Data Validation

As part of the 7th Scope of Work activity, and in support of the public reporting initiatives, the Centers for Medicare & Medicaid Services (CMS) is conducting a quarterly retrospective validation of data submitted by hospitals to the QIO Clinical Warehouse.

Overview

The validation process is a chart audit performed to ensure that the data submitted to the QIO Clinical Warehouse accurately reflects the care and services recorded in the respective patients' medical records. If a hospital has transmitted a minimum of six (6) discharges to the Warehouse across any of the four clinical topics (AMI, HF, PNE, or SIP) for a discharge quarter, the hospital is eligible for validation studies. Five (5) medical records across the four topics will be selected at random for re-abstraction. CMS has contracted with AdvanceMed Corporation, the Clinical Data Abstraction Center (CDAC) for the East Coast region, to perform the re-abstraction. The CDAC will request copies of the five medical records from each eligible hospital to perform the re-abstraction and to identify any discrepancies.

Each hospital will receive a summary report of the validation results from the CDAC. HSAG’s role is to provide hospitals with assistance, feedback, and education, especially in cases in which the hospital's data did not meet the 80 percent validation threshold (i.e., where the data from the CDAC abstractions agree with the data submitted by the hospital on less than 80 percent of key data elements across the five cases). Hospitals that fall below an 80 percent validation rate will have an opportunity to appeal the CDAC finding. HSAG will work with hospitals that initiate appeals to facilitate the process. Please refer to the CMS Hospital Process Flowchart (PDF, 13K), which depicts the validation process and provides information about the timeline for each activity.

Please click on the following links (or scroll down this page) for additional information:

• Handling Record Requests
• Reviewing Validation Results
• Appeals
• Accessing Validation Reports in QualityNet Exchange (Qnet)

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HANDLING RECORD REQUESTS

General Process

AdvanceMed will send the request for the five (5) medical records for validation studies via
overnight mail to the established CDAC contact at your facility. The CDAC contact is usually, but not always, the hospital's HSAG liaison. If you are unsure about who your established contact is, you may contact Teressa Thompson at 602.665.6161 or tthompson@azqio.sdps.org, who will assist you with this information.

Included in the mailing are a cover sheet that identifies the purpose of the request, cover sheets for each of the records being requested, and shipping materials.

Here is a sample of the CDAC request (PDF, 61K) that the Medical Records Department receives. If the record is being requested for validation, the individual cover sheets will say "Validation" above the box with the barcode in the middle of the page. Also, along the bottom left side of the page is a set of patient identifiers. One of the items is titled, "SAMPREAS" (sample reason). If the record is selected for validation, the eight-digit code just to the right of SAMPREAS will contain the capital letter "V" in the last digit.

Key Points

1. Follow all instructions provided to you by the CDAC and comply with all aspects of the request.
2. Do NOT flag, highlight, or mark copies of the records being sent to the CDAC in an attempt to assist in the identification of demographic or clinical elements.
3. Include all components of the medical record that may be located in other areas, such as: supporting documentation from other departments (e.g., ED Log), electronic records, diagnostic results, patient education tools, medication administration records, etc.
4. Return copies of ALL the records within the 30-day time frame specified in the request.
5. Attach the coversheet supplied by the CDAC so that each record is identified with the associated patient identifiers.
6. Retain a copy of each record you send to the CDAC so that it is available to review along with your validation studies results should you elect to appeal the CDAC’s findings.
7. Verify that the CDAC has received ALL five of five records by running the Validation “Case Selection” report in QNet.

Information Regarding Patient Identifiers

Some records selected for validation do not contain the traditional patient identifier information in the Patient ID field, resulting in providers being unable to identify the patient when the medical record is requested by the CDAC. This is usually due to the encryption process your JCAHO ORYX PMS vendor uses to submit your discharge data to the QIO Clinical Warehouse. CMS has instructed your JCAHO ORYX PMS vendors on how to submit data to the Warehouse so that future transmissions include the appropriate patient identifiers.

In the event that you receive CDAC requests for records for which the traditional patient identifiers are not present, you should contact your JCAHO ORYX PMS vendor with the information listed on your CDAC request. Your vendor will utilize the case ID on the request to obtain the necessary identifiers for you. Please do not contact the CDAC for patient identifying information, as they will not be able to supply it to you.

Other Information

Generally, you can expect a medical records request approximately two weeks following a data submission cut-off, the date of which can be found on the Data Transmission Schedule (PDF, 118K).

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REVIEWING VALIDATION RESULTS

General Process

CMS will notify hospitals via e-mail that the validation results are available in QNet. Please refer to the section below, Accessing Validation Reports in QualityNet Exchange [This is a link to a bookmark below], for information on obtaining Hospital Validation Reports. Hospitals should run the applicable reports and review the results immediately.

A score of 80 percent or higher is considered to be passing. When this is determined and the score is posted, the associated patient-level clinical data in the Warehouse for that discharge quarter will be flagged as validated.

Hospitals that score less than 80 percent will have failed the validation study for that discharge quarter and will have an opportunity to appeal the CDAC finding. In reviewing the validation results, hospitals should use the (DRAFT) CMS Specs for Calculating Hospital Validation Results (PDF, 576K) as a reference tool for understanding the criteria used for scoring.

When you are notified that the results are available, it is imperative that you run the validation summary reports immediately in order to determine your score. This is essential, since hospitals scoring less than 80 percent that wish to initiate an appeal must do so and submit the appeal to HSAG within 10 business days.

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APPEALS

Hospitals that fall below an 80 percent validation rate will have an opportunity to appeal the CDAC finding. HSAG will work with hospitals that initiate appeals to facilitate the process. Hospitals may appeal the CDAC finding if the findings in the validation detail report are believed to be inaccurate. For example, if the CDAC reports a mismatch between hospital abstraction and CDAC re-abstraction for an element and shows the reason for the mismatch is due to missing information in the medical record, but the hospital identifies that the proper documentation is in the record and was missed by the CDAC, then the grounds for appeal are valid. However, a hospital may not appeal the CDAC finding for situations where the CDAC noted missing information in the record and the hospital did not originally submit that information. For example, if the hospital determines that the missing information was not originally submitted in the medical record, but it does exist and is documented in another area such as an electronic file, this information cannot be submitted to the CDAC for consideration in an appeal.

Instructions for Initiating an Appeal

Hospitals wishing to appeal must complete the Validation Results Appeal Form (DOC, 44K). The form should then be transferred from the hospital to Charlie Chapin and Teressa Thompson at HSAG via QNet Exchange. Please refer to the instructions on Uploading Appeal Forms for instructions on transferring your appeal form via QNet Exchange.

The appeal form must be received by HSAG within 10 working days from the date that the original results were posted in order for the appeal to be considered.

Uploading Appeal Forms

Please follow the steps outlined below to upload your completed Validation Appeal form to HSAG, via QNet:

1. Create a directory/folder on your PC or server where you want to save your Validation Appeal form and then save the completed form to the folder.
2. Access the QualityNet Exchange site at www.qnetexchange.org.
3. In the top right corner, click on "Log In" and enter your user ID and password (the fields are case sensitive).
4. Under "My Work" (left side in blue), click on "File Exchange and Search."
5. On the “Secure File Exchange and Search” page in the lower right section, click on “Upload Files Wizard.”
6. On the "Upload Wizard" screen, click on the folder labeled "Health Services Advisory Group" and click on the option "Show Users" to view all HSAG contacts.
7. To the right you will see HSAG QNet users. Click to highlight your selection of "Charlie Chapin" and then click on "Add Selected User(s).” You should then see Charlie’s name appear in the lower right section “Send File(s) To.” Repeat the process for “Teressa Thompson.”
8. Click at the blue bar at the bottom labeled ”Select, Encrypt, and Upload File(s).” You should see your browser open to your PC directory.
9. Browse to find the folder in which you saved your appeal form in step #1; click to highlight the file name and click "Open." You will receive a message, "Uploading to server, do not close browser."
10. You should then receive a message, “Upload Successful: Click OK to upload another file or Cancel to return to File Exchange." Click OK to return to the "Upload Wizard" screen.
11. The file is now uploaded.

Confirming Upload of the Appeals Form

If you would like to confirm that your file has uploaded to the appropriate individuals, use the following steps for verification:

1. On the “Secure File Exchange and Search” page, click on "Outbox" (blue tab upper right). You should see the file listed with the upload date and file name.
2. Select the file by clicking on the box and then click on the "File Tracking" icon (magnifying glass found in lower right of screen).
3. A window will open with all the details about the upload, including the names of the people the file was sent to.

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ACCESSING VALIDATION REPORTS IN QUALITYNET EXCHANGE (QNET)

Hospital Data Validation Reports are available via QNet. To access reports, you will need to access QNet at www.qnetexchange.org and login. Go to the “My Work” section and select the “Hospital Data Validation Reports” option.

This report option is accessible to, and can be run only by, those hospital users designated within the QIO Clinical Warehouse Feedback Report Role. The feedback report role was automatically assigned to all of the authorized QNet Administrators at each hospital. A QNet Administrator may then assign the feedback report role to any users at his or her hospital.

“Case Selection” displays patient-identifying information available in the QIO Clinical Warehouse pertaining to the cases selected for validation.

You will find the "Case Selection" report, which will provide you with information about the five cases selected for validation for which medical records are requested. You will also find a selection for report(s) providing the quarterly summary of validation results, once they become available.

Reports are generated and distributed to the QualityNet Exchange Report Viewer.

The user will have the option of viewing and/or downloading each report generated. The Report Viewer can be accessed through the secure Home page of QualityNet Exchange by selecting "Report Viewer" from the "My Work" section or by selecting "Report Viewer" after submitting a request for a report from the "Report Processing" page.

Detailed instructions for generating, viewing, and downloading the Hospital Validation Reports are provided in the QNet Users Guide, which is available at the secure QNet Home Page in the "My Links" section.

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