Thursday, July 10, 2014

Two CMS SOAs: What's up with that?

In this post Affordable Care Act adoption environment, the health care spectrum has a lot of abbreviations to represent care priorities. Often those abbreviations can have double meanings; one for engaging with beneficiaries and another for managing systems. Recently, while considering the HIT and health care delivery responsibilities I have, I came across such an abbreviation. SOA is a term heard frequently in the care environment but could the use of the term confuse the savvy provider?

What is SOA?
The abbreviation "SOA" has two meanings.  If the provider likely delivers systems management services to other providers the term means "Service-Oriented Architecture". This is usually applied to the automation of processing claims and other business functions. In essence SOA is an application architecture within which business functions and selected technical functions can be invoked using identified processes (CMS 2013). To put this in practical terms you have to understand that as health care processes have evolved systems, particularly state-to-state systems have become increasingly difficult to interconnect. It is difficult for MMIS systems to communicate across technical and functional boundaries. The SOA allows processes to be published, shared, and discovered. How simple is that?

As for the SOA encountered by the savvy provider during day-to-day business activities, we are referring to "Scope of Appointment" forms. You can find the guidelines for SOA under CMS's Medicare Marketing Guidelines rules: MMG, section(s) 70.9.2; 70,9.3; and 70.9.4. Here's the scoop: a signed SOA is required for all personal or individual face-to-face marketing appointments where MA MAPD PDP and/or Cost Plan products are being discussed with Medicare beneficiaries.

When is the appropriate or approved time to perform the SOA?
The provider has two opportunities to perform the SOA. Pay attention, these are not negotiable. They are:

  1. Before the appointment, at least 48 hours if practical. 
  2. If not practical, the SOA can be signed at the beginning of the marketing appointment. However, you must ensure you document, on the SOA, why the form was not signed 48 hours in advance. There should be a space provided on the form for the explanation. Remember to document the SOA on the CMS approved SOA form. Some providers may choose to do both as a fail-safe for obtaining the SOA but only one should be submitted. The savvy provider would ensure the SOA is signed 48 hours in advance and beginning of appointment SOAs should be used sparingly as not to appear irresponsible in the eyes of CMS auditors.

  • These are the only two CMS approved times to perform the SOA. 
  • Remember, the forms must be retained for 10 years

I hope this clears up any confusion regarding SOAs. I  encourage any comments regarding either of these processes and look forward to engaging in discussions about either. As always, care for your clients first and I'll see you in the field. Carry on!