speakers bureau with agency staff around the country who are speaking to provider groups about Year 2000 readiness; and
initiated other efforts to work with provider groups and institutions to help them meet their Year 2000 responsibilities.
Background
Our foremost concern has been, and continues to be, ensuring that our more than 70 million Medicare, Medicaid, and Childrens Health Insurance Program beneficiaries continue to receive the health care services they need in the new millennium. We are aggressively addressing Year 2000 issues in the systems over which we have responsibility. ...
[*Sigh* & snip]
All of our internal systems were renovated, tested, certified, and implemented by the government-wide Year 2000 deadline of March 31, 1999. In fact, our 25 mission-critical internal systems were compliant, including end-to-end and future-date testing, three months ahead of that deadline. Among other things, these internal systems:
- manage the eligibility, enrollment, and premium status of our 39 million Medicare beneficiaries;
- make payments to approximately 386 managed care plans on behalf of over six million beneficiaries; and
- operate HCFA=s accounts receivable and payable operations.
As of last week, 73 of 75 mission-critical claim processing systems, operated by private insurance contractors that process Medicare claims and pay bills, were certified as compliant, including end-to-end and future-date testing. Since last week the remaining two contractors have furnished documentation of certification, and we are evaluating that information now.
[Sounds good ... snip]
... I would like to take a moment to explain the process we used for declaring a system to be compliant. As you are aware, we required that all mission-critical systems be renovated, tested, and implemented by the federal governments March 31, 1999 deadline. Seventy of the systems were actually self-certified as compliant by the contractors at the end of 1998, but we accepted only 54 of those certifications -- those with qualifications that we deemed to be minor -- at that time. And we asked the contractors to address and resolve those qualifications. We then required that all contractors, including those that we had previously certified as compliant with qualifications, to complete their Year 2000 readiness work by March 31, 1999, and submit written reports on the status of their systems by April 5, 1999.
We thoroughly reviewed all of the certifications and accompanying qualifications, if any, that we received by April 5, 1999. We supplemented our analysis of the paperwork with evidence gathered by our own on-site review teams. We provided all the certifications and accompanying qualifications to our independent verification and validation (IV&V) expert, AverStar, and, in conjunction with them, then made an assessment of each system. Also, as a part of our ongoing collaboration with the Department of Health and Human Services Office of the Inspector General (OIG) and the General Accounting Office (GAO), we provided these oversight bodies all of the certification and qualification information and reviewed our analysis and conclusions with them. Because of the rigor and thoroughness of our testing and reviews, I am quite confident that our systems will be able to process and pay claims timely and appropriately at the turn of the millennium.
[Good news ... also in the snipped part too]
We also hope to implement the updates to physicians and other Part B providers and suppliers starting January 17, applying them retroactively to all claims for services on or after January 1. Our IV&V contractor describes this as the Aoptimal solution@ because it < b> avoids a payment freeze while providing a reasonable amount of time for cleaning up any Year 2000-related problems identified in early January before the systems changes would be made.
[Planning for a claims lag time of three weeks ... snip]
... And we have given providers the opportunity to test with those systems to determine whether their claims, including future-dated claims, can be successfully accepted and processed. Our test results have been encouraging, thus far. For example, a major national hospital network has future-date tested successfully with nine claims processing contractors. We do not know of any other payers that are giving providers the opportunity to test the submission of future- dated claims.
Such provider testing gives us a better indication of how many providers have actually done the necessary renovations to make their billing systems compliant. ...
[snip]
Being able to submit claims and get paid is, however, only one reason why health care providers must meet their Year 2000 responsibility. Computer system problems could impact quality of care and patient safety. Patient management systems, clinical information systems, medical devices, such as defibrillators and infusion pumps, and even elevators and security systems all must be checked, renovated, and tested to make sure they are ready so that providers can give quality care.
We are concerned that some providers will not meet the Year 2000 challenge on time. Health care sector monitoring by us, the OIG and others, indicates that some providers are substantially behind in their remediation efforts and could well fail. Providers have the primary responsibility to ready their own systems for the Year 2000 in a timely manner to meet the millennium challenge successfully. We do not have the authority, ability, or resources to step in and fix systems for others. We are providing assistance to the extent that we are able, but in some cases that likely will not be enough. This matter is of urgent concern, and literally grows in importance with each passing day.
Provider Outreach Activities
[snip]
This past January, in an unprecedented step, we sent a letter to each of our more than 1.3 million Medicare and Medicaid providers stressing the importance of Year 2000 readiness, including the need to assess readiness, test systems, as well as develop contingency plans for unanticipated failures. We also provided an inventory checklist of office equipment and supplies they need to assess for Year 2000 compliance. A copy of this letter was printed in the Federal Register and distributed to every Member of Congress.
[Hummm ...]
We established a website dedicated to the Year 2000 (www.hcfa.gov/ y2k) advising providers how to identify mission-critical hardware and software and assess its readiness; test systems and their interfaces; and develop contingency plans should unexpected problems arise. The website also includes links to other pertinent sites, such as the Food and Drug Administrations website on medical device readiness. < /b> The site registered nearly 25,000 visits last month.
[snip]
... In addition, we meet regularly with managed care industry groups and trade associations to discuss and resolve Year 2000 issues. We know that our partners, including the American Association of Health Plans (AAHP) and the Health Insurance Association of America (HIAA) have been actively involved in outreach to their members.
Importantly, we required all Medicare managed care organizations to submit certifications to us about their Year 2000 readiness by April 15, 1999. We are quickly working to obtain an initial sense of the certifications submitted under the managed care data request. We also are requiring them to provide contingency plans by July 15, 1999. ...
[snip]
... By September 1999, we should have a more accurate assessment of overall plan readiness. We will work closely with and monitor those plans at greatest risk and are developing contingency plans should problems arise in this area.
I was pleased to learn that some provider associations, including the American Medical Association and the American Hospital Association, have begun to assess the Year 2000 readiness of their membership and to step-up their educational efforts on the critical nature of this problem. This is an essential undertaking. Quite simply, Year 2000 compliance cannot be a one-way street. All providers must meet the Year 2000 challenge head on, or risk not being able to receive prompt payment from Medicare, Medicaid, or virtually any other insurer, as well as risk serious compromise to patient care and safety.
[snip]
Achieving Year 2000 Readiness
[snip]
... Providing quality care to beneficiaries goes well beyond billing and claims processing. It depends upon doctors, hospitals, and other service providers ensuring that their medical equipment will work and their offices remain open. It also depends upon pharmaceutical and medical supply chains continuing to operate uninterrupted.
Providers also need to make sure they are able to submit claims to their State Medicaid systems, and in turn, the State systems must also be ready.
[snip]
... Our preliminary surveys are consistent with earlier work by the GAO that suggests some States may not be ready on time.
[snip]
... Again, we do not have the ability, authority, or resources to step in and fix State systems, and can provide only limited assistance. We are sharing whatever survey information we gather directly with the States, to provide them, at a minimum, with an independent appraisal of their Year 2000 issues and progress. It is the responsibility of each State to determine the appropriate steps it must take to meet its Year 2000 responsibility and the needs of its beneficiaries.
Contingency Planning
Regardless of success in renovating and testing systems for Year 2000 readiness, both we and providers must have business continuity and contingency plans prepared in case unanticipated problems arise. We have undertaken an extensive effort to develop these plans for all our mission-critical business processes, as should providers. Our priorities are to ensure that we can:
continue prompt and accurate payments to providers, suppliers, and others;
safeguard the Medicare Trust Funds by preventing and recovering inappropriate payments;
protect quality of care; and
sustain beneficiary entitlement and enrollment.
For HCFA, contingency planning is an agency-wide effort with active participation of all of our senior executives. We are closely following the GAOs advice on contingency planning outlined in their August 1998 guidance, Year 2000 Business Continuity and Contingency Planning and in their September 1998 report, Medicare Computer Systems --Year 2000 Challenges Put Benefits and Services in Jeopardy. We have developed and are now validating our contingency plans. ...
[snip]
Our contingency plans will, of course, factor in the possibility of provider failure. I hope the subcommittees will appreciate the delicate balance that exists between our top two contingency planning goals of paying providers promptly and preventing payment errors. Let me stress that I firmly believe that no contingency plan should cause providers who fail to prepare for the Year 2000 to be rewarded for their lack of attention, effort, or due diligence. It is quite clear that it would not fulfill our fiduciary responsibilities to pay monies from the Medicare Trust Funds in the absence of appropriate evidence that a covered service was delivered to a beneficiary.
Conclusion
We have made remarkable progress in meeting the Year 2000 challenge, as have many providers. However, we remain seriously concerned with the progress of some providers in meeting their own Year 2000 challenges. We are committed to raising awareness and providing as much assistance as we can, but in some cases that may not be enough.
[snip ... to end]
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Bold off.
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Interesting Y2K testing and errors introduced in remediated code info below.Diane
Statement of Mr. Joel Willemssen
Director, Accounting and Information Management Division
General Accounting Office
04/27/99
http://com- notes.house.gov/cchear/hearings106.nsf/ 768df0faa6d9ddab852564f1004886c0/ 8227de35056cef1885256760005ff369?OpenDocument[snip]
We reported in February that while some progress by the Department of Health and Human Services' (HHS) Health Care Financing Administration (HCFA)--and its contractors--had been made in addressing the numerous recommendations we made last year(1) to improve key HCFA management practices associated with its Y2K program, many significant challenges remained.(2) At the time, we also reported that while some progress had been achieved, many states' Medicaid systems were at risk, and much work remained.(3)
Beyond Medicare and Medicaid, the information available on the national level concerning Y2K readiness throughout the health care sector--including providers, insurers, manufacturers, and suppliers-- indicates much work remains in renovating, testing, and implementing compliant systems. Also, as we recently testified, while information on the compliance status of biomedical equipment is available through a clearinghouse maintained by the Food and Drug Administration (FDA), the test results for this equipment are not reviewed. (4) Finally, information on the Y2K readiness of pharmaceutical and medical-surgical manufacturers is incomplete.
HCFA's ABILITY TO PROCESS MEDICARE
CLAIMS INTO THE NEXT CENTURY
As the nation's largest health care insurer, Medicare expects to process over a billion claims and pay $288 billion in benefits annually by 2000. The consequences, then, of its systems' not being Y2K compliant could be enormous. ...
[snip]
... In February, we testified that although HCFA had been responsive to our recommendations and that its top management was actively engaged in its Y2K program, its reported progress was highly overstated. We testified that none of HCFA's 54 external mission- critical systems reported compliant by HHS as of December 31, 1998, was Y2K ready, based on serious qualifications identified by the independent verification and validation (IV&V) contractor. Further, we reported that HCFA continued to face serious Y2K challenges. Specifically, HCFA
' lacked an overall schedule and critical path to identify and rank Y2K tasks to help ensure that they could be completed in a timely manner;
' needed a formal risk management process to highlight potential technical and managerial weaknesses that could impair project success;
' continued to have thousands of electronic data exchanges that were not Y2K compliant;
' faced a significant amount of testing in 1999, especially since changes will continue to be made to its mission-critical systems to make them compliant; and
' needed to sustain its efforts to complete and test business continuity and contingency plans to ensure that Medicare claims will be processed next year.
The Office of Management and Budget (OMB) also continues to be concerned about HCFA's progress. In its March 18, 1999, summary of Y2K progress reports of all agencies for the reporting quarter ending February 12, 1999, it concluded that HCFA remains a serious concern due to external systems testing, implementation schedules, and the qualified compliance of a number of external mission-critical systems. OMB further stated that although Medicare contractors had been making an intensive effort to complete validation and implementation by the governmentwide deadline of March 31, 1999, some external contractors may not succeed. Due in large part to HCFA's status, OMB designated HHS as a tier 1 agency on its three-tiered rating scale, meaning it had made insufficient progress in addressing the Y2K problem.
HCFA's Actions To Achieve Compliance and
Bolster Outreach Efforts to Medicare Providers
HCFA has been responsive to our recommendations. ...
[Lots of good details ... snip]
... HCFA further plans to perform end-to-end testing with its Y2K- compliant test sites. These end-to-end tests are to include all internal systems and contractor systems; however, they will not include testing with banks and providers.
[snip]
Reported Status of HCFA's Mission-Critical Systems
HCFA operates and maintains 25 internal mission-critical systems; it also relies on 75 external mission-critical systems operated by contractors throughout the country who process Medicare claims. These external systems include six standard processing systems and the "Common Working File." Each contractor relies on one of these standard systems to process its claims, and adds its own front-end and back-end processing systems. The Common Working File is a set of databases located at nine sites that works with internal and external systems to authorize claims payments and determine beneficiary eligibility.
In HHS' latest Y2K quarterly progress report to OMB, dated February 10, it reported that as of December 31, 1998, all 25 of HCFA's internal mission-critical systems were reported to be compliant, as were 54 of the external systems. Yet as we testified in February, none of these 54 systems was Y2K ready because all had important associated qualifications (exceptions), some of them significant. (6) HCFA issued a memorandum in early January requesting Medicare carriers and fiscal intermediaries to resolve these qualifications by March 31, the federal target date for Y2K compliance. HCFA reported to us on April 19, 1999, that most of these qualifications have been resolved and that 73 of 75 external systems are now compliant (the total number of external mission-critical systems decreased from 78 to 75 because three contractors plan to leave the Medicare program before the end of the year).
[snip]
Despite Reported Compliance, HCFA's Mission-Critical Systems
Still Require Additional Y2K Renovation and Testing
The HCFA mission-critical systems that have been characterized as Y2K compliant are not, however, the final systems that will be processing Medicare claims on January 1, 2000. These systems will undergo a significant amount of change between now and July 1, 1999, for both Y2K and other reasons. These changes will require a complete retest to ensure that the systems have not been contaminated by the changes and that they still are indeed Y2K compliant.
[Interesting!]
Specifically, these changes will address (1) outstanding qualifications, (2) additional Y2K changes, (3) a critical software release of the Common Working File, and (4) legislative mandates. (7) In addition to the changes required to address outstanding qualifications, changes are also occurring because of other compliance issues not listed as qualifications. For example, three standard system maintainers are currently updating their systems because the earlier renovation was performed with noncompliant compilers. (8) Each of these three upgrades is scheduled to be completed by July 1999. In addition, analyses using tools that determine the Y2K readiness of software code are uncovering additional Y2K programming errors. For example, 28 programming errors were recently identified using a Y2K tool on the Florida standard system. These errors are to be corrected and tested by June 1999. According to HCFA officials, such errors were uncovered based on an inspection of only about one seventh of the software code associated with the Florida standard system. If time permits, HCFA is considering using this Y2K tool on 100 percent of the code on all of the standard systems.
In addition to these Y2K-related changes, HCFA is planning a major software release of the Common Working File in late June, and legislatively mandated changes are to occur through June. HCFA plans to conduct final tests of its systems between July 1 and November 1, 1999, then recertify all mission-critical systems as compliant without qualification or exception. These final tests will ultimately determine whether HCFA's mission-critical systems are Y2K compliant. The late 1999 time frames associated with this testing represent a high degree of risk.
Other Critical Risks and Challenges Remain
Testing is a critical area in which HCFA faces significant challenges. Complete and thorough testing is essential to providing reasonable assurance that new or modified systems will process dates correctly and will not jeopardize an organization's ability to perform core business operations. Because the Y2K problem is so pervasive, potentially affecting an organization's systems software, applications software, databases, hardware, firmware, embedded processors, telecommunications, and interfaces, the requisite testing can be extensive and expensive. Experience is showing that Y2K testing is consuming between 50 and 70 percent of a Y2K project's time and resources. According to our guide, to be done effectively, testing should be planned and conducted in a structured and disciplined fashion.(9)
To date, HCFA's testing of its external systems has not been rigorous. HCFA's IV&V contractor has reported concerns with test documentation, readiness, and coverage associated with HCFA's external mission- critical systems. Specifically, the IV&V contractor reported that the quality of test documentation has been found to be incomplete and inadequate during a significant number of site visits. In addition, the results of using a Y2K tool to assess renovation quality and test readiness on each of the standard systems revealed that both indicators are primarily rated in the low to medium ranges, meaning that errors exist that could cause Y2K-related system failures.
The IV&V contractor also reported that HCFA's contractors have no satisfactory mechanism for determining the quality of test coverage (e.g., systems functionality, HCFA-mandated dates, interface coverage) associated with the self-certification testing. Because of this, HCFA issued instructions on April 9, 1999, that required contractors to submit information on the functionality covered by their test cases. Until test coverage is determined and testing is fully executed, the quality of the testing conducted will remain unknown.
In addition, two standard system maintainers did not test with the Common Working File, rather, they used a system that simulates the functions performed by the Common Working File. Testing with a system that simulates the Common Working File is less than ideal since the simulated system is not identical to the actual system. HCFA has acknowledged this and plans to have these two standard system maintainers test with the Common Working File during the recertification testing.
Further, testing has not been completed in the optimal sequence to ensure compliance of all systems. Since each contractor relies on one of the six standard systems to process its claims, ideally each of these six standard systems should have been completely tested before the contractors tested their front-end and back-end processing systems with their respective standard systems. However, only the Florida standard system maintainer completed future-date testing before the system was provided to its 29 contractors. Thus, more than half of the contractors tested with standard systems that had not completed Y2K testing. Managing multiple testing baselines and ensuring that corrections to one system's testing errors does not lead to problems in another system is a major challenge.
In September 1998 we recommended that HCFA rank its remaining Y2K work on the basis of a schedule that includes milestones for renovation and testing of all systems, and that it include time for end-to-end testing and development and testing of business continuity and contingency plans.(10) Such a schedule is extremely important because of the number of systems, their complexity, and interdependencies among them. However, HCFA still lacks an integrated schedule. The complexity and required sequencing of the 75 external and 25 internal systems associated with the recertification requires an integrated testing schedule to avoid scheduling constraints. For example, the Common Working File and standard systems should be tested initially so that the contractors can test with fully compliant systems. Without an integrated schedule, HCFA cannot effectively prioritize remaining work or ensure that all Y2K testing will be completed on time.
HCFA's late start and the limited time remaining raises risks that the recertification testing will likewise not be as rigorous as necessary. Two areas already have us concerned--testing overlap and a decrease in the number of future dates that will be tested. HCFA officials told us that contractors will begin to test with the Common Working File before it is completely Y2K-tested. Ideally, these tests should be done sequentially so that each contractor can test with a fully Y2K- tested Common Working File. Also, although HCFA's recertification will test four future dates, two more than the self-certification testing, this total is fewer than what HCFA had originally planned. Initially, HCFA planned to test with nine future dates.
In addition to such individual systems testing, HCFA must also test its systems end-to-end to verify that defined sets of interrelated systems, which collectively support an organizational core business function, will work as intended. As mentioned, HCFA plans to perform this end-to-end testing with its Y2K-test sites. These tests are to include all internal systems and contractor systems, but will not include testing with banks and providers. HCFA has required its contractors to future-date test with providers and financial institutions. Even excluding banks and providers, end-to-end testing of HCFA's internal and external systems is a massive undertaking that will need to be effectively planned and carried out. HCFA has not yet, however, developed a detailed end-to-end test plan that explains how these tests will be conducted or that provides a detailed schedule for conducting them.
A final aspect of testing concerns the independent testing contractor. HCFA expects this testing to be completed by August 31. This contractor currently plans to test eight internal systems and the six external standard systems. Originally, all 25 internal mission- critical systems were to be tested. In addition, because of the changing nature of the Medicare systems and the limited remaining time, the independent testing will be conducted with systems that were available January 1999, not with the exact systems that will be operating on January 1, 2000.
HCFA also faces risks because it has thousands of data exchanges that are not yet compliant. HCFA's systems--both internal and external-- exchange data, both among themselves and with the CWF, other federal agencies, banks, and providers. Accordingly, it is important that HCFA ensure that Y2K-related errors will not be introduced into the Medicare program through these data exchanges. HCFA's total number of data exchanges dropped significantly since February 10, 1999. The number of internal data exchanges declined from 7,968 to 3,209, while the number of external data exchanges dropped from 255,383 to 141,866. HCFA officials attributed this decrease to "performing a major cleanup of the data." As of April 9,1999, HCFA reported that only four of its 3,209 internal data exchanges were still not compliant, and that over 3,000 of its 141,866 external data exchanges were not compliant. To ensure that HCFA's internal and external systems are capable of exchanging data between themselves as well as with other federal agencies, banks, and providers, it is essential that HCFA take steps to resolve the remaining noncompliance of these data exchanges.
Given the magnitude of HCFA's Y2K problem and the many challenges that continue to face it, the development of contingency plans to ensure continuity of critical operations and business processes is absolutely critical. Therefore, HCFA must sustain its efforts to complete and test its agencywide business continuity and contingency plans by June 30. Another challenge for HCFA is monitoring the progress of the 62 separate business continuity and contingency plans that will be submitted by its contractors. We will continue to monitor progress in this area.
Other issues that further complicate HCFA's Y2K challenge are planned October 1, 1999, and January 1, 2000, provider payment updates; the known and unknown contractor transitions that are to take place before January 1, 2000; and the unknown status of the managed care organizations serving Medicare beneficiaries. We have requested detailed information on the specific changes that the October 1 and January 1 updates will require to determine the amount of testing that will be necessary after these changes are made. HCFA already is faced with too much to test in too little time, and these updates further contribute to already monumental testing challenges.
As reported in HHS' quarterly submission to OMB, HCFA is concerned about the possibility of Medicare contractors, fiscal intermediaries, and carriers leaving the program and notifying HCFA of this after June. If this were to occur, the workload would have to be transferred to another contractor whose Y2K-compliance status may not be known. According to both contractor and HCFA officials, it requires 6-12 months to transfer the claims processing workload from one contractor to another. At present, HCFA is transitioning the work of the three contractors that are leaving the program.
HCFA required the 386 managed care organizations currently serving 6.6 million Medicare beneficiaries to certify their systems as Y2K compliant by April 15. As of April 21, 1999, HCFA had received certifications from 315 of the organizations. Similar to fee-for- service contractors, 271 of the 315 certifications contained qualifications. We plan to review these certifications as part of our ongoing work for the Senate Special Committee on Aging to determine whether the managed care organizations' systems are Y2K compliant and whether a formal recertification would have to be performed later this year.
MEDICAID SYSTEMS ARE AT RISK
Similar to Medicare, the systems supporting the Medicaid program also face Y2K challenges and risk. In fiscal year 1997, Medicaid--a joint federal-state program supported by HCFA and administered by the states--provided about $160 billion to millions of recipients. Medicaid provides health coverage for 36 million low-income people, including over 17 million children. Its beneficiaries also include elderly, blind, and disabled individuals.
In surveying states' Y2K status last summer,(11) we found that many systems were at risk and much work remained to ensure the continuation of services. ...
[snip]
In response, HCFA administered two state self-reported surveys and conducted several on-site visits and found that overall state Medicaid systems status had improved little. ...
[snip]
Y2K READINESS OF THE HEALTH CARE SECTOR:
MUCH WORK REMAINS
At this point, I would like to broaden our discussion to the Y2K- readiness status of the health care sector, including biomedical equipment(12) and pharmaceutical and medical-surgical products used in the delivery of health care. While it is undeniably important that Medicare and Medicaid systems be compliant so that the claims of health care providers and beneficiaries can be paid, it is also critical that the services and products associated with health care delivery itself be Y2K compliant. However, with just over 8 months until the turn of the century, the level of progress to date is not reassuring.
Virtually everything in today's hospital is automated--from the scheduling of procedures such as surgery, to the ordering of medication such as insulin for a diabetic patient, to the use of portable devices as diverse as heart defibrillators and thermometers. It, therefore, becomes increasingly important for health care providers such as doctors and hospitals to assess their health information systems, facility systems (such as heating, ventilating, and air conditioning equipment), and biomedical equipment to ensure their continued operation on January 1, 2000. Similarly, pharmaceutical manufacturers and suppliers that rely heavily on computer systems for the manufacture and distribution of drugs must assess their processes for compliance. Given the large degree of interdependence among components of the health sector--providers, suppliers, insurance carriers, and patients/consumers--the availability and sharing of Y2K readiness information is vital to safe, efficient, and effective health care delivery.
In response to an October 1998 request from the Chair of the President's Council on Year 2000 Conversion, several federal agencies and professional health care associations surveyed key components of the health care sector. Accordingly, the amount of readiness information on this sector has increased in recent months. The survey results, however, indicate that much work still remains in renovating, testing, and implementing compliant systems. Further, readiness information on the health sector is still incomplete because a significant number of sector members did not respond to the surveys.
According to a survey that the American Hospital Association (AHA) sent to 2,000 of its members in February 1999, much work remains. For example, based on the 583 responses received as of March 1, 1999, the hospitals reported that only about 6 percent of the medical devices, 13 percent of information systems, and 24 percent of physical plant/ infrastructure are compliant. However, most hospitals indicated that they expect to be compliant by the end of the year. (13)
The American Medical Association's (AMA) survey to 7,000 physicians showed that approximately 47 percent of the 522 physicians that responded by mail or telephone indicated that they do not have a good understanding of Y2K conversion, and have practices that are not Y2K ready. Almost all of these physicians reported that they would be ready by the end of the year. The survey disclosed no difference between the Y2K preparedness of large physician groups and solo or small physician groups (10 physicians or fewer). However, AMA stated that caution should be taken in interpreting the survey results due to the low response rate.
According to responses received to a December 1998 survey sent by HHS' Office of the Inspector General to a sample of 5,000 Medicare providers--1,000 each to hospitals, nursing homes, durable medical device manufacturers, physicians, and home health agencies--except for hospitals, providers reported making limited progress in assessing their biomedical equipment for Y2K compliance. All providers reported making limited progress in testing data exchanges between their computers and external vendors, and developing emergency backup plans in case of computer failures. Further, many Medicare providers did not respond to this survey. For example, the response rates for medical device manufacturers, physicians, and home health agencies were less than 30 percent.
[*Sigh* ... snip]
Finally, according to the second quarterly report by the President's Council on Year 2000 Conversion, the health care sector has not made adequate progress in addressing the Y2K problem.(14) The report stated that while recent surveys indicate that health care providers have a high level of confidence that they will complete much of the work on mission-critical systems before the end of the year, the actual number of systems made compliant to date is relatively low in areas from recordkeeping to infrastructure. The report noted that recordkeeping systems are "of great concern" because they play an essential role in processing payment claims to insurance companies and government health agencies.
Biomedical Equipment: Status Information Available for Many Items, < br> But Test Results Not Reviewed
The question of whether medical devices such as magnetic resonance imaging (MRI) systems, x-ray machines, pacemakers, and cardiac monitors can be counted on to work reliably on and after January 1, 2000, is critical to medical care delivery. To the extent that biomedical equipment uses embedded computer chips, it is vulnerable to the Y2K problem.
Such vulnerability carries with it possible safety risks. This could range from the more benign--such as incorrect formatting of a printout--to the most serious--such as incorrect operation of equipment with the potential to adversely affect the patient. The degree of risk depends in large part on the role the equipment plays in a patient's care.
Responsibility for oversight and regulation of medical devices, including the impact of the Y2K problem, lies with FDA. ...
[Lots of details about the compliance status of biomedical equipment database, and problems]
[snip]
... We reported last September that VHA and FDA relied on manufacturers to validate, test, and certify that equipment is Y2K compliant.(17) We also reported that there was no assurance that the manufacturers adequately addressed the Y2K problem for noncompliant equipment, because FDA did not require medical device manufacturers to submit test results to it certifying compliance. ...
[snip]
At the time, VA stated that it had no legislative or regulatory authority to implement the recommendation to review test results from manufacturers. In its response, HHS stated that it did not concur with our recommendation to review test results supporting medical device equipment manufacturers' certifications that their equipment is compliant. It said that the submission of appropriate certifications of compliance was sufficient to ensure that the certifying manufacturers' equipment was compliant. HHS also stated that it did not have the resources to undertake such a review, yet we are not aware of HHS' requesting resources from the Congress for this purpose.
More recently, VHA's Chief Biomedical Engineer told us that VHA medical facilities are not requesting test results for critical care/ life support biomedical equipment; they also are not currently reviewing the test results available on manufacturers' web sites. He said that VHA's priority is determining the compliance status of its biomedical equipment inventory and replacing noncompliant equipment. The director of FDA's Division of Electronics and Computer Science likewise said FDA sees no need to question manufacturers' certifications.
In contrast to VHA's and FDA's positions, some hospitals in the private sector believe that testing biomedical equipment is necessary to prove that they have exercised due diligence in the protection of patient health and safety. Officials at three hospitals told us that their biomedical engineers established their own test programs for biomedical equipment, and in many cases contacted the manufacturers for their test protocols. Several of these engineers informed us that their testing identified some noncompliant equipment that the manufacturers had previously certified as compliant. According to these engineers, to date, the equipment found to be noncompliant all had display problems and was not critical care/life support equipment. We were told that equipment found to be incorrectly certified as compliant included a cardiac catheterization unit, a pulse oxymeter, medical imaging equipment, and ultrasound equipment.
VHA, FDA, and the Emergency Care Research Institute(18) continue to believe that manufacturers are best qualified to analyze embedded systems or software to determine Y2K compliance. They further believe that manufacturers are the ones with full access to all design and operating parameters contained in the internal software or embedded chips in the equipment. VHA believes that such testing can potentially cause irreparable damage to expensive health care equipment, causing it to lock up or otherwise cease functioning. Further, a number of manufacturers also have recommended that users not conduct verification and validation testing.
[!!!???]
[snip]
Y2K-Readiness Information on Pharmaceutical and Medical-Surgical Manufacturers
Is Incomplete
Another question critical to the delivery of health care is knowing whether there will be sufficient supplies of pharmaceutical and medical-surgical products available for consumers at the turn of the century. As the largest centrally directed civilian health care system in the United States, VHA has taken a leadership role in the federal government in determining whether manufacturers supplying these products are Y2K-ready. This information is essential to VHA's medical operations because of its "just-in-time"(19) inventory policy. Accordingly, VHA must know whether its manufacturers' processes, which are highly automated,(20) are at risk, as well as whether the rest of the supply chain will function properly.
To determine the Y2K readiness of its suppliers, VA's National Acquisition Center (NAC)(21) sent a survey on January 8, 1999, to 384 pharmaceutical firms and 459 medical-surgical firms with which it does business. The survey contained questions on the firms' overall Y2K status and inquired about actions taken to assess, inventory, and plan for any perceived impact that the century turnover would have on their ability to operate at normal levels. In addition, the firms were requested to provide status information on progress made to become Y2K compliant and a reliable estimated date when compliance will be achieved for business processes such as (1) ordering and receipt of raw materials, (2) mixing and processing product, (3) completing final product processing, (4) packaging and labeling product, and (5) distributing finished product to distributors/wholesalers and end customers.
According to NAC officials, of the 455 firms that responded to the survey as of March 31, 1999, about 55 percent completed all or part of the survey. The remainder provided either general information on their Y2K readiness status or literature(22) on their efforts. As shown in table 1, more than half of the pharmaceutical firms surveyed responded (52 percent), with just less than one third (32 percent) of those respondents reporting that they are compliant. The table also shows that 54 percent of the medical-surgical firms surveyed responded, with about two thirds of them (166) reporting that they are Y2K compliant.
See ... Table 1: Status of Companies Surveyed by VHA as of March 31, 1999
On March 17, 1999, NAC sent a second letter to its pharmaceutical and medical-surgical firms, informing them of VA's plans to make Y2K readiness information previously provided to VA available to the public through a web site
http://www.va.gov/oa&mm/nac/ y2kVA made the survey results available on its web site on April 13, 1999. The letter also requested that manufacturers that had not previously responded provide information on their readiness. NAC's Executive Director said that he would personally contact any major VA supplier that does not respond.
On a broader level, VHA has taken a leadership role in obtaining and sharing information on the Y2K readiness of the pharmaceutical industry. ...
[snip]
The subcommittee consists of FDA; federal health care providers; and industry trade associations such as the Pharmaceutical Research and Manufacturers of America (PhRMA), Generic Pharmaceutical Industry Association, the National Association of Chain Drug Stores, and the National Wholesale Druggists' Association; and consumer advocates.
[snip]
See ... Table 2: Summary of Y2K-Readiness Survey Results From Pharmaceutical Manufacturers
[snip]
Based on their survey results, these industry trade associations believe that computer systems and software application problems will not substantially impede the ability of the supply chain to maintain an uninterrupted flow of medicines. However, in contrast to VHA's survey, the associations' surveys were provided in summary format and did not contain detailed information on the Y2K readiness of specific manufacturers or members of the supply chain. This information is necessary if consumers are to have confidence that there will be a sufficient supply of medications on hand at the turn of the century.
FDA's Y2K Efforts for Pharmaceutical and Biological Products Industries
Focused Initially on Awareness
FDA's oversight and regulatory responsibility for pharmaceutical and biological products(23) is to ensure that they are safe and effective for their intended uses. Because of its concern about the Y2K impact on manufacturers of these products, FDA has taken several actions to raise the Y2K awareness of the pharmaceutical and biological products industries. In addition, it is thinking about conducting a survey to determine the industry's Y2K readiness.
One of FDA's actions to raise industry awareness was the January 1998 issuance of industry guidance by the Center for Biologics Evaluation and Research (CBER) on the Y2K impact of computer systems and software applications used in the manufacture of blood products. In addition, as shown in table 3, FDA has issued several letters to pharmaceutical and biological trade associations and sole-source drug manufacturers.
[snip]
... FDA officials explained that the agency does not have sufficient resources to perform both regulatory oversight of the manufacturers and in-depth evaluations of firms' Y2K compliance activities.
[snip]
Like VHA, FDA is interested in the impact of Y2K readiness of pharmaceutical and biological products on the availability of products for health care facilities and individual patients. FDA's Acting Deputy Commissioner for Policy informed us on March 24, 1999, that the agency is thinking about surveying pharmaceutical and biological products manufacturers, distributors, product repackagers, and others in the drug dispensing chain, on their Y2K readiness and contingency planning. In anticipation of a possible survey, the agency published a notice in the March 22, 1999, Federal Register, regarding this matter. The Acting Deputy Commissioner said that potential survey questions on contingency planning would include steps the manufacturers are taking to ensure an adequate supply of bulk manufacturing materials from overseas suppliers. This is a key issue because, as we reported in March 1998,(25) according to FDA, as much as 80 percent of the bulk pharmaceutical chemicals used by U.S. manufacturers to produce prescription drugs is imported.
[!!! Thinking about ...??? Sheesh!]
In summary, HCFA and its contractors have made progress in addressing Medicare Y2K issues that we have raised. However, until HCFA completes its planned recertification between July and November, the final status of the agency's Y2K compliance will be unknown. Given the considerable amount of remaining work that HCFA faces, it is crucial that development and testing of HCFA's business continuity and contingency plans move forward rapidly to avoid the interruption of Medicare claims processing next year. Also, because many states' Medicaid systems are at risk, business continuity and contingency plans will become increasingly critical for these states in an effort to ensure continued timely and accurate delivery of benefits to needy Americans. Regarding the health sector overall, while additional readiness information is available, much work remains in renovating, testing, and implementing compliant systems. Aggressive action is needed in obtaining information on the Y2K readiness of hospitals, physicians, Medicare providers, and public health agencies. Until this information is obtained and publicized, consumers will remain in doubt as to the Y2K readiness of key health care components. In addition, while compliance status information is available for biomedical equipment through the FDA clearinghouse, FDA has not reviewed test results supporting manufacturers' certifications; this would provide the American public with a higher level of confidence that biomedical equipment will work as intended. The public also needs readiness information on specific pharmaceutical manufacturers to address concerns about the stockpiling of drugs and medications.
[snip -- to end -- lots of footnotes]
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Bold off again ... getting better.
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Mostly about the survey sent around.
Statement of George Grob
Deputy Inspector General
Department of Health and Human Services
04/27/99
http://com- notes.house.gov/cchear/hearings106.nsf/ 768df0faa6d9ddab852564f1004886c0/ 500bd97fac92b2cf8525676000600b53?OpenDocument[snip]
BACKGROUND
The Y2K problem impacts health care systems in several ways. For instance, medical records systems need to be updated to ensure providers are able to access patient histories. Biomedical devices such as defibrillators and infusion pumps must be checked to ensure they will continue to operate properly. Furthermore, both government and provider computer systems must be able to process claims after December 31, 1999 to ensure that providers get paid for services rendered.
[snip]
In order to gauge the readiness of health care providers, we designed two surveys which addressed several key areas, including Y2K awareness, computer system readiness, contingency planning, and vendor cooperation. The surveys were developed with assistance from HCFA and several provider associations, including the American Association of Homes and Services for the Aging, the American Health Care Association, the American Hospital Association, the American Medical Association, the Health Industry Distributors Association, the National Association for Home Care, the National Association for Medical Equipment Suppliers, the Health Insurance Association of America, and the American Association of Health Plans.
In late December 1998, we sent anonymous surveys to a random sample of 5,000 providers representing five provider groups: acute-care hospitals, nursing facilities, home health agencies, durable medical equipment (DME) suppliers, and physicians. Response rates ranged from a high of 49 percent for hospitals to a low of 22 percent for physicians. In January, we sent a similar survey to 407 Medicare + Choice managed care organizations. We had responses from 310, or 76 percent of those surveyed. Our findings are based solely on the providers who responded to our survey. We cannot make any statements about the Y2K-readiness of those providers who did not respond.
SURVEY FINDINGS
Overall, we found that as of January 1999, about half of fee-for- service providers reported that their computer systems were Y2K-ready; and most providers who were not ready believed they will be Y2K-ready by December 31, 1999. However, our survey indicated that many providers had not taken the steps necessary to justify their optimism. For instance, of the fee-for-service providers responding to our survey:
Less than two-thirds had renovated or replaced their computer systems.
Many had not tested their new or renovated systems.
Less than 1 in 5 had tested data exchange with their vendors.
For most, the readiness of biomedical equipment continues to be a "great unknown."
Only one-fourth to one-half had developed contingency plans.
The responses of managed care organizations were similar, although half of the plans have tested their systems and about two-thirds have developed contingency plans.
RECENT DEVELOPMENTS
What may be a better indicator of providers' progress is not what they said in our survey, but how they are currently submitting claims. Since the release of our survey, HCFA established April 5, 1999 as the deadline for submitting eight-digit dates on electronic claims. After this date, claims that are not in the required eight-digit format would be returned. This requirement was stressed in a January letter to all Medicare providers, as well as published on HCFA's web site and numerous provider association newsletters. Therefore, by monitoring providers' adherence to the new claim requirements, we can evaluate the progress providers have made in getting their billing systems ready for the new millennium. While the ability of a provider to submit claims in an eight-digit format does not mean that all of its systems are ready, it does serve as an indication that the provider has taken a critical step toward full Y2K compliance.
It appears that the health care providers have stepped up their efforts to submit claims that are Y2K compliant. On April 14, 1999, the Department reported that more than 99 percent of Part B claims and 90 percent of Part A claims were sent to HCFA with the newly-required eight-digit date. This is a significant increase from December 1998 when Medicare carriers reported that approximately 96 percent of Medicare Part B bill submitters and only 33 percent of Part A submitters that bill electronically were doing so in a compliant eight-digit date manner. We are monitoring the situation closely.
[Interesting ... whats the loophole here?]
REMAINING CONCERNS
While this preliminary information is promising, because of our findings, we are concerned that some providers have yet to perform the necessary steps to ensure that all their systems will be ready on time. Unlike most public agencies, where there is constant measurement and evaluation of Y2K progress, health care providers are under no requirements for renovation schedules, end-to-end testing of systems, independent verification of compliance efforts, etc. Neither HCFA nor any of the provider associations, such as physician or hospital associations, have the authority to compel individual health care providers to act. With the exception of HCFA's April 5th deadline for eight-digit claim submission, there are no readiness timelines or schedules which providers must follow.
The HCFA is in a somewhat stronger position with Medicare + Choice managed care organizations since it contracts directly with them to provide care to Medicare beneficiaries. The agency is requiring these organizations to certify that they understand HCFA's Y2K compliant definition and have tested all of their data systems/interfaces to ensure Y2K compliance. The HCFA is also requiring them to have a contingency plan in place in the event that internal systems or key external business partners fail. However, HCFA does not have the authority to require all health care providers to meet similarly specific requirements.
At this time, we have no additional updated information about the readiness of providers' medical record systems or biomedical equipment.
We believe the primary responsibility for ensuring Y2K readiness lies with providers themselves. We hope the provider community - both individual providers and their national associations - will rise to the challenge. However, with no one "in charge" of the providers, it is important that the Department monitor the progress of the providers, and assist them by making Y2K information readily available.
[snip -- to end]
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Mostly hospital good news ? ... with some concerns expressed ... toward the end.Statement of Ron Margolis
Chief Information Officer
University of New Mexico Hospital
04/27/99
http://com- notes.house.gov/cchear/hearings106.nsf/ 768df0faa6d9ddab852564f1004886c0/ 879356832ea3346d85256760006bd880?OpenDocument[snip]
... I am here on behalf of the American Hospital Association's (AHA) nearly 5,000 hospitals, health systems, networks, and other providers of care.
[snip]
PROGRESS ON Y2K COMPLIANCE
The majority of the nation's hospitals expect to be completely "AY2K compliant" by January 1, 2000, based on the results of a nationally representative survey we conducted. Of the balance, almost all expect to be sufficiently prepared that critical operations will not be affected. The survey occurred in February 1999, and asked hospitals about their Y2K readiness by the end of this year in three areas: information systems, medical devices and infrastructure/physical plant.
Our Y2K readiness survey indicates that almost all of the nation's hospitals expect to be prepared to meet the Y2K challenge. Respondents represented not-for-profit and investor-owned hospitals in urban and rural areas. Following are highlights.
Information Systems
Information systems include financial, billing, human resources, clinical, inventory control, and other systems.
12.9% of hospitals said their information systems were compliant when they responded in February 1999
Another 84.7% of hospitals either expected their information systems to be Y2K compliant by year end or expected no problems in their operations
0.5% expected non-compliance with possible adverse effects
Medical Devices
5.7% of hospitals said their devices were compliant when they responded in February
Another 90.4% of hospitals expected their devices to be Y2K compliant by year end or expected no problems in their operations
0.5% expected non-compliance with possible adverse effects
Physical Plant/Infrastructure
Physical plant/infrastructure includes such areas as heating and cooling, environmental control systems, telecommunications, and security systems.
23.8% of hospitals were compliant when they responded in February 1999
Another 71.7% expected to be Y2K compliant by year end or expected no problems in their operations
0.4% expected non-compliance with possible adverse effects
In the survey, less than one percent of hospitals predicted possible "adverse effects" in their critical operations as a result of the change to the Year 2000.
The AHA survey comes on the heels of a report issued last month by the Health and Human Services' Office of Inspector General (OIG) that also indicates high confidence in hospital Y2K readiness by the end of the year. ...
[snip]
Part of hospitals' Y2K preparation is to meet HCFA's requirement that Medicare bills be submitted in an 8-digit format B two slots each for the month and date, and four slots for the year. HCFA found that, as of mid-April, 90 percent of Part A bills, from organizations such as hospitals, skilled nursing facilities and home health agencies, were submitting Y2K compliant claims. Since this marks a more than 30 percent increase from the 58 percent compliance HCFA cited just two months ago in congressional testimony, we have every reason to believe that the percentage will approach 100 percent very soon.
The AHA survey results also respond to questions and statements suggesting that rural hospitals, contrary to what has been widely reported anecdotally, are keeping pace. According to the rural hospitals that responded to our February survey, 93 percent said their information systems were either totally compliant or were moving toward compliance without major difficulty; 92 percent said their medical devices were either totally Y2K compliant or were moving toward compliance without major difficulty; and 96 percent said their physical plants were either totally Y2K compliant or were moving toward compliance without major difficulty.
[snip]
CONTINGENCY PLANNING
America's hospitals and health systems are in the business of dealing with the unexpected. They are used to mobilizing quickly in the face of floods, hurricanes and potentially disastrous events that are an unfortunate fact of life. There is no reason to believe that they will not also be ready for the Year 2000.
[snip]
According to the AHA's survey, 66 percent of hospitals have initiated contact with utilities in their area; 44 percent have initiated contact with other hospitals; 38 percent have initiated contact with fire and police authorities; 36 percent have initiated contact with ambulance services; and 35 percent have initiated contact with their local governments.
[snip]
In addition, the AHA will be working with the Federal Emergency Management Administration to coordinate emergency preparedness efforts at a national level with contingency planning taking place at individual hospitals in local communities. We plan to bring together representatives of major health systems and health care manufacturing and supply companies to discuss how we can provide guidance to the health care field on issues related to Y2K preparedness and concerns about health care equipment and pharmaceutical and medical supply stockpiling.
HCFA's contingency plan
On average, hospitals and health systems receive roughly half of their revenues from government programs like Medicare and Medicaid. If that much revenue were to be suddenly cut off, hospitals could not survive, and patient care could be jeopardized. Hospitals would not be able to pay vendors. They would not be able to purchase food, supplies, laundry services, maintain medical equipment B in short, they would not be able to do the job their communities expect of them. All this would occur even as hospitals and health systems faced the substantial costs of addressing their own Year 2000 system needs B costs that are not recognized in the calculation of current Medicare payment updates.
[Wow! Half of hospital revenues come from government programs like Medicare and Medicaid!]
We applaud HCFA's announcement that the Fiscal Year 2000 PPS update will no longer have to be delayed while the agency prepares its computer systems for Y2K. We congratulate the agency's personnel for tackling the problem in such a way that it apparently will no longer require nearly $300 million in payment updates to be held back from the hospitals that need them. However, at the same time we are concerned that HCFA has not announced that it has an adequate contingency plan in place.
HCFA also must make sure its contractors -- including Medicare+Choice plans -- take steps to ensure that their performance will not be interrupted by Year 2000 problems caused by the millennium bug. HCFA should continue to make readily available its work plan, and progress reports, for bringing the contractors and Medicare+Choice plans into compliance and monitor their efforts. Letting providers know what changes may be required of them is also important. This would allow providers, contractors and plans to prepare simultaneously and ensure that their systems are compatible.
Even if HCFA and its contractors express confidence that their payment mechanisms will not be affected by the millennium bug, unforeseen problems could crop up. Therefore, it is imperative that HCFA establish a fail-safe contingency plan that anticipates and addresses how to respond in case payment mechanisms, either on the provider side or on HCFA's side, are disrupted at the turn of the century. We have offered to work with HCFA to ensure that these concerns about the Year 2000 are adequately addressed. However, HCFA has not yet shared with us any details of their contingency planning.
Medicare beneficiaries' health care needs will remain constant, regardless of how well payment systems are prepared for Year 2000 problems. If carrier and fiscal intermediary payment systems are clogged up by the millennium bug, hospitals' ability to continue providing high-quality health care could be severely affected. A system of advance payments, based on past payment levels, is one way to ensure that beneficiaries continue to receive the care they need, by assuring that hospitals have the resources necessary to care for Medicare patients. Congress should require HCFA to commit to such advance payments, or to other alternatives that would ensure continuity in case of a Y2K failure.
It is important to note that Medicare is not the only payer for hospital services. Similar payment delays could occur if private health insurers and, in the case of Medicaid, individual states, have not addressed their own Year 2000 problems. HCFA has the authority and leverage to prevent this from happening, and we urge the agency to exercise that authority.
THE SUPPLY CHAIN B MORE INFORMATION IS NEEDED
More than 60 percent of the hospitals responding to the AHA's Y2K readiness survey cited lack of information from suppliers as the number one barrier to achieving total Y2K compliance. The AHA is working with the Food and Drug Administration (FDA) to ensure that hospitals obtain the compliance information they need on medical devices and equipment. The AHA is also now focusing on a broad range of other suppliers to get the vendor information its members need, from medical device manufacturers to pharmaceutical and other medical supply companies.
[snip]
Prudent contingency planning will require an exchange of information between suppliers and providers. In the absence of reliable information, hoarding and stockpiling may occur, creating the very supply chain disruptions that everyone should be working to avoid.
THE ROLE OF THE AHA AND OTHER ASSOCIATIONS
[snip]
Protecting Public Confidence, Staying Abreast of Progress
We believe it is critical that the communities we serve understand what hospitals are doing to prevent any disruption to the provision of health care services. The AHA, in collaboration with our state, regional and metropolitan associations and other key strategic partners, is working hard to stress to our member hospitals the importance of managing the Y2K issue from a public confidence perspective. We have made available tools to counsel hospitals and health systems about how to talk with the public about Y2K and health care. A Y2K Communications Action Kit was developed that was distributed in early March to all of our members. Our members were encouraged to adapt the materials in the kits for use in their communities. The kit includes samples of how to communicate to various audiences about the Y2K issue.
[Oh. Good. Managed Care and Managed Confidence. Truth would be nice. Wonder if thats recommended? *Sigh*]
[snip]
Articles are appearing regularly in AHA News, our national newspaper, in Hospitals and Health Networks, our national magazine for hospital CEOs, in Trustee, our national magazine for volunteer hospital leadership, and in several other national publications that are published by various AHA membership societies. Several of these societies, such as the American Society for Healthcare Engineering, the American Society for Healthcare Risk Management, and the Association for Healthcare Resource and Materials Management, are deeply involved in helping their members attack the millennium bug in their hospitals.
THE COSTS OF COMPLIANCE
What are the costs of Y2K compliance expected to be? An earlier AHA survey researching this issue points to a huge financial investment by hospitals and health systems. The bottom line is that America's hospitals and health systems expect to spend somewhere around $8 billion to become Y2K compliant.
[Werent there Gartner Group figures that stated total US Y2K expenses were expected to be $6 billion? Huh?]
Smaller hospitals, those with fewer than 100 beds, will spend close to $1 billion on Y2K fixes, or an average of $435,000 each. Hospitals with between 100 and 300 beds will spend $2.5 billion, an average of $1.2 million each. Hospitals with 300-500 beds will spend nearly $2 billion, or $3.4 million each. The largest amount of spending, $2.2 billion, will occur at hospitals that have more than 500 beds.
[snip]
THE ROLE OF CONGRESS
... Your attention to this issue, through hearings such as this, reflects your understanding of the gravity of the situation.
[snip]
We ask you to help America's health care system avoid Year 2000 problems by taking several other steps:
Congress should provide the FDA with any additional authority or resources it needs to ensure the necessary information is disclosed by medical device manufacturers, and to serve a "rumor control" function regarding devices.
Congress should insist that HCFA use its authority to make advance payments under Medicare. These payments, based on past payment levels, should be implemented to ensure adequate cash flow for providers in case carrier and fiscal intermediary payment systems fail, or other disruptions to the normal operation of payments systems should occur due to the date change.
Last week John Koskinen, chairman of the President's Council on Year 2000 Conversion, mentioned the possibility of creating a contingency fund from which states (in the case of Medicaid, for example) or hospitals could draw monies needed to continue operating in case of a Y2K disruption. We support that principle, and would be glad to be a part of any discussions concerning how such a fund should be set up.
MedPAC has included in its hospital prospective payment system update recommendation for fiscal year 2000 an additional 0.5 percent to cover hospitals' costs of becoming Y2K compliant. We ask Congress to increase the congressionally mandated hospital update factor by 0.5 percent to reflect this MedPAC recommendation.
CONCLUSION
Mr. Chairman, the Year 2000 issue will affect every aspect of American life, but few, if any, are as important as health care. ...
[snip -- to end]
-- Diane J. Squire (sacredspaces@yahoo.com), April 29, 1999.
Regular, I remember reading that the pace maker problems are not the pacemakers themselves, it is the download of pacing information to the cardiologists computer. Many doctors have not gotten their updates done yet, and there is a concern that the information will be unreliable leading to mistaken treatment. Sorry I don't remember the links, I suggest that you go to a manufacturer's site to see what they have to say. If you have a particular pacemaker in mind, find out the manufacturer's name; you may even be able to get a URL from the cardiologist.
-- Tricia the Canuck (jayles@telusplanet.net), April 30, 1999.