Well....no.
If one Googles the term “MITA compliant”, the search engine returns over 100 listings of web entries that contain this term; a fascinating number, really, considering there is currently no such thing (Although if you Google “Sasquatch” you get almost two million hits so I guess we aren’t doing all THAT bad…yet).
Most of the sites that reference “MITA Compliance” are related to vendors that appear to have little or no understanding of MITA or MITA concepts; these vendors pepper their sites and their site’s meta-data with the terms “MITA” and “compliance” in the hope that search engines will direct people seeking information on MITA to their site. One particular gem that I happened upon stated that “MITA compliant MMIS systems will enable real-time HIPAA processing” and that this new and amazing capability, “will give healthcare providers to [sic] significantly increase the productivity of systems and staff.” Now this might be amusing except…there are actually real people working for real State governments in the area of Medicaid information systems who have been charged with determining the impact of MITA on their State Medicaid business and these good folks have to navigate the gauntlet of false claims and misinterpretations being offered by many of these self-proclaimed experts (present company excluded of course).
This raises an interesting question – will there be such a thing as a MITA-compliant solution at some point in the future? To answer this question, it helps to take a closer look at what MITA is and what MITA is not.
Simply put, MITA will provide standards around which technical and information solutions will be built and/or provided to advance the maturity of State Medicaid business processes. More specifically, MITA will stipulate standard formats for business process inputs and outputs and for the shared data that are used in the performance of these processes – MITA is a framework, not a solution.
In its simplest of form, a “framework” is a structure supporting or containing something or an organizing structure for the essential knowledge and skills in a program area. Some common industry definitions for the word “framework” include, “an extensible structure for describing a set of concepts, methods, technologies, and cultural changes necessary for a complete product design” and, “a systematic format and technical structure that supports metadata concepts, contents, and controlled vocabularies.”
MITA is today, a set of defined business processes that will provide significant help to States as they complete the business process re-engineering phase of systems development with the goal of maturing these processes toward the long term aspirations of utilizing clinical data to improve the quality of beneficiary care and the enabling the interoperability that will support the quality goals.
MITA today contains the basic elements needed to introduce States to the tenets of service-oriented architecture (SOA) and lays the foundations for the technical functions that need to be implemented to allow this architecture to support the maturing business processes.
MITA today explains the need for a standardized information architecture and reliance on data standards to support maturing business processes.
MITA today is not complete and does not contain the components needed for anyone to offer a “MITA compliant” solution. Noticeably missing are the definitions of the formats for the standard WSDL inputs, outputs, and data standards for various levels of business process maturity along with common conceptual and logical data models. Both of these areas are currently being addressed by CMS and various workgroups but are at best works-in-progress.
Until the MITA framework is more complete, claims of MITA compliant solutions should be viewed through the prism of caveat emptor. If someone approaches you claiming the ability to deliver a MITA compliant solution, I would simply ask, based on what?
37 comments:
hey Mikey, just to add some additional food for thought to the debunking you've done here (which I agree with 100%)...A while ago our CMS regional rep jokingly indicated (ok, perhaps only half-jokingly, I'm afraid) that they would immediately deny enhanced funding for any APDs, RFPs, or contracts that contained the words "MITA-compliant" or even contained connotations of the concept of "MITA-compliance"! But in all seriousness, from a contract management perspective, how do States hold contractors accountable to taking the steps to move toward MITA without saying something to the effect of, "you must be where MITA is and doing your best at what MITA recommends at any given point in time?" when States are constantly dealing with one moment in time to conduct a procurement that will last them 5-10+ years? I welcome any thoughts you or anyone else has on this that would be of benefit to the doubters out there (namely our management & procurement folks).
For mita-morphosis, I think the problem you talk about gets to the whole point about doing a MITA SS-A. Each Medicaid needs to figure out its own business and technical requirements. You can use MITA to tell you how "mature" your resulting process would be, and whether it is consistent with the goals expressed in the Framework. This requires a lot of effort and planning that some organizations are not ready for. Telling a vendor they need to be consistent with MITA is unfair to everyone involved unless specific requirements are identified; nobody would know what is really expected. If you have a vendor on board and they propose a solution that does not enhance data-sharing capability for quality improvement (or whatever good thing comes to mind), the requirement for that data-sharing capability needs to be stated and refined. Nothing has changed except for MITA providing a framework for improving Medicaid over time via IT.
You bring up a good point regarding contractor management. I think that the takeaway from the post is really the "caveat emptor" statement. The degree to which States need to be concerned about dubious offerings or statements from vendors is in proportion to their own understanding of MITA and the term MITA compliant; A State that is MITA-savvy obviously has less to worry about.
There are certainly very good vendors in the MITA arena that have the best interest of the States at heart, I did not mean to imply that there is a problem with all vendors. Likewise, the level of comfort that a CMS regional office staff member would have in approving an APD or RFP containing the term MITA compliant would be proportional to the regions perception of the States understanding of MITA and the background and experience of the vendor involved.
To be in keeping with the spirit of MITA, in the absence of more specific guidance from CMS, contractors should be making enhancements and/or proposing solutions that are moving in the direction of interoperability and systems that are maturing in a way that is concistent with national HIT goals and objectives. Not a great answer for now, but I am sure (at least I hop)that this discussion will continue to evolve.
Thanks for the comments!
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