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Fraud, Waste & Abuse:
Capture low hanging fruit and more…
Using Analytics to Detect, Predict and Change Behavior
ACAP Webinar
May 19, 2016
Leon Edelsack
President
TPG Data Services
Craig Stern, RPh, PharmD, MBA
Senior Consultant
ProData Analytics
Marjorie Zimmerman MS, BS Pharm
Senior Consultant
The Pharmacy Group
.
2
Introduction to
TPG Data Services (TPG-DS) has the knowledge, expertise and resources
to provide your organization with the tools necessary to efficiently
manage your prescription drug program and potential FWA issues.
Our team helps clients:
• Manage the financial performance of healthcare transactions to help
payors
• Continually monitor the marketplace, arming us with up-to-date
business intelligence to deliver unbiased information tailored to
individual client needs
• Mitigate F/W/A via an innovative and multidisciplinary approach
necessary to effectively combat losses and change behavior
3
Webinar Overview
• Defining F/W/A
• F/W/A Statistics
• Market Challenges
• Case Study
• Predictive Analytics
• Solutions
• Key Takeaways
4
Defining F/W/A
Fraud: “… an intentional deception or misrepresentation made by a person
with the knowledge that the deception could result in some unauthorized
benefit to himself or some other person. It includes any act that constitutes
fraud under applicable Federal or State law.”
Waste: Not explicitly defined by rules but “generally understood to
encompass over- utilization, underutilization or misuse of resources, and
typically is not a criminal or intentional act.”
Abuse: “... provider practices that are inconsistent with sound fiscal,
business, or medical practices, and result in an unnecessary cost to the
Medicaid program, or in reimbursement for services that are not medically
necessary or that fail to meet professionally recognized standards for health
care. It also includes beneficiary practices that result in unnecessary cost to
the Medicaid program.”
Definitions, 42 C.F.R. § 455.2 5
Types of Fraud, Waste and Abuse
• Overutilization
• Billing for unnecessary services or items
• Billing for services or items not rendered
• Upcoding
• Unbundling
• Billing for non-covered services or items
• Beneficiary fraud
6
F/W/A By the Numbers
• Every hour, the United States loses $28.5
million to healthcare F/W/A.
• That is over ten times the amount an average
American will earn in their lifetime.
• Totaling as much as $234 billion annually,
F/W/A is becoming a growing problem which
is too large to overlook.
7
Market Challenges
• Growth in F/W/A driving up healthcare costs
and increasing risk for plans and members
• Absence of real-time approach to identify
fraud before it happens
• Fraud management processes lack
sophistication and preventative measures
• Outdated technology systems
• Lack of technical knowledge at Plans to know
how to assess the vast amounts of data
8
F/W/A Players and Flow of Information
• By combining point of sale, patient and prescriber information, you gain a
total situational view
• Resulting in efficient identification and timely resolution of problems
9
Multidisciplinary Approach
• Assessment of the nexus of activity between
the member/patient, the prescriber and the
pharmacy
• Evaluation of transactions and activity among
those three entities
• Map the relationship between these different
constituents
10
F/W/A Program Elements
Capture low-hanging fruit and more..
• Protect
• Predict
• Monitor
• Change Behavior
Impacting the cycle of behavior is critical to the
success of the program…
11
Predictive Analytics
• Predictive analytics can identify patterns of
behavior that indicate areas of potential F/W/A
• Technology by itself will not change behavior
• By proactively developing and implementing
targeted communications programs to reach out
and suggest corrective action we have seen
results
12
Preventing Payments
• Ways we work to identify a F/W/A profile as
soon as the transaction happens
• Leveraging predictive tools to prevent
payment
• Aligning with the current direction of CMS –
to prevent wrongful payments before they
happen
13
Integrating Analytics &
Behavior Modification
• Specific analytics
• Technical & Clinical support
• Results help change the behavior of the
doctor or a pharmacy, and potentially even
members
14
Case Study – Industry Example
• Large Medicare program
• Concerns over PBM detection and internal
Strategic Investigation Unit (SIU) focus
• Focus on independent pharmacies
• Budget year impact net savings >$8M
15
Predictive Model Considerations
16
• Analytical flags cover financial, utilization,
geographic, severity, day/time, risk flags
• Input based on financial threshold/provider
• Analyze prescribers, pharmacies, patients – roll up
results to one or more, contact points
• Output based on:
• Severity, geography, provider type
• Flag findings weighted by frequency and probability of
risk
• Contact providers selected by threshold of risk
Predictive Modeling Output
Downtown Drugs has been identified in Fraud-Waste-Abuse audits as an outlier with more than
75% above multiple FWA metrics. Downtown Drugs was compared to other Independent
pharmacies with similar severity populations so that results indicate significant above average
variance.
State and Federal agencies have increased their vigilance on Healthcare Fraud, Waste, and Abuse
(FWA). This has prompted implementation of FWA Alarm Trigger Programs. The prescription(s)
below have initiated a FWA Excess Alarm Trigger for excess quantity (Qty), an excess daily dose
(OD), an excess dollar amount (Amt), excess day supply (OS), etc. This Alarm notice serves to
identify patients and medications that trigger an FWA Audit.
Recommendation: In addition to high risk from multiple edits, the claims below indicate paid
amounts that vary significantly over comparable claims filled by network pharmacies. These issues
require reconciliation and corrective action plans.
Note to Physician Providers: Please review the patient's chart and/ or medical condition and
consider the necessity for the trigger entity. In many cases, doses, quantities, and/or medication
can be adjusted.
This report relies on the validity of
the Medical and Pharmacy claims
submitted by Clients and PBMs. 17
Predictive Modeling Output
18
Name: DOWNTOWN DRUGS Type: INDEPENDENT Severity: Mid Severity Pharmacy ID: 2318663
Summary Potential Financial Impact(s)
• F/W/A metrics impact 14% to 25% of total paid
• F/W/A financial impact ranges from $1.5M - $6M
for pharmacy only
19
Segmented Potential Financial Impact
20
Lessons Learned
• Capture the low hanging fruit and more…
• Validated and surpassed visibility of SIU and PBM
• Fraud is legal issue and resource intensive
• Indicated greater than 4X ROI
• Demonstrated Waste & Abuse as significant as
Fraud
• Changing behavior takes time
21
Our Recommendations & Solutions
• Considerations include:
• Re-examine current internal practices for F/W/A
• Question whether you are sufficiently bending
the cost curve
• Work proactively, not reactively to mitigate
losses...
22
Key Takeaways
• Focus on prevention (CMS emphasis)
• Identifying and managing Waste & Abuse
should be high priority
• Bending the cost curve takes more than
technology
• Achieving high rate of return will take time
23
Questions?
24
THANK YOU
For additional information, please contact:
Leon Edelsack
President, TPG Data Services
leon.edelsack@tpg-ds.com
(c) 412-720-8955
www.tpg-ds.com
25

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Fraud, Waste & Abuse: Capture low hanging fruit and more

  • 1. Fraud, Waste & Abuse: Capture low hanging fruit and more… Using Analytics to Detect, Predict and Change Behavior ACAP Webinar May 19, 2016
  • 2. Leon Edelsack President TPG Data Services Craig Stern, RPh, PharmD, MBA Senior Consultant ProData Analytics Marjorie Zimmerman MS, BS Pharm Senior Consultant The Pharmacy Group . 2
  • 3. Introduction to TPG Data Services (TPG-DS) has the knowledge, expertise and resources to provide your organization with the tools necessary to efficiently manage your prescription drug program and potential FWA issues. Our team helps clients: • Manage the financial performance of healthcare transactions to help payors • Continually monitor the marketplace, arming us with up-to-date business intelligence to deliver unbiased information tailored to individual client needs • Mitigate F/W/A via an innovative and multidisciplinary approach necessary to effectively combat losses and change behavior 3
  • 4. Webinar Overview • Defining F/W/A • F/W/A Statistics • Market Challenges • Case Study • Predictive Analytics • Solutions • Key Takeaways 4
  • 5. Defining F/W/A Fraud: “… an intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to himself or some other person. It includes any act that constitutes fraud under applicable Federal or State law.” Waste: Not explicitly defined by rules but “generally understood to encompass over- utilization, underutilization or misuse of resources, and typically is not a criminal or intentional act.” Abuse: “... provider practices that are inconsistent with sound fiscal, business, or medical practices, and result in an unnecessary cost to the Medicaid program, or in reimbursement for services that are not medically necessary or that fail to meet professionally recognized standards for health care. It also includes beneficiary practices that result in unnecessary cost to the Medicaid program.” Definitions, 42 C.F.R. § 455.2 5
  • 6. Types of Fraud, Waste and Abuse • Overutilization • Billing for unnecessary services or items • Billing for services or items not rendered • Upcoding • Unbundling • Billing for non-covered services or items • Beneficiary fraud 6
  • 7. F/W/A By the Numbers • Every hour, the United States loses $28.5 million to healthcare F/W/A. • That is over ten times the amount an average American will earn in their lifetime. • Totaling as much as $234 billion annually, F/W/A is becoming a growing problem which is too large to overlook. 7
  • 8. Market Challenges • Growth in F/W/A driving up healthcare costs and increasing risk for plans and members • Absence of real-time approach to identify fraud before it happens • Fraud management processes lack sophistication and preventative measures • Outdated technology systems • Lack of technical knowledge at Plans to know how to assess the vast amounts of data 8
  • 9. F/W/A Players and Flow of Information • By combining point of sale, patient and prescriber information, you gain a total situational view • Resulting in efficient identification and timely resolution of problems 9
  • 10. Multidisciplinary Approach • Assessment of the nexus of activity between the member/patient, the prescriber and the pharmacy • Evaluation of transactions and activity among those three entities • Map the relationship between these different constituents 10
  • 11. F/W/A Program Elements Capture low-hanging fruit and more.. • Protect • Predict • Monitor • Change Behavior Impacting the cycle of behavior is critical to the success of the program… 11
  • 12. Predictive Analytics • Predictive analytics can identify patterns of behavior that indicate areas of potential F/W/A • Technology by itself will not change behavior • By proactively developing and implementing targeted communications programs to reach out and suggest corrective action we have seen results 12
  • 13. Preventing Payments • Ways we work to identify a F/W/A profile as soon as the transaction happens • Leveraging predictive tools to prevent payment • Aligning with the current direction of CMS – to prevent wrongful payments before they happen 13
  • 14. Integrating Analytics & Behavior Modification • Specific analytics • Technical & Clinical support • Results help change the behavior of the doctor or a pharmacy, and potentially even members 14
  • 15. Case Study – Industry Example • Large Medicare program • Concerns over PBM detection and internal Strategic Investigation Unit (SIU) focus • Focus on independent pharmacies • Budget year impact net savings >$8M 15
  • 16. Predictive Model Considerations 16 • Analytical flags cover financial, utilization, geographic, severity, day/time, risk flags • Input based on financial threshold/provider • Analyze prescribers, pharmacies, patients – roll up results to one or more, contact points • Output based on: • Severity, geography, provider type • Flag findings weighted by frequency and probability of risk • Contact providers selected by threshold of risk
  • 17. Predictive Modeling Output Downtown Drugs has been identified in Fraud-Waste-Abuse audits as an outlier with more than 75% above multiple FWA metrics. Downtown Drugs was compared to other Independent pharmacies with similar severity populations so that results indicate significant above average variance. State and Federal agencies have increased their vigilance on Healthcare Fraud, Waste, and Abuse (FWA). This has prompted implementation of FWA Alarm Trigger Programs. The prescription(s) below have initiated a FWA Excess Alarm Trigger for excess quantity (Qty), an excess daily dose (OD), an excess dollar amount (Amt), excess day supply (OS), etc. This Alarm notice serves to identify patients and medications that trigger an FWA Audit. Recommendation: In addition to high risk from multiple edits, the claims below indicate paid amounts that vary significantly over comparable claims filled by network pharmacies. These issues require reconciliation and corrective action plans. Note to Physician Providers: Please review the patient's chart and/ or medical condition and consider the necessity for the trigger entity. In many cases, doses, quantities, and/or medication can be adjusted. This report relies on the validity of the Medical and Pharmacy claims submitted by Clients and PBMs. 17
  • 18. Predictive Modeling Output 18 Name: DOWNTOWN DRUGS Type: INDEPENDENT Severity: Mid Severity Pharmacy ID: 2318663
  • 19. Summary Potential Financial Impact(s) • F/W/A metrics impact 14% to 25% of total paid • F/W/A financial impact ranges from $1.5M - $6M for pharmacy only 19
  • 21. Lessons Learned • Capture the low hanging fruit and more… • Validated and surpassed visibility of SIU and PBM • Fraud is legal issue and resource intensive • Indicated greater than 4X ROI • Demonstrated Waste & Abuse as significant as Fraud • Changing behavior takes time 21
  • 22. Our Recommendations & Solutions • Considerations include: • Re-examine current internal practices for F/W/A • Question whether you are sufficiently bending the cost curve • Work proactively, not reactively to mitigate losses... 22
  • 23. Key Takeaways • Focus on prevention (CMS emphasis) • Identifying and managing Waste & Abuse should be high priority • Bending the cost curve takes more than technology • Achieving high rate of return will take time 23
  • 25. THANK YOU For additional information, please contact: Leon Edelsack President, TPG Data Services leon.edelsack@tpg-ds.com (c) 412-720-8955 www.tpg-ds.com 25

Editor's Notes

  1. TPG Data Services (TPG-DS) is one of the business subsidiaries of The Pharmacy Group (TPG). Powered by ProData Analytics, TPG-DS has developed a unique approach to Fraud Waste & Abuse
  2. Highlight the differences between fraud, waste and abuse Impact to the industry
  3. Fraud is well defined as a legal standard and the efforts of payors (including the gov’t itself) have long been focused Waste is less clearly defined but is not a criminal act and may not be intentional which make it an area of opportunity to change behavior Abuse while not criminal does imply intent
  4. There are many forms of F/W/A- some attributable to the prescriber, some to the pharmacy and some even to the member
  5. There are numerous views about the money at stake but everyone is in agreement that the amount is staggering
  6. One way to address the issue is to consider examining the actions with all the key constituents
  7. To best capture the low hanging fruit and more the approach have to first protect the payor and to do this it is important to have a mechanism that can predictor potential F/W/A. Then the process has to be a diligent and ongoing monitoring of activity among all the key constituents. All these have to be done with a focus on ultimately changing the behavior of the identified entity.
  8. Predictive analytics uses a variety of statistical techniques on both current and historical information to make inferences about future behavior The technologies used to do this today are proven and robust but on their own will not change behavior Behavior modification requires identification, on-going communication and as important-recommendations of corrective action
  9. As mentioned before the priorities are to protect the Plan and to do this one needs to build a profile of potential F/W/A and flag transactions as soon as possible Leveraging the predictive tools creates a historical baseline and when combined with current transactions one can begin to prevent payment This type of approach is driven by the CMS directives of moving away from a pay and chase methodology
  10. I would like to summarize this approach before going into the Case study. Predictive analytics supplemented with technical and clinical support provides the substantive results that in turn must be communicated if one truly hopes to change the behavior at the level of the prescriber, pharmacy and perhaps even at the member level
  11. I would now like to turn to a case study where this approach was developed for the Plan The Plan was a large Medicare program. We believe the issues they were facing are directly applicable to Medicaid programs as well. The executives responsible for government programs raised concerns over the ability of their PBM to provide sufficient visibility to F/W/A. And while the internal SIU had uncovered some sizable Fraudulent activities, the Plan was looking for an approach to augment their efforts. They believe there was low hanging fruit if the focus was made at the pharmacy and specifically the independents The plan wanted to demonstrate a budget impact in excess of $ 8 million
  12. The Plan desired to have analytical flags that that covered a variety of factors Where the input was based on specific financial thresholds at the provider level The plan wanted to view the activities across the 3 majors points with the ability to view the information at an aggregate level of any one of them The output of the analytics was normalized the data base on patient severity, geography and provider type The Plan was presented an extensive listing of parameters and develop a preferred weighting and risk assignment
  13. The reports were design to provide both recommendations for corrective actions and comparative indices among like groups This slide shows an example of the descriptive summary and recommendations given to a specific pharmacy.
  14. This part of the report flagged those areas where the pharmacy was substantial deviation
  15. Internal to the Plan financials were aggregated and summarized to provide management visibility