Section 1
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1.1
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Is the program purpose clear?
Explanation:
The purpose of the NPDB is to ensure that licensing and
credentialing authorities have accurate and complete information
about practitioners' past damaging or incompetent performance
when making decisions to license or privilege individual health
care practitioners. The information collected and distributed
allows licensure and privileging officials to make more informed
decisions and, thereby, improve the quality of health care by
eliminating or restricting the ability of incompetent or
miscreant practitioners to practice. The purpose of the HIPDB is
to make information related to health care fraud and abuse
activities by practitioners, providers, and suppliers available
to law enforcement, licensing, and health plan officials. These
officials can use the information to avoid dealing with
fraudulent or abusing practitioners, providers, and suppliers or
to assist in their prosecution, thus helping to reduce fraud and
abuse and improve quality of health care. The HIPDB was
established as part of the fraud and abuse control efforts in the
Health Insurance Portability and Accountability Act of 1996.
Evidence: Section 402 of the Healthcare
Quality Improvement Act specifies the purpose of the NPDB.
Section 221(a) of the Health Insurance Portability and
Accountability Act of 1996 specifies the purpose of the HIPDB.
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YES
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20%
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1.2
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Does the program address a specific and existing problem,
interest, or need?
Explanation:
Concerning the NPDB, licensing and credentialing authorities
continue to require a reliable source of information to confirm
and augment information submitted by applicants for licensure and
clinical privileges to ensure that "previous damaging or
incompetent performance" is disclosed. Higher standards for
verification of credentials, when combined with the increasing
mobility of the health care workforce mean that it is more
important than ever that an authoritative source of verification
information is available to ensure that past damaging or
incompetent performance is discovered before a practitioner is
licensed or granted privileges. Concerning the HIPDB, law
enforcement and licensing and health plan officials have a need
for adverse action and fraud and abuse-related information on
practitioners, providers, and suppliers to help them make more
informed licensure, contracting, or prosecutorial decisions.
Estimates of the level of losses related to fraud and abuse in
health care range from $50,000,000,000 to $100,000,000,000 each
year. Medicare and Medicaid fraud and abuse have been estimated
at $33,000,000,000 a year. Estimates of Medicare fraud and abuse
range up to 14 percent of all Medicare expenditures.
Evidence:
Ten years after the NPDB became operational, a survey of
licensing and credentialing authorities by the University of
Illinois at Chicago and Northwestern University found that
information provided by the NPDB was very influential in
decision-making in over two-thirds of the cases in which
licensing or credentialing authorities received reports of
previous adverse actions or malpractice payments. There is also
strong evidence that practitioners continue to have licensure and
disciplinary actions taken against them and that they continue to
be responsible for incidents which lead to malpractice payments.
During 2005, there were over 4,000 State licensure actions, over
900 clinical privileges actions, over 1,200 Medicare/Medicaid
exclusion actions, and over 17,000 malpractice payments reported
to the NPDB. During 2005 the HIPDB received almost 1,400 reports
of healthcare-related criminal convictions. In addition the HIPDB
received almost 26,000 State licensure action reports, and almost
4,000 other reports.
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YES
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20%
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1.3
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Is the program designed so that it is not redundant or
duplicative of any other Federal, state, local or private
effort?
Explanation: There are no
other programs in either the public (Federal, State or local),
non-profit or private sectors that collect the range of
information collected by the NPDB and the HIPDB. The stated
purpose of the Data Banks, as articulated in their authorizing
legislation, clearly identified the need for national systems to
collect this type of information because a similar or duplicative
system did not exist.
Evidence: Other
than the NPDB, no national data collection system for all
malpractice payments exists; malpractice insurers generally
release this competitive information only as required by law.
Similarly, other than the NPDB and HIPDB, no national repository
of clinical privileges, health plan action, or professional
society membership information exists. There are systems which
contain voluntarily submitted and sometimes not comprehensive
State licensure information for some types of practitioners.
These systems are generally operated by federations of State
licensing boards for a few professions. They do not normally
contain information on malpractice payments, clinical privileges,
professional society membership actions, civil judgments,
criminal convictions, Medicare and Medicaid exclusions, etc.
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YES
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20%
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1.4
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Is the program design free of major flaws that would limit the
program's effectiveness or efficiency?
Explanation:
The current design of both programs, NPDB and the HIPDB, includes
the use of a contractor to administer the NPDB and HIPDB computer
operations and the use of Federal staff to develop policy and
manage the programs. It has been determined that the existing
design of the program maximizes program efficiency and
effectiveness as it allows for continual quality improvement in
the functioning and responsiveness of databanks. Unlike the NPDB,
the HIPDB statute does not allow (or require) hospitals to query
its data banks, resulting in a dramaticly lower amount of user
fees for the program, relative to those received by the NPDB.
Federal government agencies, such as CMS and HHS OIG, are not
required to pay the user fees for querying the HIPDB as they must
do when querying the NPDB. This also results in decreased income
for the HIPDB. HIPDB's program managers and contractor's have
been able to keep the HIPDB functioning and achieving its goals
and objectives, in part due to efforts that have increased data
bank's efficiency over the past several years.
Evidence:
Aside from the design flaw within the statute of the HIPDB,
independently conducted surveys for both data banks have shown
adequate to high levels of customer satisfaction with the
systems.
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NO
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0%
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1.5
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Is the program design effectively targeted so that resources
will address the program's purpose directly and will reach
intended beneficiaries?
Explanation:
All NPDB revenue comes directly from NPDB queriers who submit and
pay for queries (requests for copies of NDPB reports). Similarly,
almost all HIPDB revenue comes directly from HIPDB query fees,
although a small amount comes from the Health Care Fraud and
Abuse Control (HCFAC) account to compensate for free queries from
federal agencies (by law). No funds are appropriated for either
program. All revenues are used for the NPDB and HIPDB programs'
purposes and support the operation of the NPDB and HIPDB. The
NPDB and HIPDB do not make any grants or otherwise subsidize any
programs. Targeted "beneficiaries" of the NPDB and
HIPDB programs are 1) the legally authorized queriers and
reporters; 2) individual practitioners, providers, and suppliers,
who are permitted to obtain a copy of their own NPDB and/or HIPDB
record; and 3) researchers, who may obtain statistical data.
Evidence: Eligible reporters and
queriers ("beneficiaries") are specified in law and
regulations. The enabling statutes also require that the programs
be funded from user fees. Eligible queriers submit over 3,500,000
queries each year to the NPDB and over 900,000 queries each year
to the HIPDB. They also file over 25,000 reports to the NPDB and
over 33,000 reports to the HIPDB each year. Researchers download
over 3,000 copies of the NPDB Public Use Data File each year.
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YES
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20%
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Section 2
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2.1
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Does the program have a limited number of specific long-term
performance measures that focus on outcomes and meaningfully
reflect the purpose of the program?
Explanation:
The program has developed two long-term measures.
Evidence:
Long Term Measure 1: Increase the annual number of licensing and
credentialing decisions which limit practitioners' ability to
practice because of information contained in NPDB and HIPDB
reports. Long Term Measure 2: Increase the annual number of times
information provided by the NPDB and HIPDB is considered useful
by the querying entity which received it.
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YES
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14%
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2.2
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Does the program have ambitious targets and timeframes for its
long-term measures?
Explanation: The
Data Banks programs' have ambitious targets and timeframes for
their long-term measures (please see evidence section). Three
experts within the medical credentialing field have attested to
the ambitiousness of these targets: 1) Ms. Jodi Schirling, CPMSM,
Manager of Corporate Credentialing for Nemours, past-President of
the National Association of Medical Staff Services, and also
Chair of the National Practitioner Data Bank's "Executive
Committee" (a voluntary committee composed of industry
representatives) stated: "I have reviewed the baseline and
target data used in the OMB Program Assessment and Review Tool
for the NPDB and HIPDB. I have been in the credentials field for
almost 30 years. Based on my experience in credentialing, and as
a Past President of the National Association Medical Staff
Services, I think the data is meaningful and the targets are
ambitious." 2) Christina W. Giles, CPMSM, MS, President of
Medical Staff Solutions and a partner in Edge-U-Cate, LLC, stated
"I have reviewed the baseline and target data used in the
OMB Program Assessment and Review Tool for the NPDB and HIPDB. I
have been in the credentials/medical staff services
administration area for over 25 years. Based on my experience in
the field of credentialing and my work experience as a consultant
for the past ten years working with medical staffs across the
country, and as faculty/teacher of this field for 20+ years, I
would agree that the data identified is realistic and meaningful
and the targets for the coming years are ambitious." 3)
Susan J. Freeburn, RN, Director of the Credentials Verification
Program of the Armed Forces Institute of Pathology's (AFIP)
Department of Legal Medicine, and a credentialing leader for the
Department of Defense, stated: "I have reviewed the data
attached for the NPDB-HIPDB programs targets for long-term
measures and find them both ambitious with reasonable timeframes.
Looking at the past performance and projecting to the future,
your goals look to be attainable. "As the Director of the
AFIP, Department Legal Medicine's CVO for the past five years, we
have witnessed the effect of a positive NPDB or HIPDB with the
agencies that we are contracted to do PSV. The Data Bank's
information has been an invaluable tool for finding malpractice
and unethical behaviors in practitioners in all walks of the
medical field."
Evidence: Long
Term Measure 1: The annual number of licensing and credentialing
decisions which limit practitioners' ability to practice because
of information contained in NPDB and HIPDB reports. Baseline:
Based on matched query responses (not reports) NPDB HIPDB 2005
44,500 Decisions 1,120 Decisions Target for FY 2013: NPDB HIPDB
2013 48,700 Decisions 1,400 Decisions Long Term Measure 2: The
annual number of times information provided by the NPDB and HIPDB
is considered useful by the querying entity which received it.
Baseline: NPDB HIPDB 2005 451,400 Useful Disclosures 11,400
Useful Disclosures Target for FY 2013: NPDB HIPDB 2013 489,000
Useful Disclosures 14,200 Useful Disclosures
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YES
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14%
|
|
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2.3
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Does the program have a limited number of specific annual
performance measures that can demonstrate progress toward
achieving the program's long-term goals?
Explanation:
The program has developed two annual measures which are identical
to its long-term measures except that data is collected, and
progress toward achieving their long-term targets is monitored,
annually.
Evidence: Annual Measure 1:
The annual number of licensing and credentialing decisions which
limit practitioners' ability to practice because of information
contained in NPDB and HIPDB reports: Annual Measure 2: The annual
number to times information provided by the NPDB and HIPDB was
considered useful by the querying entity which received it.
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YES
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14%
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2.4
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Does the program have baselines and ambitious targets for its
annual measures?
Explanation: The
Data Banks programs' have ambitious targets and timeframes for
their long-term measures. Three experts within the medical
credentialing field have attested to this ambitiousness of these
targets: 1) Ms. Jodi Schirling, CPMSM, Manager of Corporate
Credentialing for Nemours, past-President of the National
Association of Medical Staff Services, and also Chair of the
National Practitioner Data Bank's "Executive Committee"
(a voluntary committee composed of industry representatives)
stated: "I have reviewed the baseline and target data used
in the OMB Program Assessment and Review Tool for the NPDB and
HIPDB. I have been in the credentials field for almost 30 years.
Based on my experience in credentialing, and as a Past President
of the National Association Medical Staff Services, I think the
data is meaningful and the targets are ambitious." 2)
Christina W. Giles, CPMSM, MS, President of Medical Staff
Solutions and a partner in Edge-U-Cate, LLC, stated "I have
reviewed the baseline and target data used in the OMB Program
Assessment and Review Tool for the NPDB and HIPDB. I have been in
the credentials/medical staff services administration area for
over 25 years. Based on my experience in the field of
credentialing and my work experience as a consultant for the past
ten years working with medical staffs across the country, and as
faculty/teacher of this field for 20+ years, I would agree that
the data identified is realistic and meaningful and the targets
for the coming years are ambitious." 3) Susan J. Freeburn,
RN, Director of the Credentials Verification Program of the Armed
Forces Institute of Pathology's (AFIP) Department of Legal
Medicine, and a credentialing leader for the Department of
Defense, stated: "I have reviewed the data attached for the
NPDB-HIPDB programs targets for long-term measures and find them
both ambitious with reasonable timeframes. Looking at the past
performance and projecting to the future, your goals look to be
attainable. "As the Director of the AFIP, Department Legal
Medicine's CVO for the past five years, we have witnessed the
effect of a positive NPDB or HIPDB with the agencies that we are
contracted to do PSV. The Data Bank's information has been an
invaluable tool for finding malpractice and unethical behaviors
in practitioners in all walks of the medical field."
Evidence: Annual Measure 1: The annual
number of licensing and credentialing decisions which limit
practitioners' ability to practice because of information
contained in NPDB and HIPDB reports. Baseline: NPDB HIPDB 2005
44,500 Decisions 1,120 Decisions Annual performance targets for
FY 2006 - 2008 are: NPDB HIPDB 2006 45,025 Decisions 1,155
Decisions 2007 45,550 Decisions 1,190 Decisions 2008 46,075
Decisions 1,225 Decisions Annual Measure 2: The annual number to
times information provided by the NPDB and HIPDB is considered
useful by the querying entity which received it. Baseline: NPDB
HIPDB 2005 451,400 Useful Disclosures 11,400 Useful Disclosures
Annual performance target for FY 2006 - 2008: NPDB HIPDB 2006
456,100 Useful Disclosures 11,750 Useful Disclosures 2007 460,800
Useful Disclosures 12,100 Useful Disclosures 2008 465,500 Useful
Disclosures 12,450 Useful Disclosures
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YES
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14%
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2.5
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Do all partners (including grantees, sub-grantees,
contractors, cost-sharing partners, and other government
partners) commit to and work toward the annual and/or long-term
goals of the program?
Explanation:
The NPDB- HIPDB operating contractor is the only formal partner.
The contractor's performance is monitored with weekly and monthly
reports. Performance measures are established in the contract,
and the contractor is rewarded with bonus payments if performance
targets are exceeded and fined if performance targets are not
met. The contractor is dedicated to meeting or exceeding the
performance targets.
Evidence: In
general, over the past five years the contractor has met
performance goals. Measures and standards for performance goals
include (1) a website for reporting and querying accessible and
functioning at least 94 percent of the time (less than 100
percent to allow for weekend downtime for maintenance and
improvements), (2) an average response time for computer matched
queries of no more than 3.75 hours, and (3) an erroneous
disclosure rate for queries on practitioners of no more than 0.15
percent. Six other measures are also used, including one for
"customer (i.e., PDBB) satisfaction." If the
contractor's performance is below the standard, money is
subtracted from the performance incentive award. If the
contractor substantially exceeds the standard, money is added to
the performance incentive award. An example of when the
contractor did not meet expectations and PDBB's action concerns
the second quarter in FY '03, when several research-related
products were delivered which did not meet government quality
expectations for accuracy and had to be redone by the contractor
after PDBB discovered data errors. As a result, PDBB reduced the
amount that the contractor receives as a Performance Fee
Incentive Award for that quarter. Performance metrics include
up-time for the querying and reporting web site, response time
for query responses, time for human resolution of doubtful
matches, time for report processing notification, erroneous
disclosure rates, customer service center telephone wait time,
and customer satisfaction.
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YES
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14%
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2.6
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Are independent evaluations of sufficient scope and quality
conducted on a regular basis or as needed to support program
improvements and evaluate effectiveness and relevance to the
problem, interest, or need?
Explanation:
The NPDB and HIPDB regularly conduct independent, unbiased,
scientific evaluations of the programs. Approximately every 5 to
6 years since its opening, the NPDB has contracted with an
independent researcher to conduct national scope surveys of NPDB
reporters and queriers. The surveys are designed to assess user
satisfaction with the NPDB, to determine how NPDB information is
being used for decision-making, and to determine what kind of
program improvements might be beneficial. The most recent of
these surveys was completed in 2001 and was conducted jointly by
Northwestern University Institute for Health Services Research
and Policy Studies and the University of Illinois at Chicago
Health Policy Center Survey Research Laboratory. The next survey
will be conducted beginning in 2006. In the interim, the NPDB and
HIPDB have contracted for independent American Customer
Satisfaction Index surveys. The HIPDB ACSI survey was conducted
in 2002 and the NPDB ACSI survey was conducted in 2003. The HIPDB
survey found reporter satisfaction at "68" and querier
satisfaction at "76." The average for all federal
programs was "70.2" and for all private sector programs
was "73.1." The NPDB survey found that satisfaction for
queriers was "78" and for reporters was "76."
The federal agency average that year was "70.9" and the
private sector average was "73.8." The Data Bank
programs are among the highest rated federal government programs.
The program expects to again conduct ACSI surveys in 2010 or
2011.
Evidence: The NPDB and HIPDB
programs' evaluations, past and future, are as follows: 2001:
Assessment of overall satisfaction with reporting and querying
processes of the National Practitioner Data Base (NPDB) - by
Northwestern University's Institute for Health Services Research
and Policy Studies and University of Illinois at Chicago's Health
Policy Center, Survey Research Lab. 2002: HIPDB American Customer
Satisfaction Index Survey (ACSIS) 2003: NPDB American Customer
Satisfaction Index Survey (ACSIS) 2006: Award of contract for
large national sample survey of NPDB and HIPDB users and
non-users. Final report expected in 2008. 2010 - 2011: American
Customer Satisfaction Index Surveys of NPDB and HIPDB users.
2012: Award of contract for large scale national sample survey of
NPDB and HIPDB users and non-users. Final report expected in
2014. This schedule is a continuation of the schedule for
national surveys and ACSI surveys previously conducted for the
NPDB and later the HIPDB.
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YES
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14%
|
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2.7
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Are Budget requests explicitly tied to accomplishment of the
annual and long-term performance goals, and are the resource
needs presented in a complete and transparent manner in the
program's budget?
Explanation:
Within the Congressional Justification document both Data Banks
programs provide a description of the total costs associated with
operating their respective data banks. However, the programs do
not explicitly tie their budgets, each of which are funded almost
entirely through user fee collections, to their ability to
accomplish their annual and long-term goals. The relationship
between the two programs' annual and long-term targets and their
user fee levels is not clear.
Evidence:
The budget justifications for the Data Banks programs' activities
are included in the Health Resources Administration Fiscal Year
2007 Justification of Estimates for Appropriation Committees.
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NO
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0%
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2.8
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Has the program taken meaningful steps to correct its
strategic planning deficiencies?
Explanation:
No strategic planning deficiencies have been identified in the
last five years.
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NA
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0%
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Section 3
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3.1
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Does the agency regularly collect timely and credible
performance information, including information from key program
partners, and use it to manage the program and improve
performance?
Explanation: The agency
regularly collects information for program management and
improvement purposes. This information includes: reporting and
querying volumes, fee payments, calls to the NPDB and HIDPB
Customer Assistance Center, timeliness of processing, and
operating problems. In addition, program and contract officials
solicit comments from stakeholder and customer organizations as
well as users on program performance and policies and provide
suggestions for improvements. The information collected is used
to adjust program priorities, allocate resources, or other
appropriate management actions. The program has also obtained
baseline data to set meaningful targets for its annual and long
term performance measures. These data are obtained from surveys
conducted approximately every five years to assess user
satisfaction with the program and its operations and to learn
what could be improved.
Evidence: Based
on the information collected from these various mechanisms, the
program has made numerous management improvements including
improved electronic data collection "forms",
improvements to the Internet-based querying and reporting
processes, and modifications and clarifications of Data Bank
policies.
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YES
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14%
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3.2
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Are Federal managers and program partners (including grantees,
sub-grantees, contractors, cost-sharing partners, and other
government partners) held accountable for cost, schedule and
performance results?
Explanation:
The NPDB and HIPDB have a formal schedule for system enhancements
as reflected by new system software and web releases planned for
specific dates. The NPDB and HIPDB operating contract establishes
quantitative performance metrics which are evaluated quarterly,
via the Quarterly Performance Metrics Report. Penalties are
assessed or bonuses are awarded to the contractor depending on
compliance with the standards established in the contract.
Government Managers operate under a pass/fail system that clearly
outlines their specific duties. Modest financial rewards also
exist for outstanding performance. Annual and bi-annual reviews
are conducted to ensure acceptable standards of performance are
being met. Both the NPDB-HIPDB Program and Project Managers have
and continue to receive "Outstanding" performance
rating for the overall management of the NPDB-HIPDB program.
Evidence: 1) The Quarterly Performance
Metrics Report This report contains two parts: Part I - contains
the performance summary that lists each metric and the
contractor's level of performance for the quarter. It also
contains a brief written explanation of any factors that caused
performance to fail to meet expectations. Part II - contains a
breakdown, by metric, of the incentive payment due and penalties
assessed for the quarter. 2) HHS Performance Evaluations Plan
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YES
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14%
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|
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3.3
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Are funds (Federal and partners') obligated in a timely
manner, spent for the intended purpose and accurately
reported?
Explanation: The NPDB and
HIPDB programs are operated from user fee collections. These user
fees are primarily used to operate, maintain, and enhance these
Data Banks. User query payments are made via Credit Card or
Electronic Funds Transfer (EFT) through a U.S. Department of
Treasury contract with Mellon Bank. Program Management monitors
on a weekly basis NPDB and HIPDB financial transactions, and on a
monthly basis performs the financial reconciliation between
Mellon Bank and the contractor. In addition, all program income
(i.e., query fee collections) and expenses (i.e., administrative
costs) information is reviewed and audited on a monthly
basis.
Evidence: It is the
responsibility of the NPDB-HIPDB Project Manager to manage the
day-to-day financial efforts of NPDB and HIPDB Operations (i.e.,
contractual obligations) and Administration (i.e., program
staff). The NPDB has several processes in-place to track how the
user fee income is managed and spent. 1. On a monthly basis a
"Statement of Income and Expenses" report is generated
for the NPDB and HIPDB. This report shows monthly contract and
Government administrative costs and User Fee Income collected.
Every line item cost that is recorded during that given month is
reviewed for validity before it is incorporated into the
cumulative monthly reports. 2. There also exists a "NPDB
Expenditures & Funding Requirements" document that
outlines all contractual and administrative financial obligations
for past, present, and future NPDB requirements. Periodically,
these reports are briefed to HRSA Management and the Data Banks
stakeholders.
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YES
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14%
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3.4
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Does the program have procedures (e.g. competitive
sourcing/cost comparisons, IT improvements, appropriate
incentives) to measure and achieve efficiencies and cost
effectiveness in program execution?
Explanation:
The NPDB and HIPDB Program Staff is continuously looking for
methods for improving system efficiencies and reducing
operational costs. One significant approach that is used is to
insist on reliable, repeatable, and managed processes to ensure
that the system and any improvements are designed and developed
with high quality are on schedule and are within budget. To date,
several improvements in efficiency and cost effectiveness have
been implemented (see evidence for a list of these improvements).
In addition, the program has an efficiency measure -- The length
of time it takes the NPDB and HIPDB to process a query and return
results to the querier. The challenge to the NPDB and HIPDB is to
maintain query response time within the 240 minute threshold even
though the task of matching queries to reports becomes more
difficult each year as both the number of queries and the number
of reports in the NPDB and HIPDB continue to increase
substantially each year. Data Banks' efficiency measure: Produce
increasing amounts of output in the same amount of time. Numbers
of queries responded to within 240 minutes Baseline 2005
4,414,000 queries 2006 Target: 4,611,000 queries 2007 Target:
4.701,000 queries 2008 Target: 4,792,000 queries
Evidence:
Examples of cost savings and improved efficiencies that have
taken place during the management of the NPDB and the HIPDB
include: 1. Cost savings resulting from the elimination of a
dedicated electronic mailbox system and communications contract.
Users no longer need to e-mail queries and reports through a
dedicated network service provider paid for by the NPDB. NPDB and
HIPDB customers now use the Internet for all data bank
communications at no additional cost to them beyond their normal
Internet connection charge and at a significant communications
cost savings to the NPDB and HIPDB. 2. Cost savings resulting
from virtual elimination of paper processing. The Internet-based
system was redesigned to virtually eliminate paper processing.
Users can now not only query and report electronically, they can
also update their registration information on-line, retrieve
electronic billing information, access documentation and help
files, and perform simplified self-queries. 3. Cost savings from
all electronic payment. The system provides for query payment
only by credit card or Electronic Funds Transfer (EFT). This
eliminates the need to accept and process checks, and has
significantly reduced both costs and the need to collect unpaid
checks. 4. Improved accuracy of information reported and
submitted for query match. The web interface enables improved
validation of information submitted to the Data Banks. Validation
rules are in effect for both queries and reports. Improved
validation helps to ensure that all required information is
provided and properly formatted before a report or query can be
submitted. This improves report data quality.
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YES
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14%
|
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3.5
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Does the program collaborate and coordinate effectively with
related programs?
Explanation: Since
by law there is some overlap in the information collected by the
National Practitioners Data Bank and the Health Care Integrity
Data Banks, as well as some overlap in the organizations that
provide or access this information, efficient collaboration and
coordination is between the two Data Banks is paramount. The NPDB
supplies computer operations for the HIPDB through the NDPB
operating contract. Reporters required to report file only one
report which is automatically placed in the correct data bank or
banks as required based on the information they supply in the
report. Reporters do not have to have a detailed understanding of
the laws' requirements to ensure that they report to the correct
data bank. Queriers eligible for both data banks also may submit
only one query which is routed to both data banks. In addition,
program management staff operate the "Secretarial Review"
process for resolving disputed reports jointly for the two
programs, applying separate regulations as necessary.
Practitioners with reports in both data banks need file only one
dispute to open a case relative to both data banks. Operating
metrics used to assess contractor performance are also assessed
jointly for both data banks. System improvements for one data
bank also are implemented for the other data bank. To the limited
extent that there are programs elsewhere in the federal
government, State and local governments as well as the private
sector, the Data Banks work well with these programs. For
example, in the federal sector, the HHS Office of Inspector
General (OIG) collects and discloses actions it takes against
practitioners authority to bill the Medicare and Medicaid
programs, through an on-line database. These actions also are
reported to the Data Banks by the OIG. The Data Banks set up an
efficient system for the OIG to report this information to the
Data Banks using the same database the IG uses for its systems.
In another example, the Data Banks work with the National
Association of State Insurance Commissioners (NAIC) to compare
its statistical data to NPDB statistical data on malpractice
payments to assess reporting compliance.
Evidence:
1) The electronic reporting interface does not ask reporters
eligible to report to both the NPDB and the HIPDB which data bank
they are reporting to. Instead it automatically files reports
with the correct data bank or data banks depending on the
information in the report being submitted. 2) The NPDB and HIPDB
now contain almost 31,000 Medicare/Medicaid exclusion reports. 3)
The NPDB routinely purchases annual "Supplement A to
Schedule T" data from the NAIC to compare to NPDB
malpractice payment reporting information.
|
YES
|
14%
|
|
|
|
|
3.6
|
Does the program use strong financial management
practices?
Explanation: In 2005, HHS
received a material control weakness for its financial systems
and processes. HRSA contributes to the material internal control
weakness identified in the 2005 HHS audit. HHS is in the process
of resolving these weaknesses by replacing existing accounting
systems within HHS with the Unified Financial Management System
(UFMS). UFMS is scheduled to be operational for HRSA in October
2006.
Evidence: Since 2003, HRSA has
been not been included in a consolidated HHS audit. In a 2005
audit of HHS, Ernest and Young found a material weakness in HHS
financial systems and processes. In particular, the audit found:
Documentation regarding significant accounting events, recording
of non-routine transactions and post-closing adjustments, as well
as correction and other adjustments made in connection with data
conversion issues must be strengthened. Processes to prepare
financial statements need improvement. Financial systems are not
FFMIA compliant. Weaknesses were identified in
Department/Operating Division Periodic Analysis, Oversight and
Reconciliations In addition, the audit found PSC's DFP CORE
accounting system, which supports the activities of HRSA, did not
facilitate the preparation of timely financial statements and did
not have an efficient mechanism in place to compile accounting
statements.
|
NO
|
0%
|
|
|
|
|
3.7
|
Has the program taken meaningful steps to address its
management deficiencies?
Explanation:
The Unified Financial Management System (UFMS) will improve funds
control and monitoring and provide real-time data. In addition to
streamlining the accounting process, HHS monitors funds received
through annual Independent Financial Audits from grantees.
Evidence: To address management
deficiencies, HRSA developed a baseline assessment of grantees to
provide information about the overall strengths and weaknesses
within the program. In 2005, HRSA implemented a web-based data
collection system through the Electronic Handbook on the HRSA
GEMS site to improve the data quality and elements collected.
HRSA also held a TA conference call with consultants presenting
elements of health care and business plans to incorporate program
planning and provide HRSA program staff concrete information for
grantee goals.
|
YES
|
14%
|
|
|
|
|
Section 4
|
4.1
|
Has the program demonstrated adequate progress in achieving
its long-term performance goals?
Explanation:
The historical performance data collected by the program for both
measures supports the conclusion that the NPDB and HIPDB will
reach their long term goals. No targets were previously adopted
for the Useful Disclosures measure shown in this PART review.
Targets for "decisions affected" have been modified
over the years based on results of the most recent survey of
users and delays in implementation of Section 1921 regulations,
which will likely shift queries from the HIPDB to the NPDB.
Targets for Decisions Affected were established for the NPDB as
early as for FY '99 (before the HIPDB was opened) and were based
on results from the NPDB's first national survey of users. The
first target goal was 10,400 decisions affected. The target was
substantially adjusted upward for FY '01 and beyond based on
results of the NPDB's second national user survey and querying
volume targets. Historical data that indicates that both data
banks have made good progress in achieving its first long-term
goal, "Increasing the number of licensing and credentialing
decisions which limit practitioners' ability to practice because
of information contained in NPDB and HIPDB reports" since
1999: Year NPDB NPDB HIPDB HIPDB Decisions Affected Actual
Decision Affected Actual Target Performance Target Performance
1999 10,400 10,800 n/a n/a 2004 42,700 43,800 800 1,000 2005
48,600* 44,500 560* 1,120 2013 48,700 1,400 *Target assumed
substantial increase based on implementation of Section 1921
Regulations, which did not happen. Actual Performance shows
continued increase despite what proved to be an unwarranted
target. Historical data that indicates that both data banks have
made good progress in achieving its second long-term goal
"Increasing the number of times information provided by the
NPDB and HIPDB is considered useful by the querying entity which
received it" since 2001: NPDB HIPDB 2001 ACTUAL 393,100
Useful Disclosures 8,300 Useful Disclosures 2005 ACTUAL 451,400
Useful Disclosures 11,400 Useful Disclosures 2013 TARGET 489,000
Useful Disclosures 14,200 Useful Disclosures
Evidence:
1) Decisions affected targets (long-term/annual measure 1) for
NPDB and HIPDB in 2005 were set based on proposed schedules for
adoption of Section 1921 regulations. However, the regulations
were not adopted as planned. Because of the assumed
implementation of the Section 1921 regulations, the 2005 target
for the NPDB was set much too high and the 2005 target for the
HIPDB was set too low. In fact, actual 2005 performance of both
data banks continued to show healthy improvement. American
Customer Satisfaction Index Results for the HIPDB 2) American
Customer Satisfaction Index Results for the NPDB
|
YES
|
25%
|
|
|
|
|
4.2
|
Does the program (including program partners) achieve its
annual performance goals?
Explanation:
The historical performance data collected by the program for both
measures supports the conclusion that the NPDB and HIPDB have
largely achieved their annual performance goals. Targets for
"decisions affected" have been modified over the years
based on results of the most recent survey of users and delays in
implementation of Section 1921 regulations, which will likely
shift queries from the HIPDB to the NPDB. Targets for Decisions
Affected were established for the NPDB as early as for FY '99
(before the HIPDB was opened) and were based on results from the
NPDB's first national survey of users. The first target goal was
10,400 decisions affected. The target was substantially adjusted
upward for FY '01 and beyond based on results of the NPDB's
second national user survey and querying volume targets.
Historical data indicating that both data banks have largely
achieved their goals for their first annual measure, "Increasing
the number of licensing and credentialing decisions which limit
practitioners' ability to practice because of information
contained in NPDB and HIPDB reports" over the past 7 years:
Year NPDB NPDB HIPDB HIPDB Decisions Affected Actual Decision
Affected Actual Target Performance Target Performance 1999 10,400
10,800 n/a n/a 2000 13,350 11,050 700 675 2001 38,000 38,700
1,000 820 2002 39,750 39,800 836 810 2003 47,385* 39,900 1,200
850 2004 42,700 43,800 800 1,000 2005 48,600* 44,500 560* 1,120
*Target assumed substantial increase based on implementation of
Section 1921 Regulations, which did not happen, (therefore the
targets for NPDB where higher and those for HIPDB lower). Actual
Performance shows continued increase despite what proved to be an
unwarranted target. Historical data indicating that both data
banks have largely achieved their goals for their second annual
measure, "Increasing annually the number of times
information provided by the NPDB and HIPDB is considered useful
by the querying entity which received it" over the past 5
years: NPDB HIPDB 2001 393,100 Useful Disclosures 8,300 Useful
Disclosures 2002 403,600 Useful Disclosures 8,200 Useful
Disclosures 2003 404,500 Useful Disclosures 8,600 Useful
Disclosures 2004 444,200 Useful Disclosure 10,200 Useful
Disclosures 2005 451,400 Useful Disclosures 11,400 Useful
Disclosures The program had not created targets for this measure
prior to this year; however their annual data on this measure
does indicate that both data banks have made yearly progress on
this measure since 2001. (The only indication of a lack of
progress came for the HIPDB in 2003, but this was reversed in
2004 and 2005.)
Evidence: 1) Decisions
affected targets (long-term/annual measure 1) for the NPDB in
2003 and the NPDB and HIPDB in 2005 were set based on proposed
schedules for adoption of Section 1921 regulations. However, the
regulations were not adopted as planned. Because of the assumed
implementation of the Section 1921 regulations, the 2005 target
for the NPDB was set much too high and the 2005 target for the
HIPDB was set too low. In fact, actual 2005 performance of both
data banks continued to show healthy improvement. 2) American
Customer Satisfaction Index Results for the NPDB
|
LARGE EXTENT
|
17%
|
|
|
|
|
4.3
|
Does the program demonstrate improved efficiencies or cost
effectiveness in achieving program goals each year?
Explanation:
Over the past year, the NPDB and the HIPDB have achieved improved
efficiencies and cost effectiveness. The Data Banks are financed
by user fees paid by queriers. There are no appropriations for
either the NPDB or HIPDB. Since over 2/3 of NPDB queries and all
HIPDB queries are submitted voluntarily, the NPDB and HIPDB must
be operated efficiently in order to keep user fees affordable for
queriers. Query fees have been raised and lowered over the years
to reflect the cost of operating the Data Banks, but current
query fees are less than half of the previous highest level. In
addition, both the NPDB and the HIPDB have been able to achieve
the efficiency measure of maintaining the length of time it takes
the databanks to process a query and return results to the
querier. For both the NPDB and the HIPDB, the amount of time was
240 minutes despite an increase since 2003 of almost 10 percent
in the annual number of queries. Data Banks' Efficiency Measure
with historical data: Produce increasing amounts of output in the
same amount of time. 1991: 810,000 queries (NPDB only) (within 10
to 60 days of submission of a query) Numbers of queries (NPDB and
HIPDB) responded to within 240 minutes 2003: 4,044,000 queries
responded to within 240 minutes 2004: 4,329,000 queries responded
to within 240 minutes 2005: 4,414,000 queries responded to within
240 minutes
Evidence: By law hospitals
are required by Section 425 of the Health Care Quality
Improvement Act of 1986 (42 USC 11135) to query the NPDB on all
new applicants and once every two years on all practitioners with
medical staff privileges. All other queriers, who submit over 2/3
of the queries to the NPDB and all HIPDB queries, have no legal
requirement to query. Various enhancements throughout each Fiscal
Year enable the Data Banks to use improvements in information
technology to fulfill their goals. For example, over the past
year, the NPDB and HIPDB have achieved improved efficiencies and
cost effectiveness through (1) increasing the quality of the
report data in the system while reducing the effort incurred by
users to submit and maintain reports by eliminating duplicate
reports, improving report/query matching processes, and
implementing industry standard XML data transfer as a supplement
to the pioneering data transfer format implemented before the
industry standard XML was developed, (2) eliminating or further
reducing the already minimal use of paper in the NPDB and HIPDB's
processes, (3) adding upgraded web browser support (4) enhancing
system security to implement the results of a HRSA OIT audit and
to follow the guidance of NIST Special Publication 800-53 and the
FISMA, and (5) implementing pay.gov, a more robust credit card
transaction processing system than was previously used.
|
YES
|
25%
|
|
|
|
|
4.4
|
Does the performance of this program compare favorably to
other programs, including government, private, etc., with similar
purpose and goals?
Explanation: The
NPDB and HIPDB are the only programs collecting and disseminating
malpractice payment and adverse licensure, privileges,
membership, judgment, and other adverse action information on
practitioners, providers, and suppliers in the US. There are no
other comparable programs, including government, private or
non-profit. Information on Federal exclusion actions can be
obtained, although in a labor intensive way, from the Federal
Register and the OIG web site. For clinical privileges actions,
professional society membership actions, malpractice payments,
State exclusion actions, and adjudicated actions, information
could possibly be obtained from the entity which took the action
if the querying entity knows where to look and is willing to
spend considerable time and effort gathering the information.
This generally requires the practitioner of interest to disclose
his or her past history. The failure of some practitioners to
honestly reveal this information, of course, is a primary reason
Congress established the data banks. For some professions State
board organizations, such as the Federation of State Medical
Boards, collect and make available information on licensure
sanctions of licensed practitioners. They do this under varying
circumstances and at varying cost. The amount of information
available to licensing and credentialing authorities depends to a
large degree on individual State laws. However, this information
is limited to information on actions taken in the individual
State. The Data Banks are the only source of this information on
a national basis, which is necessary as health care providers
today often move to, and look for work in, different States. As a
practical matter there is no single alternative source to the
data banks for the information they contain.
Evidence:
American Customer Satisfaction Index Results for the HIPDB
|
NA
|
0%
|
|
|
|
|
4.5
|
Do independent evaluations of sufficient scope and quality
indicate that the program is effective and achieving
results?
Explanation: The NPDB has
regularly sponsored independent, scientific evaluations of the
programs involving national scope surveys of NPDB customers
(reporters and queriers). The most recent survey was completed in
2001 and was conducted jointly by Northwestern University
Institute for Health Services Research and Policy Studies and the
University of Illinois at Chicago Health Policy Center Survey
Research Laboratory. The independent evaluation results
demonstrate that the NPDB is effective in achieving the desired
results. Key findings were that 91.76 percent of queriers
referring to a specific sampled report they had received from the
NPDB on a practitioner found that information provided by the
NPDB in the report was useful in their licensing and/or
privileging consideration of that practitioner. For 57.41 percent
of the reports received from the NPDB, the report was considered
"useful" because it was the querier's "basic
source for malpractice payment, licensure, clinical privileges,
and exclusion information." For 9.04 percent of the reports,
the queriers "decision regarding the practitioner [would]
have been different if [the entity] had not received the NPDB
response." This represents a significant percentage given
the nature of the adverse information in the NPDB, because it
indicates that almost 1 out of 10 practitioners who otherwise
would have escaped notice of their previous bad acts or
malpractice were discovered because of NPDB reports and
subsequently were not licensed or privileged or only granted
restricted licenses or privileges explicitly because of the
NPDB's information, just as Congress intended. PDBB contracted
with the independent American Customer Satisfaction Index (ACSI)
program to conduct a standard ACSI user satisfaction survey for
the HIPDB in 2002. The ACSI survey provided useful information
and allowed the program to compare satisfaction with the HIPDB to
the NPDB and to public satisfaction with other federal and
private sector programs. It also allowed PDBB to identify major
areas on which improvement efforts should be focused. The ACSI
survey, however, is a relatively standardized, limited sample,
limited question survey. It is not designed to provide detailed
information on whether individual HIPDB matched query responses
made a difference in decision making or on how information from
specific matched query responses was used. Such detailed specific
HIPDB information will be gathered in the national user survey of
NPDB and HIPDB users which is scheduled for completion in
mid-2008.
Evidence: 2001: Assessment of
overall satisfaction with reporting and querying processes of the
National Practitioner Data Base (NPDB) - by Northwestern
University's Institute for Health Services Research and Policy
Studies and University of Illinois at Chicago's Health Policy
Center, Survey Research Lab. 2002: HIPDB American Customer
Satisfaction Index Survey (ACSIS) 2003: NPDB American Customer
Satisfaction Index Survey (ACSIS) 2006: Award of contract for
large national sample survey of NPDB and HIPDB users and
non-users. Final report expected in 2008.
|
LARGE EXTENT
|
17%
|
|
|
|
|