Horizon Healthcare Services, Inc.

Horizon Blue Cross Blue Shield of
New Jersey

Government Programs


2020 Quality Improvement
Program Description



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1. Purpose of the Quality Improvement (QI) Program ..................................................................................................................... 5

2. Program Scope ............................................................................................................................................................................... 5

3. QI Program Objectives/Goals ........................................................................................................................................................ 7

3.1 Program Evaluation ......................................................................................................................................................... 8

4. Structure of the QI Program..................................................................................................................................................... 9

4.1 Governing Body ............................................................................................................................................................... 9

4.2 Committees ..................................................................................................................................................................... 9

4.3 Inclusion of Participating Providers in the QI Program ................................................................................................ 13

4.4 GPOrganizational Chart................................................................................................................................................. 14

4.5 QI Program?s Resources ................................................................................................................................................ 14

4.6 External Quality Review ................................................................................................................................................ 19
4.6.1 Department of Medical Assistance and Health Services (DMAHS)/Island Peer Review Organization (IPRO)........ 19
4.6.2 Centers for Medicare & Medicaid Services (CMS) ................................................................................................. 20

4.7. Behavioral Health .......................................................................................................................................................... 21

5. QI Program?s Function............................................................................................................................................................ 21

5.1 Member Safety .............................................................................................................................................................. 22

5.2 Disparities in Health ...................................................................................................................................................... 22
5.2.1 Complex Health Needs........................................................................................................................................... 23

5.3 Quality Assurance.......................................................................................................................................................... 24
5.3.1 Grievances and Appeals ......................................................................................................................................... 24

5.3.1.1 Medicaid Grievances ................................................................................................................................. 24
5.3.1.2 Medicare Grievances................................................................................................................................. 25
5.3.1.3 Appeals...................................................................................................................................................... 26

5.3.2 Quality of Care and Service .................................................................................................................................... 26
5.3.2.1 Quality of Care and Service ....................................................................................................................... 28

5.3.2.1.1 Mortality Data................................................................................................................................. 28
5.3.2.2 Programs for the Elderly and Disabled...................................................................................................... 28
5.3.2.3 Population Health ..................................................................................................................................... 29

5.3.3 Audits and Reports................................................................................................................................................. 29
5.3.4 Early and Periodic Screening, Diagnostic and Treatment (EPSDT) - Lead Screening.............................................. 30

5.4 Policy Management....................................................................................................................................................... 31

5.5 Delegation Oversight..................................................................................................................................................... 32

5.6 Compliance with State and Federal Regulatory and NJ Medicaid Managed Care Contract Requirements ............... 33

5.7 Accreditation ................................................................................................................................................................. 35



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5.8 Credentialing and Re-credentialing .............................................................................................................................. 35

5.9 Clinical Practice Guidelines (CPGs)................................................................................................................................ 35

5.10 Cultural Competency and Health Literacy .................................................................................................................... 36

5.11 Fraud, Waste, and Abuse .............................................................................................................................................. 37

5.12 Program Performance ................................................................................................................................................... 37
5.12.1 QI Program Work Plan ................................................................................................................................. 38
5.12.2 Performance Improvement Projects (PIPs ) ................................................................................................. 38

5.12.2.1 Medicaid PIPs (State PIPs) ....................................................................................................................... 38
5.12.2.2 Medicare PIPs (CMS PIPs/CCIPs) ............................................................................................................. 39

5.12.3 Heal thcare Effectiveness Data and Information Set (HEDIS) ....................................................................... 39
5.12.4 Stars ............................................................................................................................................................. 40
5.12.5 Consumer Assessment of Healthcare Providers and Systems (CAHPS) ....................................................... 40
5.12.6 Heal th Outcomes Survey (HOS) ................................................................................................................... 40

5.13 New Initiatives............................................................................................................................................................... 41

5.14 Opportunities for Continued Improvement ................................................................................................................. 41




Attachments to Program Description

Attachment 1 ? 2018-2019 Medicaid Managed Long Term Services & Supports (MLTSS) Program Description

Attachment 2 ? 2019 FIDE-SNP Care Management and Quality Management Program Description

Attachment 3 ? 2019 GP Committee Organizational Chart

Attachment 4 - GP Executive Organizational Chart

Attachment 5 - Quality Management Organizational Chart


















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1. Purpose of the Quality Improvement (QI) Program
The purpose of the Horizon Blue Cross Blue Shield of New Jersey?s Government Programs (GP) QM

Program is to systematically monitor, assess, track, trend and continuously improve the quality of care,

service, health status and safety of its members. The QI Program is designed to be comprehensive and to

have the necessary resources, infrastructure, and authority to meet the program?s goals and objectives. The

program also monitors targeted accomplishments, including clinical standards to be developed, medical care

evaluations to be completed, and other key quality assurance activities to be completed, including Medicaid,

Medicare, Managed Long Term Services & Supports (MLTSS) and FIDE-SNP related quality activities.



2. Program Scope
The Government Programs? QI Program applies to all of Horizon BCBSNJ?s Government Programs lines

of business. 1 The membership served by the QI Program includes: Horizon NJ Health (Medicaid & MLTSS),

Horizon NJ TotalCare (HMO D-SNP), Medicare Supplement and Medicare Advantage HMO and PPO plans.

The scope of the QI Program encompasses the clinical and service aspects of the care its members

receive. The QI Program has oversight of GP?s efforts to monitor and improve preventive, acute, chronic,

behavioral and rehabilitative aspects of care. The QI Program also reviews the Plan?s initiatives and outcomes

related to member and provider satisfaction, member and provider education, access and availability of care,

disparities in health care, continuity and coordination of care, member appeals/grievances, quality of care

concerns, clinical and service quality metrics and the credentialing of providers. The QI Program is also

charged with effectuating changes to improve GP?s performance on Healthcare Effectiveness Data and

Information Set (HEDIS), Stars, Consumer Assessment of Healthcare Providers and Systems (CAHPS) and


1 As a result of incongruent State and Federal requirements and timelines, Horizon BCBSNJ?s Government Programs QI Program
description acts as an overarching guide while allowing individual lines of business to meet their specific contractual and regulatory
requirements through the creation of line of business specific QI programs when necessary. These line of business specific program
descriptions are reviewed and approved by the QIC. This structure allows individual lines of business (MLTSS for example) to meet their
varied filing submission dates while ensuring each line of business? QI Program information is captured within the overall Horizon
Government Programs QI Program description. See Attachment 1 for the MLTSS Program Description. See Attachment 2 for the FIDE-
SNP Care Management and Quality Management Program Description.



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Health Outcomes Survey (HOS). Accreditation efforts and audits completed by the Quality Management

Department and other GP departments are also reviewed as part of the QI Program. The following Quality

Assurance Activities are also developed and monitored on an ongoing basis:

? Guidelines for the management of selected diagnoses and basic health maintenance, and

distribution of all standards, protocols, and guidelines to all providers and upon request to

enrollees and potential enrollees.

? Treatment protocols, which allow for adjustments based on the enrollee?s medical condition,

level of functioning, and contributing family and social factors.

? Procedures for monitoring the quality and adequacy of medical and behavioral health care

including: 1) assessing use of the distributed guidelines and 2) assessing possible over-

treatment/over-utilization of services and 3) assessing possible under-treatment/under-

utilization of services.

? Evaluation of procedures for focused medical care evaluations to be employed when indicators

suggest that quality may need to be studied, including procedures for conducting problem-

oriented clinical studies of individual care.

? Procedures for prompt follow-up of reported problems and grievances involving quality of care

issues. Timeframes for prompt follow-up and resolution which follow the standard described in

Article 5.15B.

? Hospital Acquired Conditions and Provider?Preventable Conditions including the implementation

of a no payment policy and a quality monitoring program consistent with the Centers for

Medicare and Medicaid Services (CMS) that addresses Hospital Acquired Conditions and Provider-

Preventable Conditions according to federal regulations.

? Data Collection Procedures for gathering and trending data including outcome data.

? Mortality rates review of inpatient hospital mortality rates of its enrollees.

? Corrective action procedures for informing subcontractors and providers of identified deficiencies

or areas of improvement, conducting ongoing monitoring of corrective actions, and taking

appropriate follow-up actions, such as instituting progressive sanctions and appeal processes.



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? Discharge planning procedures to ensure adequate and appropriate discharge planning, including

coordination of services for enrollees with special needs.

? Ethical Issues monitoring of providers for compliance with state and federal laws and regulations

concerning ethical issues, including but not limited to, advance directives; family planning

services for minors; and other issues as identified. Reports are submitted annually or within thirty

(30) days to DMAHS with changes or updates to the policies.

? Emergency care methods to track emergency care utilization and to take follow-up action,

including individual counseling, to improve appropriate use of urgent and emergency care

settings.

? New medical technology policies and procedures for criteria which are based on scientific

evidence for the evaluation of the appropriate use of new medical technologies or new

applications of established technologies including medical procedures, drugs, devices, assistive

technology devices, and durable medical equipment.

? Informed consent, which requires that all participating providers comply with the informed

consent forms and procedures for hysterectomy and sterilization as specified in 42 C.F.R. Part

441, Sub-part F, and shall include the annual audit for such compliance in its quality assurance

reviews of participating providers.

? Continuity of care system which includes a mechanism for tracking issues over time with an

emphasis on improving health outcomes, as well as preventive services and maintenance of

function for enrollees with special needs

? Collects data and acts on opportunities to improve collaborative care between behavioral health

and medical health care for all members receiving case management services.



3. QI Program Objectives/Goals




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The GP QI Program is designed to produce prospective, concurrent, and retrospective analyses of the

Plan?s activities in order to improve the quality of care and service members receive. The specific goals of the

QI Program are to ensure that GP:

? Provides health care that is medically necessary with an emphasis on the promotion of
health in an safe, effective and efficient manner

? Assesses the appropriateness and timeliness of the care and services being provided
? Promotes members? ability to maintain themselves in the least restrictive, most integrated

setting of their choice
? Optimizes care delivery for members with special and/or complex care needs
? Identifies members? needs and coordinates care to address the needs of the member
? Focuses on the quality of medical and behavioral health care and services provided to all

members
? Works to identify and reduce health care disparities within its membership
? Strives to improve member and provider satisfaction
? Maintains oversight of delegated entities
? Maintains oversight of the credentialing and re-credentialing of providers
? Meets current National Committee for Quality Assurance (NCQA) Health Plan

Accreditation requirements
? Works to improve plan performance on HEDIS, Stars, CAHPS, HOS and Performance

Improvement Projects (PIPs)
? Monitors and ensures the appropriateness of Utilization Management decision-making

through the medical appeal process


3.1 Program Evaluation
The QI Program is evaluated annually. This evaluation is coordinated by the Quality

Management Department with input from all business areas represented on the Quality

Improvement Committee (QIC). The format of the QI Program Evaluation parallels the QI Program?s

Work Plan and includes:

? A description of completed and ongoing QI activities that address quality of clinical care
and quality of service

? Evaluation and assessment of patient safety activities
? Tracking and trending of data to assess program performance in measures of quality of

care and quality of service
? An analysis of improvements in quality of care and service to members
? A critical assessment of barriers to achieving goals and root cause analysis
? An evaluation of the overall effectiveness of the QI Program


The QI Program Evaluation is presented annually to the QIC for review, comments,

and approval. The Vice President and Chief Medical Officer of Government Programs, or a



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designee, annually presents the QI Program Evaluation to the Horizon Healthcare of New

Jersey Board of Directors.



4. Structure of the QI Program

4.1 Governing Body
Horizon Healthcare Services Inc.?s (the ?Parent?) subsidiary companies report into the Parent

organization. The Parent and its subsidiary companies have administrative service agreements with

each other wherein the subsidiaries utilize staff, policies and procedures and other items from the

Parent. The subsidiary companies that comprise the Government Programs division include Horizon

Healthcare of New Jersey, Inc. and Horizon Healthcare Services, Inc. d/b/a Horizon Blue Cross Blue

Shield of New Jersey. Horizon Healthcare Services is the contracting entity for the Medicare

Supplemental, Medicare Advantage HMO, MA PPO and Part D product lines. Horizon Healthcare of

New Jersey is the contracting entity for the FIDE-SNP HMO and Medicaid HMO product lines.

The Parent?s Board of Directors (the ?Board?) is the governing body of the Horizon BCBSNJ

enterprise, and is accountable for the GP QI Program. The Quality Committee of the board reviews

and approves the GP QI Program Description annually.

The board has assigned responsibility for the QI Program to the Executive Vice President,

Government Programs & Operations who has assigned responsibility to the Vice President and Chief

Medical Officer (VP/CMO) of Government Programs. The VP/CMO has the authority over and

responsibility for the development and implementation of the QI Program. The Government

Programs Medical Director assigned to support the Quality Management Department, who reports to

the VP/CMO, has direct oversight of the development and implementation of the QI Program. The

VP/CMO has delegated the chairmanship of the QIC to the Government Programs medical director

assigned to support the Quality Management Department. The QIC is responsible for the day-to-day

approval, monitoring and evaluation of the GP QI Program.

4.2 Committees
The organizational structure of GP committees supports the implementation of the QI

Program. Each committee has a charter that outlines the purpose, scope, meeting frequency, and



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composition. Below are descriptions of the Quality Improvement Committee and

subcommittees/workgroups that report to the QIC.

Quality Improvement Committee (QIC)

The QIC?s purpose is to oversee all GP QI activities. The QIC is a multidisciplinary committee

that meets on a regular basis, at least 6 times per year. This frequency is sufficient to demonstrate

that the committee is following up on all findings and required actions. The role, structure, and

function of the committee are specified in its charter. Annually, the charter is revised as needed and

approved by the committee. Recorded meeting minutes document the committee's activities,

findings, recommendations and actions.

The QIC is accountable to the Quality Board of Horizon BCBSNJ. Quarterly, the activities,

findings, recommendations and actions of the QIC are reported to the Quality Board. There is active

participation on the QIC from network providers. At least one participating provider attends all QIC

meetings.


? Healthcare Disparities Workgroup


The Healthcare Disparities Workgroup meets at least 6 times per year. The purpose of
this workgroup is to reduce health care disparities within its membership. The
workgroup brings together a cross-functional team that reviews data, develops and
implements interventions, conducts barrier analysis and measures the impact of
interventions put in place to decrease health care disparities.


? Physician Advisory Committee (PAC)

The PAC meets quarterly. The purpose of this committee is to identify issues of
concern to the physician community and identify opportunities for optimizing patient
care. The PAC meetings are combined with the Utilization Management/Case
Management Committee.


? Dental Committee (Special Needs and Oral Advisory)

This committee advises on and reviews issues pertinent to the delivery of oral health
care services to special needs members. This committee advises GP of changes and
advances in the treatment of oral health care issues that are unique or prevalent with
this population. The committee advises and reviews benefits and services GP provides
to its special needs members as well as new or existing policies. This may or may not
involve quality of care issues. This committee meets quarterly.



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? Delegated Vendor Oversight Committee (DVOC)

The DVOC is an interdisciplinary subcommittee that provides oversight of delegated
vendors performing services on GP?s behalf for both health care and non-health care
contracts. The committee meets at least eight times per year.


? Medicare Star Rating Subcommittee

The Medicare Star Rating Subcommittee is an interdisciplinary committee that meets
ten times per year and oversees efforts aimed to improve the quality and cost
effectiveness of the care and services GP provides to Medicare beneficiaries. The
committee coordinates GP efforts that focus on improving the plan?s Medicare Star
Rating and CAHPS scores.


? HEDIS Workgroup

The HEDIS workgroup is an interdisciplinary team that provides oversight for efforts
aimed at improving the quality and cost effectiveness of the care and services GP
provides to all members. The workgroup coordinates GP efforts focused on improving
the plan?s Medicare and Medicaid HEDIS performance. This workgroup meets six times
per year.



? Utilization Management/Case Management Committee (UM/CM)

The purpose of the UM/CM committee is to ensure high-quality, cost-effective health
care for all GP members. The committee is responsible to review the management of
Medicare and Medicaid health services to support GP?s vision of improving quality and
enhancing the member experience. The UM/CM Committee meets at least ten times
per year.


? Managed Long Term Services & Supports Committee (MLTSS)

The purpose of the MLTSS committee is to provide oversight to the Horizon NJ Health
MLTSS Quality Program. The committee reviews the program?s progress toward its
goals to systematically monitor, assess, track, trend and improve the quality of care,
service, health status and safety of MLTSS members. The committee meets at least on
a quarterly basis.


? Fully Integrated Dual Eligible Special Needs Plan Committee (FIDE-SNP)

The purpose of the FIDE-SNP committee is to provide oversight to the Horizon NJ
TotalCare (HMO D-SNP) Quality Program. The committee reviews the program?s
progress towards its goals to systematically monitor, assess, track, trend and improve
the quality of care, service, health status and safety of the FIDE-SNP members and
ensure compliance with stated program activities according to the Centers for



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Medicare & Medicaid Services? (CMS) FIDE-SNP Model of Care (MOC). The FIDE-SNP
Committee meets at least four times per year.


? MLTSS & FIDE-SNP Community Advisory Committee (MLTSS & FIDE-SNP CAC)

The MLTSS & FIDE-SNP CAC is comprised of MLTSS and FIDE-SNP leadership as well as
providers from the communities that serve GP MLTSS and FIDE-SNP membership. CAC
meetings allow GP to share information about the operations and performance of the
MLTSS and FIDE-SNP programs with community providers, while allowing them to
share their experiences related to the programs with GP. The MLTSS & FIDE-SNP CAC
meets at least four times per year.


? Administrative Policy Approval (APA) Subcommittee

The APA Subcommittee meets monthly, and the purpose of the committee is to review
and approve all GP Administrative Policies and Procedures.


? Quality Peer Review Committee (QPRC)

The goal of the QPRC is to ensure members receive quality health care and excellent service.
QPRC meets at least six times per year - and on an ad hoc basis - to review potential quality of
care and service issues involving GP members.

? Member Services Satisfaction Committee (MSSC)

The MSSC is a multidisciplinary committee, focusing on issues related to member satisfaction in
order to create proactive action plans to address the identified barriers to providing GP members
with the highest quality experience. The MSSC reviews reports focused on call center
performance, member grievances, and claims as well as appeals associated with these issues. The
MSSC reviews CAHPS results and other member satisfaction survey results so that the committee
can coordinate interventions aimed at improving member experience. The committee also
determines areas of service with the greatest effect on member satisfaction, and identifies areas
of opportunity to increase quality of care through quality initiatives. This committee meets at
least quarterly.

? Community Health Advisory Committee (CHAC)

The purpose of the CHAC is to provide a vehicle for community review and advice on matters
related to health care education, outreach, and promotion affecting GP members. Meetings are
held in both English and Spanish. The CHAC meets quarterly.

? Provider Service Satisfaction Committee (PSSC)



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The purpose of the PSSC is to oversee and ensure provider satisfaction with GP. The PSSC
committee reviews grievance and appeal data and specific issues related to provider satisfaction.
The committee meets on a quarterly basis.

? Credentials Committee

The Credentials Committee is a committee within the Horizon BCBSNJ Quality Improvement
Committee (QIC), established to implement and oversee credentialing, re-credentialing,
certification, and/or re-certification of physicians, health care professionals, facilities and ancillary
providers. The Credentials Committee is empowered by Horizon Healthcare Service?s, Board of
Directors and the Horizon Healthcare of New Jersey Board of Directors, the management of GP
and the QIC with decision-making authority on matters pertaining to provider credentialing and
re-credentialing. This committee meets at least 10 times per year.

? Pharmacy and Therapeutics (P&T) Committee (Medicaid)

The Medicaid P&T Committee is responsible for clinical support of the Horizon NJ Health Medicaid
Pharmacy Program. The P&T Committee is comprised of primary care and specialty physicians,
pharmacists and other health care professionals. The Medicaid P&T Committee provides input on
pharmaceutical management procedures and on developing, managing, updating and
administering the Drug Formulary System. The Medicaid P&T Committee meets at least quarterly.

? Pharmacy and Therapeutics (P&T) Committee (Medicare)

The Medicare P&T Committee is responsible for clinical support of the Horizon BCBSNJ Medicare
Pharmacy Program, including FIDE-SNP. The P&T Committee is comprised of primary care and
specialty physicians, pharmacists and other health care professionals. The Medicare P&T
Committee provides input on pharmaceutical management procedures and on developing,
managing, updating and administering the Medicare Formulary. The Medicare Formulary
development and maintenance is delegated to the Pharmacy Benefit Manager, Prime
Therapeutics, and is overseen by the Prime P&T Committee with active participation by the
Horizon BCBSNJ Medicare Pharmacy Program. The Medicare P&T Committee meets at least
quarterly.

4.3 Inclusion of Participating Providers in the QI Program
Horizon BCBSNJ providers are included as voting members of the QIC. Participating providers

are also voting members of GP Utilization Management/Case Management Committee, Physician

Advisory Committee, Pharmacy and Therapeutics Committees, Dental Advisory Committee and

Quality Peer Review Committee. Participating physicians and other providers are kept informed about

the written QI Program Description available in provider newsletters and on the plan?s website at

horizonNJhealth.com/for-providers. Providers can also access information in the Provider



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Administrative Manual about how they can be included in the design, implementation, review and

follow up of GP QI activities.

4.4 GP Organizational Chart
See Attachment 3 2019 GP Committee Organization Chart, Attachment 4 for the GP Executive

Organizational Chart and Attachment 5 for the Quality Management Department?s Organizational

Chart. Due to the expansion of the Quality Management Department, the Quality Management

Clinical Operations Organizational Chart, the Quality Management Performance Improvement and

Reporting and the Quality Management and Administration Organizational Chart are reported

separately. In October 2019, the Commercial Quality team members merged with the GP Quality

Management Operations Division. In doing so, the teams can share best practices and also leverage

resources that will yield positive outcomes for Horizon BCBSNJ members.

4.5 QI Program?s Resources
The GP QI Program has the full support of GP?s executive leadership. To demonstrate this

support, leadership approved an expansion in staffing and a reorganization of the Quality

Management Department, which occurred in 2019. In addition to the support provided by GP

executive leadership, all departments within the division contribute to the success of the QI Program

through their focus on quality in their daily activities and their participation in the QIC.

With the expansion and reorganization of the Quality Management Department, continuing

into 2020, and the existing GP health services structure, the QI Program will have sufficient material

resources and staff with the necessary education, experience and/or training to effectively carry out

the QI Program?s activities. In addition, the Quality Management Department has access to

consultants who provide activities such as statistical analysis, business process improvement

recommendations, quality related education and accreditation preparation support. To maintain and

improve quality performance, Horizon BCBSNJ monitors all current and planned initiatives to assess

current and future staffing needs. This opportunity ensures that the appropriate staff is in place to

adequately address the needs of the quality improvement efforts. Below are descriptions of the key

roles within GP that support the QI Program.

QI Programs Staffing:

Vice President and Chief Medical Officer (VP/CMO)



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The VP/CMO of GP is a board-certified New Jersey licensed physician with a master?s degree

in public health, experienced in health insurance, health care consulting, NCQA accreditation and

pharmaceutics. The VP/CMO is responsible for the design and implementation of the QI Program.

The VP/CMO provides quarterly reports to the Quality Subcommittee of the Horizon Healthcare of

New Jersey Board of Directors, which details the quality-related activities of GP and the QIC. This

reporting may be delegated to the medical director of the Quality Management Department.

Executive Medical Directors

The executive medical directors provide senior level leadership and direction, and contribute

to Quality Management initiatives, including Accreditation and CMS Star programs, as well as

furnishing strategic and UM oversight of GP lines of business. The executive medical directors

establish and implement utilization standards, provide overall medical expertise to ensure continuous

quality improvement, work to ensure that cost-effective services are provided to members, maintain

effective provider relations and develop clinical innovations.

Senior Medical Directors/Medical Directors/Dental Director

The Senior Medical Directors, Medical Directors and Dental Director provide support to the

QI Program and the Quality Management Department. They are involved in the evaluation of the

clinical and service functions of GP including, but not limited to, clinical practice guidelines,

grievances, and quality of care referrals, HEDIS/Stars/CAHPS/HOS initiatives and corrective action

plans (CAP).

Quality Management Coordinator

The Quality Management Coordinator is a board-certified New Jersey licensed physician who

has a master?s degree in public health. The coordinator has experience in UM, Quality Management,

managed care operations, MLTSS, Medicare and Fully Integrated Dual Eligible Special Needs

Programs. The QM coordinator reports to the GP VP/CMO and is responsible for the creation and

execution of the QI Program Description, work plan, and annual evaluation, as well as all the

functions carried out by the Quality Management Department. The QM Coordinator or designee

chairs the QIC and is a voting member of select QIC subcommittees. The QM Coordinator?s

representation and voting rights on QIC subcommittees may be delegated to medical directors within

GP or a director within the Quality Management Department.



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Director, Quality Management Performance Improvement and Reporting

The Director of the Quality Management Department reports to the executive medical

director of the Quality Management Department. The Director has experience leading HEDIS and Star

Rating initiatives for large health plans as well as coordinating quality transformation efforts within

institutions and provider groups. The Director is responsible for assisting in the planning and direction

of the QI Program and Quality Management Department functions. The Director is also responsible

for the oversight and function of the business areas within the Quality Management Department

including Star Rating/HEDIS/CAHPS/HOS, pay for performance and population health. The Director

develops departmental reports and presents these reports, along with the medical director, to the GP

leadership team directly and through the committee reporting structure. The Director represents the

Quality Management Department on GP committees and may serve as the Quality Management

Medical Director?s designee when the Medical Director is not present.

Director Quality Management Clinical Operations

The Director of Quality Management Clinical Operations reports to the Medical Director of

the Quality Management Department. The Director is a licensed professional registered nurse and

has experience in health plan management for UM, CM and appeals. The Director is responsible for

assisting in the planning and direction of the QI Program and Quality Department functions specific to

clinical operations. The Director is also responsible for the oversight and function of the business

areas within the Quality Management Department including medical UM appeals audits, and quality

of care referrals and quality of care. The Director develops departmental reports and presents these

reports, along with the Medical Director, to the GP leadership team directly and through the

committee reporting structure. The Director represents the Quality Management Department on GP

committees and may serve as the Quality Management medical director?s designee when the medical

director is not present.

Director Quality Management Improvement Operations

The Director of the Quality Management Improvement Operations Department reports to

the Executive Medical Director of the Quality Management Department. The Director has

experience in Continuous Quality Improvement (CQI) methodology, state contractual requirements,

and NCQA, DMAHS and CMS quality standards. The Director has a master?s degree in business



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administration, with concentrations in management information systems and risk management. The

Director is responsible for design, development, and implementation of on-going improvement and

maintenance of quality improvement initiatives necessary for attaining NCQA accreditation, and

meeting CMS and DMAHS contractual requirements. The Director provides leadership for

implementing, monitoring and evaluating the Quality Improvement Program for GP. The Director

also leads and directs processes and overall quality improvement activities that produce better

patient care and more efficient operations. They also develop programs to review and evaluate

patient care and outcomes. The Director represents the Quality Management Department on GP

committees and may serve as the Quality Management Medical Director?s co-chair.

Director Clinical Behavioral Health Services

The Director of Clinical Behavioral Health Services reports directly to the Vice President of

Behavioral Health. The Director has a doctoral degree in social work and is a licensed clinical social

worker. The Director is responsible for GP?s transition from delegated behavioral health services to

internal management of services and benefits beginning January 1, 2020. The Director monitors the

effectiveness of behavioral health care services including utilization management, Medicare Case

Management and all Quality Management activities related to behavioral health. Internal

management of behavioral health services allows GP to be in a stronger position to work directly

with providers and health systems to improve integration of physical and behavioral health care for

our members.

Quality Management Department Managers

Quality Management Department managers report to the Director or Medical Director of the

Quality Management Department. GP Quality managers are comprised of nurses, social workers and

non-clinicians with backgrounds in quality assurance, compliance, analytics and State Health

Department operations. Managers are responsible for routine operations within their scope of

accountability. Managers have specific business areas within the Quality Management Department

that they oversee including member and provider grievances and appeals quality peer review, audits,

HEDIS/Star Rating performance, quality policy revisions, accreditation, quality assurance and quality

related compliance.

Quality Management Department Supervisors



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Supervisors within the Quality Management Department report to Managers or Directors. GP

Quality Management Department supervisors include both clinicians (RNs and LPNs) and non-

clinicians. The Supervisors are responsible for ensuring that the Quality Management Department?s

staff completes daily operations as outlined within policies and procedures.

Quality Management Department Subject Matter Experts, examples include but are not limited to;

Accreditation Specialists

The accreditation specialists support the Quality Management Department?s goal of

improving the quality of health care for its members through ongoing monitoring of compliance with

accreditation standards and regulatory requirements. The specialists work with all business areas, as

well as with delegated vendors, to ensure that their work and reporting supports all applicable NCQA

Health Plan Accreditation Standards.

PIP Specialists

There is a dedicated team responsible for assisting in the design, implementation, execution,

analysis, and reporting of State and CMS required PIPs. They lead the Quality Management

Department, as well as other GP departments and external collaborators, in the work required to

successfully achieve the goals of each of QI project.

Health Data Analysts

Health data analysts perform research, analysis, programming, implementation and

coordination to ensure accurate and timely reporting for the Quality Management Department. The

responsibilities include, but are not limited to, analyze reporting, development of databases and

reports that are responsive to department needs, review and coordinate all data requests to ensure

data consistency and accuracy, utilize various software packages to extract and analyze data, provide

support and education to all Health Services departments on data requirements and needs for quality

activities.

Quality Outreach Specialists

Quality Outreach Specialists are responsible for the coordination, implementation and

monitoring of all Medicaid and Medicare (Star Rating) HEDIS member and provider outreach,

engagement and intervention. This position is also responsible for assisting the manager of Outreach



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& Interventions in operationalizing all initiatives to improve HEDIS performance by working with

internal and external stakeholders.

Additionally, the QI program pursues an integrated approach to achieving ongoing

improvements in the quality of care and service delivered to members. Staff in the Quality

Department work closely with the following departments:

Provider Contracting & Strategy (PC&S) works with Quality Management to ensure that the

tools to assess the access and availability of practitioners and providers are adequate, that

practitioners/providers comply with the QI program, that clinical materials distributed to

practitioners are understandable and useful, and that practitioners understand members rights and

responsibilities and treat enrolled members accordingly.

Clinical Services Operations includes Care, Case and Disease Management and UM. Care,

Case Disease Management staff identifies and refers potential quality issues to the Quality

Management Department for investigation, recommends benefit enhancement, approves clinical

practice guidelines and participates in the QIC.

Delegate Vendor Oversight (DVO) and Quality Management staff work collaboratively in the

review of Quality Management initiatives with delegates and ensures compliance with the NCQA

standards. In addition, DVO provides oversight of the activities and responsibilities of delegated

vendors to ensure quality health care is provided to members.

4.6 External Quality Review

4.6.1 Department of Medical Assistance and Health Services (DMAHS)
and the Island Peer Review Organization (IPRO)

On behalf of the New Jersey DMAHS, IPRO conducts oversight activities of Horizon NJ

Health and Horizon TotalCare (HMO D-SNP). Annually, IPRO conducts an assessment of

Horizon BCBSNJ operations to determine if Horizon BCBSNJ has implemented and

operationalized State-mandated contractual requirements. The Quality Management

Department is responsible for Horizon BCBSNJ?s preparation, the submission of

documentation and the coordination of the onsite assessment. After the annual assessment

is completed and Horizon BCBSNJ receives feedback from DMAHS/IPRO, corrective action



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plans are created and executed to address the opportunities for improvement that were

highlighted in IPRO?s report. These corrective actions are monitored by the QIC through their

completion.

Additionally, as a follow up to the annual assessment, the plan receives a Quality

Technical Report (QTR) each year from IPRO that aggregates and analyzes relevant data to

draw conclusions on quality, timeliness and access to Medicaid managed care services. IPRO

is required to make improvement recommendations as a part of its external quality review

activities and then discuss how the managed care organization addressed those

recommendations in the next annual QTR.

DMAHS/IPRO also has oversight of additional Horizon BCBSNJ activities including

focused studies, audits to evaluate the quality of care received by the publicly insured

enrolled in managed care, HEDIS performance, CAHPS performance and evaluation of

Horizon BCBSNJ?s Performance Improvement Projects (PIPS).

In addition to the external quality reviews performed by the State, GP undergoes

quality reviews/audits performed by CMS and NCQA. Horizon BCBSNJ ensures CMS required

QIPs and CIPS are approved by CMS. Horizon BCBSNJ maintains compliance with NCQA Health

Plan Accreditation standards and the plan?s Medicaid and Medicare lines of business are

assessed by NCQA as part of the health plan accreditation process.

4.6.2 Centers for Medicare & Medicaid Services (CMS)
CMS evaluates Organizational Determinations, Appeals and Grievances (ODAG)

annually in two specific reviews. Those reviews are entitled ?Timeliness Review? and ?Part C

and Part D Data Validation Audit.? The former looks at specific period in the previous year and

the later looks at the entire previous year. The focus is to evaluate timeliness of performing

ODAG functions. These results are compared against all other Medicare Advantage Plans to

identify health plans that are considered ?outliers.? The health plans determined to be

?outliers? would be subject to adverse action on behalf of CMS.

Additionally, CMS performs a full-program audit every four years. This full-program

audit evaluates ODAG function including ?clinical decision making.? Program Audit Results are



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compared against other Medicare Advantage health plans. All Medicare Advantage health

plans that are below the top 25 percent are subject to adverse action on behalf of CMS.

Monthly monitoring of these functions, combined with workflows that include

regulations, support a state of readiness for the above outlined audits.

4.7. Behavioral Health
The Behavioral Health Program is committed to providing quality services to help members

manage all aspects of their health. Effective January 1, 2020, GP transitioned from delegation of

behavioral health services from Beacon Health Options to fully integrating services into current GP

programs. Behavioral Health Case Management services are available to the Medicare membership

and a specific subgroup of the Medicaid membership. The benefits provided through Medicaid are

limited to the enrollees in the Division of Developmental Disabilities (DDD), MLTSS and FIDE-SNP

programs. Case managers provide assessment, development and implementation of individualized

plans of care; and offer coordination of medical and behavioral health care services for members and

their families. The Behavioral Health Program utilizes the Care Radius medical management system to

support delivery and documentation of the case management process.

The Director of Behavioral Health Services reports into QIC and a behavioral health

practitioner participates on the QIC, UM/CM, P&T and FIDE-SNP Committees to provide information

and guidance on mental health/substance use disorder topics and related quality initiatives and

activities. Additionally, the Provider Contracting & Strategy and Network Operations Departments

review geographical access reports that address the adequacy of the behavioral health provider

network. Deficiencies are acted on to reduce barriers to access and ensure continuity of care for

members.



5. QI Program?s Function
The function of the QI Program is to coordinate, oversee, guide, and assess GP efforts to ensure

that continuous quality improvement is being pursued throughout the organization. The following

sections highlight the functions of the QI Program. In addition to focusing on these functions, the GP QI

Program has the ability, through the QIC, to add additional areas on which to focus its attention.



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Each year the QI Program Description is reviewed and revised as necessary. Annually, a QI Work

Plan is developed and implemented to guide the execution of the QI Program. At the conclusion of each

year, a QI Program Evaluation is completed to assess the success of the QI Program and guide the

creation of the following year?s QI Program Description and Work Plan looking at those areas where goals

were not met and will continue to be monitored into the next calendar year. The work plan is monitored,

reviewed and updated on a quarterly basis and new initiatives are added as needed.

5.1 Member Safety
Promoting safety for its membership is a key focus for Horizon BCBSNJ and involves a wide

range of activities. The QI Program, as well as the Quality Management Department, are central

contributors and coordinate the member safety initiatives performed throughout the organization.

To promote safety for hospitalized members and in accordance with the CMS guidelines,

state law, and the State Medicaid Managed Care Contract, GP has policies to address quality of care

and service, hospital acquired conditions and serious adverse events. The Quality Management

Department reviews the State Medicaid Managed Care contract, CMS regulations, applicable state

laws, national clinical practice and other guidelines at least annually. Policies are reviewed and

approved every year including the list of selected hospital-acquired conditions and serious adverse

events.

Additional activities occurring within the Quality Management Department and QIC that

focus on enhancing member safety include: assisting in the reporting of quality indicators to the

provider network, monitoring and follow up on corrective action plans required from delegated

vendors and/or network providers who identified care and/or service deficiencies, conducting quality

of care reviews focused on member safety issues, designing quality improvement projects targeted at

at-risk populations, researching grievances related to member safety issues, analyzing under and

over utilization data, and when appropriate, coordinating GP response to potential urgent/immediate

member safety threats.

5.2 Disparities in Health
Disparities in health reduce the overall quality of care provided within the health care system

while adding to overall health care costs. In 2020, to address the multiplicity of the needs of the

membership, the QI Program will continue to work on identifying and addressing disparities in health



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outcomes among different member populations. GP programs to reduce disparities in health will be

driven by discussions held during Disparities Workgroup and QIC meetings, as well as

recommendations made by the QIC. The interventions selected to reduce health care disparities in

clinical and service areas will be instituted during 2020 and will be included on the 2020 QI Work Plan.

Current topics under review include breast cancer screening (BCS), cervical cancer screening (CCS),

depression in the elderly FIDE-SNP population, colorectal cancer screening (COL), prostate cancer

screening, social determinants of health and childhood obesity. Horizon BCBSNJ?s ongoing efforts to

reduce disparities will be coordinated and monitored through the QIC.

The goal of this program is the implementation of interventions and community health events,

which reduce disparities between differing member populations. New interventions for social

determinants of health and childhood obesity will launch in 2020. Ongoing interventions from 2018 for

depression in the elderly FIDE-SNP population BCS, CCS, COL and prostate cancer screening will

continue through 2020.

5.2.1 Complex Health Needs
The QI program is dedicated to addressing the needs of members with complex

health issues. The Complex Case Management Program resides within the Medicaid Case

Management and Medicare Advantage (MA) Care Management teams (product line specific)

and integrates all components of case management and coordination to support access to

care for members with complex diseases (including transplantation, HIV/AIDS, oncology and

behavioral health) and chronic conditions. Members are identified and referred for Complex

Case Management using a variety of methods, such as data provided from

utilization/concurrent review, predictive modeling tools, physician or member referrals and

health information lines. The assigned case manager coordinates care with members, their

families, and providers as appropriate to assist in assessment, development and

implementation of individualized plans of care to meet the identified needs of the member

across multiple settings. Case Management and Medicare Advantage Care Management

utilize the Care Radius medical management system to support both the delivery and

documentation of the case management process.

Additionally, the Provider Contracting & Strategy and Network Operations

Departments review geographical access reports to address the adequacy of the provider



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network. Reporting indicates sufficiency of PCP, Ob/Gyn, and high volume and high impact

specialties required to treat the membership. Deficiencies in the network are acted upon to

reduce barriers to care and to ensure continuity of care for members.

5.3 Quality Assurance

5.3.1 Grievances and Appeals

5.3.1.1 Medicaid Grievances
Horizon BCBSNJ is committed to improving the efficiency and quality of how

the Plan manages appeals and grievances. In 2019, all grievance analysts were

provided with additional training to ensure grievances were handled timely and

efficiently, and will continue to be monitored in 2020 to initiate additional trainings

where needed. The training included review of the process for identifying quality of

care issues and making outbound calls to providers. In addition, 100 percent of all

grievances receive a quality review prior to closure. This added step ensures that

member and provider grievances are addressed appropriately.

The GP grievance resolution teams address member and provider grievances

within the mandated timeframes required by the NJ State Medicaid Contract, CMS

Health Maintenance Organization (HMO) regulations, and in accordance with

standards set forth by an applicable accrediting body of NCQA. The staff receives

grievances through telephone calls coming into the member/provider services areas,

State referrals, CMS referrals, internal and external direct calls, written

correspondence, GP websites and the electronic internal complaint form. The

internal processes provide the opportunity for all employees within the organization

to document any grievance that was received during an interaction with a member

and/or provider. The grievance staff is the liaison between the member/provider,

Horizon BCBSNJ, and the delegate or vendor for grievances related to any delegate or

vendor. As necessary, the team participates in monthly meetings with delegates and

vendors to ensure grievances are processed within compliance contractual

agreements and service level agreements and also discuss any issues that may arise.



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Grievance data is analyzed monthly and submitted to the appropriate

committees for review and discussion. At least quarterly, member, provider and

delegated vendor grievance data is presented to the QIC. After presentation at the

QIC, the information is presented at the Quality Committee of the Horizon Healthcare

of New Jersey Board for review and discussion. As required by the NJ State Medicaid

Managed Care Contract and CMS regulations, grievance reports are prepared and

submitted to the state and CMS.

The Horizon NJ Health appeals staff handles all member and provider

Utilization Management appeals in accordance with the NJ State Medicaid Managed

Care contract requirements, applicable CMS regulations, and accreditation standards.

Please note that grievances may also be referenced as complaints.

5.3.1.2 Medicare Grievances
CMS provides stringent guidelines related to the intake and resolution of

grievances received by Medicare enrollees. In order to meet the requirements, a

dedicated grievances team exists within the organization to resolve grievances. The

focus of the team is to review and resolve grievances regardless of where they

originate within the organization. The grievances staff receives referrals by telephone

calls, written correspondence, internal referrals or legislative referrals. Grievances

received by 1-800-Medicare are also handled within the grievances team.

All grievances are reviewed in detail to identify the root cause of the issue.

There is continuous collaboration within various departments within the organization

to review and resolve grievances. All grievances are handled within the CMS

designated timeframe and follow all CMS guidelines as outlined in the Managed Care

Manual Chapter 13; Medicare Managed Care Beneficiary Grievances, Organization

Determinations, and Appeals Applicable to Medicare Advantage Plans, Cost Plans,

and Health Care Prepayment Plans (HCPPs), collectively referred to as Medicare

Health Plans. The staff member serves as a liaison between the member/provider,

delegated vendors, and regulatory bodies, and follows the grievance until

completion. Grievance inventory is monitored on a daily basis in order to ensure

grievances are acknowledged and resolved in a timely manner. The overall outcomes



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are reviewed on a monthly basis in order to identify trends and any corrective action

is identified on a case-by-case basis. Quarterly grievance reports are presented to the

appropriate committees for review. Please note that grievances may also be

referenced as complaints.

5.3.1.3 Appeals
The Quality Management Department has a team dedicated to processing

appeals across all GP lines of business. The Appeals Department is comprised of non-

clinicians, registered nurses, medical directors and a leadership team focused on

ensuring compliance with NCQA standards and state /federal regulations. External

MD specialty match consultants are used when appropriate to provide expertise to

the input of a medical necessity review. This ensures member and provider appeals

are managed in accordance with nationally recognized criteria to render

determinations based on medical necessity.

The quality improvement initiatives continue in the Appeals Department with

ongoing education and monitoring for effective administration of medical necessity

appeals. Leadership and staff have been structured to create subject matter experts

to support the Medicaid, Medicare and FIDE-SNP lines of business. There continues to

be a refocus on data driven outcomes via diversified reporting through the business

analyst?s support. The result is tracking, trending and identifying opportunities for

improvements in production. Operationally, monitoring tools such as the appeals

dashboard helps create and modify department policies/procedures and workflows

to support compliance with CMS and State contractual timeframes.

5.3.2 Quality of Care and Service
Within the Quality Management Department, a team exists which is focused on

quality of care issues. This team provides ongoing education to GP personnel regarding

potential quality of care concerns and serious adverse events. This education includes the

definitions/categories for quality-of-care referrals with direction on how staff can refer

potential quality of care issues to the Quality Management Department for investigation, and

to the medical director for review. All instances where a quality-of-care issue and/or serious

adverse events, hospital acquired, or provider preventable event may exist are presented to



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the Quality Peer Review Committee (QPRC) for discussion, determination of departure from

quality standards and guidelines, and possible practitioner sanctioning.

QPRC sanction determinations are forwarded to the Credentialing Committee for

inclusion in the provider's credentialing file. Quality-of-care referrals as well as provider

sanctions are tracked and trended by the QPRC. Entities that receive sanctions may be

monitored by the PC&S team through telephonic and medical record audits, as well as onsite

visits. When the QPRC issues sanctions against providers, the QPRC may require the provider

to create and implement corrective action plans (CAPs). These CAPs are reviewed by the

QPRC for completeness. The QPRC reports quality-of-care concerns (QOC), hospital-acquired

conditions (HAC) and serious adverse events (SAE) to the QIC.

The Quality Management Clinical Operations RN staff provides quarterly education

sessions regarding quality of care referral categories. These information sessions are

conducted in office and via WebEx (to accommodate staffs who work from home). In addition

to structured reviews of the criteria, the Quality Management staff provides support to all

referring staff to ensure that referrals and grievances are created correctly.

Quality of Care Referrals are captured by a Tableau quality report that was developed

in 2017. The Tableau report is a comprehensive report of quality of care referrals and

grievances. This report is updated daily, and follows all lines of Government Programs

business. Information obtained from Tableau is used for monthly monitoring of total cases

referred, closed, and outstanding.

Readmission monitoring for quality-of-care indicators are reviewed prior to

proceeding with the UM appeal process. Working with the Medical Directors, cases are

reviewed and quality-of-care indicators are validated. If no quality-of-care indicators are

identified, the UM appeal process will commence.

Monthly data is reviewed for trends and outliers. In the event a quality of care

indicator persists, referrals are made to Horizon NJ Health?s Provider Contracting & Strategy

(PC&S) team. PC&S reports the results of its investigation to the Provider and Member

Services Satisfaction Committees, which report into the QIC.



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The QI Program is designed to maintain and enhance high quality of care and service

in an era of high expectations from our members and providers.

5.3.2.1 Quality of Care and Service
The Clinical Quality Operations team has the ability to monitor and track quality of

care grievances and quality-of-care referrals for all lines of business including MLTSS

and FIDE-SNP. Data regarding these lines of business is reported to the Government

Programs QIC committee. In addition, tracking of cases for members defined as aged,

blind and disabled (ABD), Division of Developmental Disabilities (DDD) and elderly are

reported to the QPRC committee. Potential quality of service issues identified for

MLTSS, FIDE-SNP, ABD, DDD, and elderly during the investigation of a quality of care

issue will be referred to the appropriate area for review and investigation.

5.3.2.1.1 Mortality Data

Another function of the Quality Management Department is the

tracking of mortality data for Medicaid, FIDE-SNP and MLTSS members. The

mortality data is also stratified by special populations as defined by the New

Jersey Medicaid HMO contract. These categories include aged, blind, disabled

(ABD), Division of Developmental Disabilities (DDD) and elderly members. On

an annual basis, the analysis is presented to the QPRC committee for review

and approval.

5.3.2.2 Programs for the Elderly and Disabled
Horizon BCBSNJ continues to focus on the care of all members. In doing so,

Horizon BCBSNJ has segmented the population to address the needs of the most

critical members, which include a focus on elderly members aged 65 years and older

and members with disabilities. The elderly and disabled population is managed by

various programs including Care, Case and Disease Management and Quality

Management Programs. They are designed to outreach, engage and educate both

members and providers on the importance of preventive visits and communication to

providers on outcomes of care.



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For elderly and disabled enrollees, GP monitors, evaluates and reports on

member outcomes at least annually. GP tracks and reports on each population

separately. Horizon BCBSNJ?s program includes functional standards to evaluate

outcomes of care; as well as measurement and distribution of outcome reports to

providers. The program includes a process for communicating measurement

standards to providers and evidence that the process is implemented.

The results are included in the QI Program Evaluation. GP includes quality

indicators of potential adverse outcomes and provides appropriate education,

outreach, case management and other activities as outlined in the Medicaid Contract.

5.3.2.3 Population Health
GP manages Medicaid and Medicare members through multiple programs to

increase member satisfaction, improve health outcomes and reduce cost, known as

the Triple Aim. GP utilizes a data-driven approach to population health management

of its member population. This approach includes stratifying the population into four

quadrants (Healthy, Rising Risk, Complex Care and Safety and Outcomes). In addition,

the population is also segmented by location (zip code, city or county), age and

gender.

The objectives of the GP Population Health Management Program are to

improve the overall health and wellness of the population through programs that

encourage preventive health services, health and disease maintenance programs and

appropriate utilization of practitioner and other provider services. Through

population analysis, interventions are designed to meet the needs of the target

population, as well as have an understanding of their needs and barriers. The

Population Health Program is available to all active enrolled members, with the

option to opt out via a telephone call, at which time they are placed on a do not

contact list.

5.3.3 Audits and Reports
The QI Program has oversight of audits and reports completed by multiple business

areas. There are several reasons that audits and reports are performed. Audits and reports



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are required by the State, necessary to meet accreditation requirements, and they provide

GP with insights as to how processes, providers and systems are performing. A selection of

the audits and reports that are performed and then reviewed by the QIC is listed below:

? MLTSS Quarterly Audit
? FIDE-SNP Audits
? Geo Access Reports
? 24-hour Access Audit
? Medical Record Review Audit
? Appointment Availability Audit
? Office Manager Satisfaction Survey
? Behavioral Health Clinical and Quality Performance Measures
? EPSDT Audit
? Lead Report
? Vendor Oversight Audit


These audits are incorporated into the QI Program Work Plan. As part of the QI

program, the QIC uses the work plan to track the completion of these audits. The QIC

provides the business area completing each audit/report with recommendations about

how it can be modified to improve its usefulness.

5.3.4 Early and Periodic Screening, Diagnostic and Treatment (EPSDT)
- Lead Screening

Lead screening using blood lead level determination must be done for every Medicaid-

eligible and NJ FamilyCare child between nine (9) months and eighteen (18) months of ages,

preferably at twelve (12) months of age and a second time between 18-26 months, preferably

at twenty-four (24) months of age. Testing should be done on any children between twenty-

seven (27) to seventy-two (72) months of age not previously tested. GP provides a screening

program for the presence of lead toxicity in children, which consists of two components; a

verbal risk assessment and blood lead testing. The verbal risk assessment is given to providers

to perform at every periodic visit between the ages of six (6) months and seventy-two (72)

months. Monthly data reports are reviewed for the 9-18 month and 18-26 month age groups.

Those between 27-72 months that have not previously been tested are also included on this

report. Those members that have been tested and have an abnormal rate above 5 ug/dl are

handled by the Case Management Department for management and follow up. Additionally,



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the health plan has various lead monitoring methods and interventions in place to increase

lead screening rates plan-wide. Primary and secondary prevention methodologies have been

adopted to ensure lead screening takes place earlier, rather than later, in the applicable age

groups. These interventions include, but are not limited to, member mailings, provider

mailings, call campaigns, provider onsite education, provider webinars, member gap-detail

analysis and community events.

In 2020, GP will continue to monitor initiatives to increase lead screening awareness

and lead testing. In addition to our interventions targeted towards all of our members and

providers, we have interventions specific to our hard-to-reach members who appear on the

annual member work plan. There are also specific interventions in place and developed each

year specific to providers falling under 80% lead testing compliance for two-consecutive, six

month periods. Those providers who are on this ?under compliance? list are monitored

throughout the year and reported to the Quality Peer Review Committee in the case that they

are unable to increase their rate to 80% or higher. Providers that are placed on a CAP are

notified in April following the measurement year (i.e. letters are sent out in April 2020 for

providers under 80% for two consecutive, six month periods in 2019) via letter and fax. They

are advised that they have been placed on a CAP and their lead screening performance will be

monitored throughout the year (i.e. 2020 for 2019 non-compliance). In August of the following

year (August 2020 for 2019 non-compliance), providers who are still under 80% compliance

are notified via fax as a reminder that they have until year-end to increase their lead screening

rates. If their lead screening compliance is still below 80% by year-end, they are referred to

QPRC to determine further corrective action.

While provider compliance is key and monitored closely, there are a number of

interventions underway that support providers to increase their lead testing rates. These

efforts are proactive and ongoing throughout the year to maintain compliant rates and also to

improve low rates.

5.4 Policy Management
Annual policy review is conducted and presented to the QIC or the applicable subcommittee or

workgroup of the QIC, by the department responsible for each policy. All policies are reviewed to

comply with the Corporate Policy and Procedure Development Policy and include the effective date,



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most recent revision and most recent review dates. In addition, policies are reviewed for applicable

regulatory and accreditation content.

All GP policies are maintained on a SharePoint site. The site allows staff access to all current GP

policies. Monitoring of state compliance requirements is coordinated with the Regulatory Affairs

Department. Any policies requiring state/DMAHS approval are submitted to the GP Regulatory Affairs

Department for submission to the State. Such policies which require State/DMAHS review and

approval require a DMAHS stamp on the policy.

5.5 Delegation Oversight
Delegated managed care entities that administer health care services and/or provide services

covered under GP?s benefit plans are subject to review and oversight under the QI Program. These

services include, but are not limited to, activities/functions relating to utilization review/management,

case management, quality improvement, credentialing/re-credentialing, utilization management

appeals, HEDIS gap closures, radiology services, pharmaceutical services, laboratory services, vision

services, dental services, telemedicine, post-acute skilled nursing facility (SNF) and rehab care services,

durable medical equipment, grievances, customer service and claims processing.

Contracted delegates/vendors are obligated to provide and administer services in accordance

with contractual terms and conditions, applicable state and federal laws & statutes, including but not

limited to, regulations set forth by the New Jersey Department of Banking and Insurance (DOBI), New

Jersey DMAHS Managed Care Contract provisions, the Health Claims Authorization, Processing and

Payment (HCAPP) Act, CMS regulations, Horizon BCBSNJ policies and procedures, and current-year

NCQA standards and guidelines. GP remains accountable for the quality, integrity and appropriateness

of delegated functions and services provided by subcontractors for Horizon BCBSNJ?s MLTSS, FIDE-SNP

and Medicare Advantage members.

It is Horizon BCBSNJ?s responsibility to ensure monitoring and oversight activities are

performed to ensure delegate/vendor compliance and to promote the delivery of and access to quality

and cost-effective health care and services to members. The Delegate Vendor Oversight Committee is

responsible for the following: assessing on-going monitoring and evaluation activities performed

collaboratively and independently by GP business units; evaluation of delegate/vendor performance

results to ensure business goals and outcomes are achieved to further the delivery of quality health



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goals and outcomes for our members and; ensuring subcontractor compliance with contractual

provisions, regulatory requirements, and applicable accreditation guidelines.

A quarterly subcommittee report summarizing items and issues reviewed and discussed at

DVOC meetings must be submitted and presented to the QIC and the Horizon Quality Committee

Board (HQCB). A summarized overview on delegate/vendor oversight activities must also be submitted

to the Compliance and Ethics (C&E) Committee. Committee reports must include, but not be limited

to, delegate/vendor performance statistics, the status of delegate/vendor CAP (when applicable) and,

oversight monitoring reports and; must highlight matters of importance and/or that require the

attention of the QIC, HQCB or C&E Committee.



5.6 Compliance with State and Federal Regulatory and NJ Medicaid
Managed Care Contract Requirements
Government Programs places the utmost importance on compliance with regulatory and

contract requirements. This is particularly important as it relates to member safety, the handling of

private health information and the integrity with which the Plan cares for its members.

? Confidentiality

GP processes address sensitive protected health information about members and physicians.

Documents that are created and reviewed as part of the process are confidential and privileged. The

information is maintained in compliance with appropriate federal and state regulations, the Health

Insurance Portability and Accountability Act (HIPAA) and all applicable accreditation standards. All

employees, participating physicians, vendors and consultants must maintain the Horizon BCBSNJ

standards of ethics and confidentiality regarding both member information and proprietary

information. All employees and non-employees are required to sign a confidentiality statement, as

well as any consultant or business associate that may need to access confidential member

information. In addition, certain business associates perform certain business functions on behalf of

GP involving the use, disclosure or receipt of private health information. These third parties are

business associates of GP and will sign a GP Business Associate Agreement to protect the privacy and

safeguard the security of such private information when assisting with administrative functions or

providing services for or on behalf of GP.



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? Member Rights, Responsibilities and Patient Engagement

GP is committed to maintaining a mutually respectful relationship with its members that

promotes effective health care. GP makes clear its expectation for the rights and responsibilities of

members and sets a structure for cooperation among members, practitioners and the health plan.

GP recognizes that members must establish a dynamic partnership in the management of their care,

which includes the members' family and their health care practitioner.

When care does not meet the member's expectations, GP assures members of their right to

voice grievances (complaints) and to appeal any decisions with which they do not agree.

? Regulatory Compliance

The QI Program through the QIC:

o Monitors regulatory requirements for quality management and compliance;

o Ensures that the appropriate actions are taken when areas of quality management non-
compliance are identified; and

o Ensures GP quality management reporting system provides adequate information for
meeting the regulatory external review and accreditation requirements of mandatory and
voluntary review bodies.

? Ethics

The QI program functions as a key component in promotion of integrity and values found in

the care and services provided to GP members. As outlined in the Horizon BCBSNJ Corporate Code of

Business Conduct and Ethics, Horizon BCBSNJ is committed to maintaining the highest legal and

ethical standards in the conduct of its businesses. In maintaining these standards, Horizon BCBSNJ

places heavy reliance on individual good judgment, honesty and character. This commitment applies

without exception to all activities.



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5.7 Accreditation
GP Medicare and Medicaid lines of business are accredited by the NCQA. The Quality

Management Department, through the QI program, continuously monitors all applicable GP business

areas to ensure their compliance with the most current NCQA Health Plan Accreditation standards

and guidelines. The QI Accreditation Team provides education, assessment and feedback to business

areas for continual readiness in between reaccreditation cycles. The Accreditation Team monitors

compliance with standards on an ongoing basis and reports the status of accreditation activities at

least quarterly to the QIC.

5.8 Credentialing and Re-credentialing
GP?s credentialing and re-credentialing activities are managed by the Horizon BCBSNJ

Credentialing Department. Horizon BCBSNJ?s credentialing and re-credentialing process determines

whether physicians, other health care professionals, and organizational providers of services meet all

applicable state licensing standards, participation and credentialing criteria, and are qualified to

provide the care or services for which they have been contracted. GP maintains oversight of the

credentialing and re-credentialing activities through the QIC. In addition, the QPRC provides reports

to the Credentialing Committee on quality of care and service sanctions that are issued by the QPRC.

This information is taken into account when providers are evaluated for re-credentialing.

5.9 Clinical Practice Guidelines (CPGs)
CPGs are evidenced-based practice standards promoted by GP. They are used to assist staff in

making appropriate recommendations and to inform members and providers about making educated

health care decisions. Topics addressed by GP CPGs include, but are not limited to, preventive health,

asthma, diabetes, maternity, EPSDT, behavioral health and geriatric care. The CPGs are based on

nationally recognized medical association standards and medical references. The guidelines are

reviewed and updated at a minimum of every two years, or as needed, and they are presented to the

UM/CM Committee for approval. Information about GP CPGs is made available to providers through

the GP Provider Administrative Manual, provider newsletters and the Horizon NJ Health website.

Guidelines are available to members through the website, member newsletters, and/or a copy can be

requested by calling the Member Services Department.



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5.10 Cultural Competency and Health Literacy
Horizon BCBSNJ recognizes the cultural diversity and health literacy needs of its health plan

members. The Plan is committed to promoting cultural competency, increasing health literacy, and

decreasing health care disparities, regardless of gender, gender identity or sexual orientation. GP

utilizes data from multiple sources to develop and implement policies and programs to increase

cultural competency and health literacy. Education is provided to staff and participating providers to

enhance the provision of culturally competent and linguistically appropriate care. Language

assistance services, including bilingual staff and interpreter services, are offered and provided to

members at no cost. GP produces member-related materials which are easily understood and in

languages that meet member needs.

The objective of GP cultural competency and health literacy efforts are to improve materials
and communications by:

? Increasing the cultural sensitivity of employees and providers
? Gaining a better understanding of the needs of our members through solicitation of

member feedback
? Optimizing members? experience with the health plan
? Enhancing the provision of quality care to members with diverse values, beliefs and

behaviors
? Encouraging the development of more effective strategies for communication with

members
? Identifying and overcoming barriers most likely to inhibit the advancement of health

care for diverse groups


In evaluating cultural and linguistic needs, GP performs the following:

? Identifies linguistic needs and cultural backgrounds of members, by using U.S. Census
data, enrollment data and member feedback

? Identifies languages of practitioners in provider networks to assess whether they meet
members' linguistic needs and preferences


The data from these reports is analyzed and used by GP to adjust the practitioner network if

the current practitioner network does not meet members' language needs and preferences. Where

there is a deficiency, efforts are made to recruit providers and practitioners to meet the needs of the

underserved groups.



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Additionally, case managers identify member cultural, physical, auditory, vision and

linguistic barriers to care as a part of the Complex Needs Assessment process. Member needs are

assessed and barriers are addressed throughout the continuum of care.

5.11 Fraud, Waste, and Abuse
The Fraud, Waste and Abuse Prevention Plan documents the organization's comprehensive

approach to prevent, detect, investigate, recover, and report cases of fraud, waste, and abuse in the

Medicare Advantage, Medicare Advantage Part D, Medicaid, FIDE-SNP and NJ FamilyCare Programs.

The plan supplements all Horizon BCBSNJ and Horizon NJ TotalCare (HMO D-SNP) policies and

workflows on fraud, waste and abuse prevention, and provides a framework for monitoring

compliance with the following fraud waste and abuse-related requirements including:

? NJ Medicaid Managed Care Contract

? Federal Program Fraud Civil Remedies Act, New Jersey False Claims Act

? New Jersey Anti-Fraud Prevention and Detection Plan Protocol, (N.J.A.C.
11:16-6.7)

GP routinely discovers issues that require intervention and analysis. The various methods

employed to aid in monitoring and identifying fraud, waste and abuse include daily queries, the SAS

analytical software package, referrals from internal departments, external referrals (i.e. State

Medicaid Fraud Unit, pharmacy audit vendors, and fraud hotline) and media publications. Horizon

BCBSNJ?s Medicaid and Medicare Special Investigations Unit (SIU) coordinates fraud waste and abuse

activities with all state and federal agencies. If a potential issue is identified, the information is

reported to Horizon BCBSNJ?s Medicaid and Medicare SIU for evaluation and further action.

5.12 Program Performance
Horizon BCBSNJ dedicates resources across the organization, and specifically within the

Quality Management Department, to focus on GP Quality Performance. This work is guided by the QI

program and included in the QI program Work Plan. The QIC has oversight of this work including the

planning, monitoring and evaluation of the outcomes of these efforts.



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5.12.1 QI Program Work Plan
Annually, the Quality Management Department creates the QI program Work Plan.

The work plan is presented to the QIC in the first quarter of the year. The QIC provides

recommendations for revisions and the committee approves the work plan. The QI program

Work Plan is designed to be inclusive of all aspects of the QI program?s responsibilities. The

work plan is updated as needed during the year to incorporate recommendations that are

identified through the completion of the QI Program Evaluation and/or by recommendations

made by the QIC. The QIC reviews the work plan at least quarterly to ensure that the

activities outlined within the work plan are being addressed by the appropriate business

owners, and to ensure progress is being made toward the stated goals. If the QIC determines

that progress is not being made toward goals, the committee is tasked with providing

recommendations to assist the business area in identifying barriers and developing

interventions to overcome the barriers. The 2020 QI Work Plan will identify items applicable

to behavioral health services, which were previously delegated to Beacon Health Options.

5.12.2 Performance Improvement Projects (PIPs)
A performance improvement project (PIP) is a concentrated effort on a specific

problem within the health plan. Information is systematically collected for the clarification of

issues or problems, which are then the focus of improvement. Improvements are made via

the development of interventions. The Plan develops and conducts PIPs to examine and

improve care or services in areas that have been deemed as containing deficiencies.

Deficiencies are determined via the analysis of data against a specific standard.

The Quality Improvement Operations team is responsible for assisting in the design,

implementation, execution, analysis, and reporting of GP state and CMS-required PIPs and

Chronic Care Improvement Projects (CCIPs). Plan Do Study/Check Act cycle in addition to Lean

Six Sigma methodologies are used to develop and ensure continuous quality improvement

throughout the entirety of each PIP.

5.12.2.1 Medicaid PIPs (State PIPs)
Horizon NJ Health conducts four performance improvement projects (PIPs)

specific to its State/Medicaid membership. The topics for these PIPs are determined

by DMAHS. The current topics include: (1) MLTSS reducing admissions, readmissions



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and gaps in service for members with congestive heart failure in the Horizon NJ

Health MLTSS Medicaid population; (2) Increasing Developmental Screening and Early

Intervention; (3) FIDE-SNP reducing admissions, readmissions and Emergency Room

(ER) visits in members with asthma; (4) MCO Adolescent Risk Behavior and

Depression Collaborative. Twice per year, Horizon NJ Health submits reports to the

State detailing Horizon NJ Health?s efforts and outcomes related to each PIP. This

takes place in April and August. In addition to semi-annual submissions, Horizon

BCBSNJ monitors intervention implementation timeliness and effectiveness along

with all other PIP-related activities to ensure positive results.

5.12.2.2 Medicare PIPs (CMS PIPs/CCIPs)
GP participates in ongoing quality improvement programs for each contract

in place. The purpose of the QI program is to ensure that GP has the necessary

framework and infrastructure to coordinate care, promote quality, performance, and

efficiency on an ongoing basis. The guidelines followed and incorporated into the QI

programs are based on the 42 CFR? 422.152 regulation. Each Chronic Care

Improvement Project (CCIP) applies to the three MA contracts in place. Currently,

there are three CCIPs in place for each contract with a focus on promoting effective

management of chronic disease. The CCIPs in place have a three-year project cycle.

GP is no longer required to submit updates for its Medicare CCIPs to CMS, but rather

monitors CCIPs internally and submits an attestation that confirms the projects are in

place.

5.12.3 Healthcare Effectiveness Data and Information Set (HEDIS)
GP Medicare, FIDE-SNP and Medicaid HEDIS measures are evaluated and analyzed

monthly. Initiatives are developed, changed, and/or enhancements to initiatives and

outreach activities are discussed in the HEDIS workgroup meetings. HEDIS performance

results are reported annually to the State, QIC, NCQA and reported at the Quality Committee

board meeting through review of the QI Program Evaluation.

Annually, GP creates a new work plan to address State HEDIS measures that fall

below 50th percentile with the exception to the Lead Screening Measure, which is added if it

falls below the 75th percentile. This work plan is provided to DMAHS on or before August 15



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annually. Existing initiatives and outreach areas are evaluated for their impact and, if needed,

are enhanced to improve measure performance. The results and outcomes of initiatives and

outreach are monitored monthly and shared in HEDIS workgroup meetings held four times

per year.

5.12.4 Star Ratings
GP Medicare Star Rating measures are monitored monthly. Star Rating measures are

assigned to business owners who develop strategies, initiatives and outreach activities to

maintain and/or improve performance. Star Rating progress is reported to the QIC on a

quarterly basis. Star Rating measure performance results are reported annually to the State

(FIDE-SNP product only), to the QIC, NCQA and at the Quality Committee board meeting

through review of the QI Program Evaluation.

5.12.5 Consumer Assessment of Healthcare Providers and Systems
(CAHPS)

The CAHPS survey captures accurate and complete information about member-

reported experiences and how well the Plan and providers are meeting members?

expectations and goals. The Quality Management Department coordinates Government

Programs? efforts to improve CAHPS scores for Medicare, Medicaid and FIDE-SNP for adults

and children. The planning, work and results of these efforts are reported to QIC directly.

Specific CAHPS work plans are created to manage each line of business. Government

Programs has determined that in 2020, opportunity exists to continue efforts to improve on

all measures. These are all drivers of customer satisfaction and impact the Plan?s overall

ratings. The QI Program Work Plan will incorporate the QIC?s oversight of CAHPS

improvement efforts.

5.12.6 Health Outcomes Survey (HOS)
The Health Outcomes Survey (HOS) provides an assessment of how Horizon BCBSNJ?s

members describe changes in their health status over time. Horizon BCBSNJ?s Customer

Experience team analyzes the results of the HOS survey and this analysis is presented to the

QIC for discussion and recommendations for interventions that can be put in place to

improve Horizon BCBSNJ?s HOS survey results. Review of the HOS survey results is included in

QI Program Work Plan.



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5.13 New Initiatives
In 2020, GP will be embarking on multiple new initiatives. While all of GP?s new initiatives

have the potential to impact the quality of care and service GP provides its members, the following

specific initiatives require direct monitoring by the QI program because of their scope and impact on

members and providers.



? ?Lost? Post Service Appeals

In collaboration with the Operations Service Center (OSC), internal compliance teams, legal and
facility management, we will continue efforts to eliminate the post service third party vendor
facility appeals that have USPS tracking numbers but never arrive at the UM appeal department
for processing. The OSC improvement activities include hiring additional staff and securing a
scanning tool to validate receipt of forwarded USPS mail with tracking.

? Mortality Reporting

In 2019 the QM Department established a Tableau report for self-service mortality reporting
capabilities for Government programs and the commercial lines of business. In 2020, expansion of
the use of mortality reports will move forward in collaboration with other Horizon BCBSNJ clinical
departments.

? Behavioral Health (BH) and Substance Use Disorder (SUD) Appeal Management

Medical necessity management for BH and SUD appeals will be transitioned to Horizon BCBSNJ.
The GP Appeals Team has three additional staff who will have specific education to manage these
appeal types. In addition, a supervisor with extensive BH experience will oversee the team.

5.14 Opportunities for Continued Improvement
Opportunities for improvement that are identified in the QI Program Evaluation are

incorporated into the following year?s QI Program activities for implementation and monitoring by

the QIC including but not limited to:

? Health Care Disparities ? identification of opportunities for improvement health care
disparities to improve member support and engagement

? Appeals ? Complexity of the appeal process for Medicare and FIDE-SNP members
? Reduce ?lost post-service facility appeals? sent with USPS tracking
? Misroutes of grievances to the Quality of Care team
? Hospital Acquired Conditions and Serious Adverse Event Management
? Readmission quality of care reviews



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? Star Rating and CAHPS ? focused implementation of improvement initiatives
? Lead ? improve screening rates across all counties
? Reducing admissions, readmissions and gaps in services for members with Congestive

Heart Failure in the Horizon NJ Health MLTSS Medicaid population
? Dental provider network deficiencies in Atlantic County
? MLTSS provider network deficiencies in several counties
? Improve timeliness of grievance processing
? Continued focus on GP CAHPS - to ensure that member satisfaction is achieved.

Addressing opportunities identified within the HEDIS & CAHPS Performance to achieve
NCQA Commendable status for the Medicaid and Medicare products



GP will pursue these opportunities for improvement in 2020 and include updates to activities

in the QI Work Plan to monitor, track and trend progress toward goals.



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Attachments to Program Description

Attachment 1 ? 2019-2020 MLTSS Program Description

2019-20 MLTSS
Program Description.p



Attachment 2 ? 2020 FIDE-SNP Care Management and Quality Management Program Description

2020 SNP Care
Management and Qua



Attachment 3 ? 2020 GP Committee Organization Chart

2020 Horizon GP
Committee Organizatio



Attachment 4 - GP Executive Organizational Chart

Horizon GP Executive
Organizational Chart



Attachment 5 - Quality Management Department?s Organizational Chart

QM Org Chart
January 2020.pdf



Government Programs 2020 Quality Improvement Program Description



Approvals


__________________________________ ___2/26/20____________
Roberta McNeill, MD Date
Medical Director
Chairperson Designee, Quality Improvement Committee




__________________________________ __2/26/20_____________
Donald Liss, MD Date
Vice President & Chief Medical Officer









3.1 Program Evaluation 8
4.1 Governing Body 9
4.2 Committees 9
4.3 Inclusion of Participating Providers in the QI Program 13
4.4 GPOrganizational Chart 14
4.5 QI Program?s Resources 14
4.6 External Quality Review 19
4.7. Behavioral Health 21
5.1 Member Safety 22
5.2 Disparities in Health 22
5.3 Quality Assurance 24
5.4 Policy Management 31
5.5 Delegation Oversight 32
5.6 Compliance with State and Federal Regulatory and NJ Medicaid Managed Care Contract Requirements 33
5.7 Accreditation 35
5.8 Credentialing and Re-credentialing 35
5.9 Clinical Practice Guidelines (CPGs) 35
5.10 Cultural Competency and Health Literacy 36
5.11 Fraud, Waste, and Abuse 37
5.12 Program Performance 37
5.13 New Initiatives 41
5.14 Opportunities for Continued Improvement 41
1. Purpose of the Quality Improvement (QI) Program
2. Program Scope
3. QI Program Objectives/Goals
3.1 Program Evaluation

4. Structure of the QI Program
4.1 Governing Body
4.2 Committees
4.3 Inclusion of Participating Providers in the QI Program
4.4 GP Organizational Chart
4.5 QI Program?s Resources
4.6 External Quality Review
4.6.1 Department of Medical Assistance and Health Services (DMAHS) and the Island Peer Review Organization (IPRO)
4.6.2 Centers for Medicare & Medicaid Services (CMS)

4.7. Behavioral Health

5. QI Program?s Function
5.1 Member Safety
5.2 Disparities in Health
5.2.1 Complex Health Needs

5.3 Quality Assurance
5.3.1 Grievances and Appeals
5.3.1.1 Medicaid Grievances
5.3.1.2 Medicare Grievances
5.3.1.3 Appeals

5.3.2 Quality of Care and Service
5.3.2.1 Quality of Care and Service
5.3.2.1.1 Mortality Data

5.3.2.2 Programs for the Elderly and Disabled
5.3.2.3 Population Health
5.3.3 Audits and Reports
5.3.4 Early and Periodic Screening, Diagnostic and Treatment (EPSDT) - Lead Screening

5.4 Policy Management
5.5 Delegation Oversight
5.6 Compliance with State and Federal Regulatory and NJ Medicaid Managed Care Contract Requirements
5.7 Accreditation
5.8 Credentialing and Re-credentialing
5.9 Clinical Practice Guidelines (CPGs)
5.10 Cultural Competency and Health Literacy
5.11 Fraud, Waste, and Abuse
5.12 Program Performance
5.12.1 QI Program Work Plan
5.12.2 Performance Improvement Projects (PIPs)
5.12.2.1 Medicaid PIPs (State PIPs)
5.12.2.2 Medicare PIPs (CMS PIPs/CCIPs)

5.12.3 Healthcare Effectiveness Data and Information Set (HEDIS)
5.12.4 Star Ratings
5.12.5 Consumer Assessment of Healthcare Providers and Systems (CAHPS)
5.12.6 Health Outcomes Survey (HOS)

5.13 New Initiatives
5.14 Opportunities for Continued Improvement