Elkridge, MD, July 19, 2021 – In a series of recent letters to State Health Officials, the Centers...
Modular Cloud Based MMIS Implementation – The Sky is the Limit
This is the first in a series of blogs in NewWave’s Thought-Leadership Series exploring the intersection of ideas and technology and government and industry to help facilitate the transformation of America’s healthcare delivery and payment systems. Our belief is that all revolutions need pragmatic technological engineering.
The Centers for Medicare & Medicaid Services (CMS) introduced the Medicaid Program in 1965 as part of Title XIX of the Social Security Act to manage the healthcare needs of individuals in the States who are underprivileged, disabled, or who have children with special healthcare needs. In order to manage the Medicaid Program, CMS provides States up to 95% of the funding required to implement a Medicaid Management Information System (MMIS), and 50% to 90% of the funding to manage the Medicaid Operations. States manage the Medicaid Program under CMS supervision and with various non-standard implementations of the Medicaid Management Information System (MMIS). Earlier implementations of MMIS were primarily mainframe-based systems which were difficult to scale and very costly to maintain. Some State MMIS infrastructures are still in this situation.
Over time, States began signing contracts with IT vendors to automate some of the program features and migrate the application from mainframe-based systems to Java or .NET-based applications. These projects can take years to complete and cost tens of millions of dollars to implement and maintain. (The Alaska, New Hampshire, and North Dakota MMIS Implementations each took more than seven years to complete and were implemented around 2015. The California and New York MMIS Implementations failed after those states spent over a one-hundred million dollars and took over five years to implement). Additionally, because information technology systems advance at such a fast rate, these systems quickly became outdated and States were left with two options: Either make the best of using a subpar, broken system – creating diminished health outcome and wasting money — or scrap the entire existing MMIS program and having to enter another lengthy and inefficient legacy technology acquisition program.
Learning the lessons of the unsuccessful launch of the MMIS program, CMS introduced Medicaid Information Technology Architecture (MITA) in 2006, strongly encouraging states to work together to create and use MMIS solutions that have shareable features. To facilitate that shareability, CMS subsequently introduced the concept of a Modular MMIS System. Instead of awarding a full MMIS contract to a single vendor, CMS encouraged States to go with a modular approach. In this approach, the MMIS system is divided into separate modules, which can be customized by individual vendors based on the individual State requirements. The goal was rather than awarding full MMIS contracts to single vendors – and spending millions of dollars and years of effort that often failed – each vendor would be accountable for an individual modules and each state’s vendors would have to follow a standard set of requirements. CMS required a “system Integrator” contractor, that would coordinate with each vendor to ensure that all modules worked as an enterprise MMIS system. This approach divides the risk among multiple vendors and improves the chances of a successful implementation.
CMS also encourages States to think about modular cloud-based MMIS implementations and to start sharing the infrastructure resources and IT applications among themselves. Some of the key examples of these intragovernmental contracts are Michigan/Illinois and Arizona and Hawaii modular MMIS implementations. In both of these examples the coordinating States use a common application with individual State user access controlled via role-based access to State controlled cloud based data warehouses to ensure data security.
Many of the commercial off-the-shelf (COTS) applications and modules that have been added in recent years still rely on legacy technologies that have grown too rigid to alter or easily integrate across multiple platforms and/or providers. Connecting disparate technologies that weren’t intended to operate with other systems remains a burdensome challenge.
In order to mitigate the risk, the states typically choose one of three paths to achieve modular MMIS interoperability:
- Using a single underlying technological platform – first defining standards and processes and then acquiring applications and services as needed over the complete lifecycle of the platform. Once a State determines which platform to use, the information gathered will provide vendors solid guidance for how to build and integrate modules to run on the platform and integrate with other systems across State agencies.
- Establishing a set of data and process standards – that must be adhered to for seamless integration and optimization across multiple platforms and modules. In this scenario, state officials provide guidelines for data and/or application programming interfaces (APIs). This guidance helps industry partners determine how best to implement modules that will meet the state’s predefined standards.
- Finding a partner to manage integration – This requires choosing the right partner to provide integration management. In this scenario, state agencies manage daily government service operations, while the integration partner manages the service and maintains service level agreements (SLAs) to ensure performance levels are met.
Today both CMS and the States have also begun to focus on implementing HL7/FHIR Standards in their modular MMIS implementation looking to ensure data and application Interoperability between various IT vendor tools and the MMIS System.
NewWave has extensive experience implementing FHIR-based framework for CMS and the Medicare program and we are ready to disrupt modular MMIS system implementations with the introduction of a custom FHIR API-based framework that we have developed for States to use in developing a modern, modular, Medicaid IT systems. This framework will standardize the data formats and data transfer methods, enabling a more robust modularity by allowing State stakeholders and vendors to focus on optimizing individual modules, rather than having to build an entire MMIS system or build work-around to shoe-horn module into their current systems.
Building on our extensive successful experience working with CMS’ Transformed Medicaid Statistical Information System (TMSIS); our work building the CMS Blue Button 2.0 API allowing 56 million Medicare beneficiaries to have access to their personal health claims data; and our leading-edge health IT engineering capabilities, NewWave is positioned to deliver the products, services and thought-leadership for the next-generation State Modular MMIS Implementation.