May 4-8, I. Organizational Preparedness: What You Need to Know and Do

(1)

Boards May 4-‐8, 2015

9:00 a.m. to 3:30 -‐ 4:00 p.m.

I. Organizational Preparedness: What You Need to Know and Do

Background

Systems and Business Processes Vendors and External Systems Contracting and Payers

Testing, Revenue, and Training

II. Organizational Tools for Your Team

III. Desk Reference Materials

Lisette Wright, M.A., Licensed Psychologist Executive Director

Behavioral Health Solutions

(2)

BEHAVIORAL HEALTH/SUBSTANCE USE

PROVIDER ORGANIZATIONS

Prepared exclusively for: Fairfax County and Health Planning Region II Community Service Boards

By:

Behavioral Health SoluOons, P.A.

LiseRe Wright, M.A., Licensed Psychologist ExecuOve Director

May 4-‐8, 2015

(3)

Agenda

OrganizaOonal Readiness

Systems and Business Process Inventory

Revenue Cycle and Billing

ContracOng and RelaOonships

TesOng

(4)

READINESS

(5)

Typical ICD-‐10 TransiOon QuesOons

What are we going to do?

Who’s going to do it?

When is this going to get done?

How long will it take?

How do we know WHAT to do?

(6)

ICD-‐10 ImplementaOon In Steps

1.

ExisOng Culture and A\tudes

2.

Internal Team/CommiRee’s

3.

Assessment of Current States

4.

Planning and ExecuOng the Tasks

5.

Assessing and Tracking the Progress

(7)

ICD-‐10 Components

“What’s

YOUR

Y2K

Plan?”

Desk Reference Materials Clinical Training / EducaOon Revenue Cycle Systems & Business Processes Payer Contracts Policies and Procedures CDI Program

(8)

ExisOng Culture And A\tudes

DocumentaOon Compliance

Ownership and Steward of Quality

Care

SupporOng the DX and TP throughout

the LOS

EHR A\tudes Reinforcing the Leadership: Need to Change

Concept of ProacOve Versus

ReacOve All it takes is 1

lawsuit, suicide, payback…

(9)

Aligning With Strategy

Vision and Mission Focused

Consumer-‐centric and HolisOc Collegial and

(10)

Internal Team Membership

Clinical Medical Billing/Revenue Cycle Leadership Quality/Compliance

Champions of PosiOve Change InformaOon or ApplicaOons Systems

(11)

Sharing The Work Load And Strategy

•  Core ICD-‐10 ImplementaOon Team

•  Programs: May have smaller teams of 2-‐3 people

•  At this point, meet weekly

•  Use internal communicaOons such as SharePoint

•  Keep straighjorward minutes:

1.  Describe the Problem

2.  The AcOon Item

3.  Who Assigned To

(12)

(13)

What Do We Do?

q 

Communicate with all stakeholders

q 

Establish sequence, Oming, and work eﬀort needed

q 

Assess, idenOfy, and facilitate remediaOon plans

q 

Inventory and assign tasks, to-‐do’s, and Omelines

q 

Liaison between parOes (staﬀ, management, 3

rd

parOes)

q 

IdenOfy & problem-‐solve risks to ICD-‐10 project execuOon

q 

IdenOfy decision-‐making authority and processes

q 

Provide mechanism for stakeholder feedback and input

(14)

PROCESS INVENTORY

(15)

Systems And Business Processes

We know what we currently do…

We know where we must be…

(16)

The Systems And Business Process Inventory

(17)

Examples Of Systems

DiagnosOc touchpoints Any Stand-‐Alone Databases kept for OperaOonal Purposes Eligibility and Beneﬁt InformaOon Systems Prior-‐ AuthorizaOon’s, Forms PracOce Management Systems, eRX, HIE’s, Labs ReporOng: Public health, state, performance Child Welfare or other regulatory systems Super bills, charge sheets, MD visits, OON Forms Claims and Clearinghouses Computerized conversion tools (ICD-‐DSM) EHR’s: internal logic of CDS, alerts Business Intelligence / AnalyOcs ReporOng Internal databases / registries Templates EHR Billing Rules

(18)

How To Perform A Systems Inventory

1. Make a list of the system and any subsystem

2. Determine what is aﬀected and what changes need to happen

3. Determine Omelines (internal and external)

4. IdenOfy and track contacts, bulleOns, updates, dates, etc.

5. IdenOfy other tasks necessary to make the system work

(19)

Helpful Framework For Systems

•  Think about workﬂows and who does what:

•  Who Assigns Diagnoses?

•  Who submits claims?

•  What paperwork do you use?

•  Where does this paperwork live?

•  Who performs eligibility checks?

•  How do mulOple, diﬀerent diagnoses apply to 1 consumer and who

determines this?

•  Who assigns diagnoses? What if there are concerns or quesOons?

•  Is there a way to streamline the process?

(20)

Systems QuesOons To Ask Vendors

•  Vendors and Other Outside Business Associates

•  Plan, Dates, and Timelines

•  TesOng

•  Releases or Updates and Cost

•  What training will you provide on the new diagnoses in the system

•  Customer Support for Problems/TroubleshooOng

•  UOlizaOon of dual-‐coding, back-‐billing

•  Results of tesOng with payers

•  Source of Codes?

•  Vendor percepOon of impact on workﬂow?

(21)

The EHR: A Major Area For Concern

Your EHR

contains

diagnosOc

informaOon

is “hidden”

places

Your EHR

Vendor may

not be

ready, or

have

“turned on”

the

funcOonality

The

funcOonality

provided

may not be

User

Friendly

(22)

Three Main Areas Of EHR FuncOonality

Code Set Maintenance: What is the vendors plan to keep up with the CDC ICD-‐10 CoordinaOon and Maintenance changes; Who maintains the table structure modiﬁcaOons?

Code Set “AggregaOon”: Are the codes grouped according to diagnosOc category? If YES, then who does this?

(23)

ICD And DSM In The EHR

•  Proprietary processes: How one vendor does it is how one vendor does it

•  Easier to load ICD-‐10 codes into the system

•  DSM: Licensing Fees hi\ng vendors hard (6-‐ﬁgures)

•  Some vendors sOll do not have DSM-‐5 codes loaded

•  Netsmart:

•  Plug in DSM-‐5 diagnosis name, ICD-‐10 codes are then suggested

•  Qualifacts:

•  Same strategy as Netsmart

•  EPIC: DSM? What’s That? Sure, we will add it!

(24)

DSM-‐5 In EHR’s: What They Are Doing

(25)

Huh? Mixing ICD 9-‐10 codes with DSM-‐5 “descripOons?” Then again, if this works…

(26)

Again, how one vendor does it is one way. No

standardizaOon, no consensus, direcOon, guidance, etc. Therefore, the burden is on you as a provider

(27)

(28)

(29)

(30)

DSM-‐5

•  Using the Axis III ﬁeld to represent the main ICD-‐10 diagnosis

•  Some drop downs only contain the frequently used codes

•  Not all codes needed are included

•  Self-‐Harm Codes

•  Co-‐morbid Medical codes

•  Including/not WHODAS

•  Take-‐Away From the Vendor ConversaOons:

•  The vendors are in the same boat that we are!

•  Every vendor is diﬀerent

•  Main message: Burden is on the provider organizaOon to work through

(31)

Some Possible OpOons For Code Searches

•  Term-‐Based:

•  Using one word, or part of a word to produce the diagnosis lisOng

•  Search By Code

•  Search by code range, individual code numbers, parOal code numbers

•  AlphabeOcal or Tabular-‐Based:

•  Search by the 2015 Tabular Index or AlphabeOcal Index

•  Concept-‐Based:

•  Similar to Term-‐Based, but pulls tables from clinical concepts such as

“depression” or “anxiety”

•  Crosswalks:

•  Search by the old ICD-‐9 code with results pulling ICD-‐10 suggesOons

(32)

Advanced: Code AggregaOon

•  Groups/Categories of Codes that are used to support analyOcs and business intelligence (similar to a data dicOonary concept)

•  To do this, you will need:

1.  A standardized name for the set of codes 2.  DeﬁniOon of the intent of the code set

3.  DescripOon of what codes are aggregated and why 4.  Unique idenOﬁer for the set

(33)

Your EHR Diagnosing To-‐Do’s

1.  Clinical: drop-‐down’s, language and terms

2.  Assess for dual-‐coding capability before/auer October 1 AND is it End-‐User determined?

3.  Diagnoses in the System:

a.  At the Program or Service Level?

b.  Who changes these pre/post October ?

c.  When will the diagnoses change prior to October 1?

d.  How does this get changed so data entry only happens once for the

clinician?

e.  Diagnosis Tables: How do they funcOon? Does the end user pick ICD

versus DSM? If it is pre-‐set, what about pre-‐October 1 diagnoses? Axis versus No Axis's?

(34)

Diagnosing ConOnued…..

7.  Speciﬁer pop-‐up windows? For ICD or DSM?

8.  FuncOonal Assessments: GAF, WHODAS and the ability to

combine the GAF without Axis-‐driven diagnosing 9.  MulOple providers for one consumer: How does the

diagnosis get managed?

(35)

EHR Items

Billing Rules Supports or Internal Clinical Decision Logic

Templates and Clinical

DocumentaOon Support Tools

Reports: May need to be modiﬁed or new

ones created

Imports and Exports: Transfer of care from somewhere else and

imporOng DX’s (HIE)

Custom Forms

Order Sets? Can you add prompts in the EHR to capture good documentaOon?

(36)

Vendor-‐Partnership

§ Acknowledge their struggle

§ Oﬀer to be a Beta-‐site to get ahead of improvements

§ Work closely with the Vendor to request improvements:

§  Increased support at go-‐live?

§  Expected response Omes?

§  Vendor readiness for the federally mandated changes?

§  RemediaOon plans

§  Penalty plans

§  Any provisions to handle situaOons where vendors do not meet

(37)

OperaOonal Processes

How are outside records handled and put into the system? What

about “old” diagnoses?

When do you update current diagnoses and current client records? Conduct Formal Form Review Process: Hunt, gather, slice, dice, update, and improve

(38)

Business Processes To Assess And Address

•  Referrals

•  AuthorizaOons and Pre-‐CerOﬁcaOons

•  Payer-‐readiness with the new forms, eligibility systems

•  Intake Paperwork for Consumers

•  Update forms

•  ContracOng ConsideraOons with Vendors and Payers (next secOon)

•  Financial OperaOons (see next secOon)

•  Clinical training

•  Clinical DocumentaOon

•  Interfaces and Cross-‐System Dependencies (eRX, HIE)

•  ReporOng: Map ﬂow of data/reports and modiﬁcaOons needed

(39)

BILLING

(40)

Biggest Risk And Impact Area

Business Process, Contracts, Issues

Revenue and Billing Systems, Claims

(41)

Moving Into The Revenue Cycle

• 

We will have MORE diagnoses to choose from as of

October 1, 2015, this will require:

ü Assignment of the most speciﬁc code/diagnoses

ü More documentaOon to diﬀerenOate between diagnoses

ü More documentaOon to support diagnoses (to avoid audit paybacks later)

ü More documentaOon to support medical necessity

What impact will increased speciﬁcity and more diagnoses have on contracts and reimbursements?

(42)

The Payers Are Busy Too

1.  Distribute informaOon and guidelines

2.  EducaOon and communicaOon with providers

3.  Internal/external tesOng to accept ICD-‐10 claims

4.  Review current beneﬁt plans to idenOfy which ICD-‐10 codes match/apply

5.  EducaOon of staﬀ (customer service, claims reviewers) 6.  Assess and ready for new business processes

7.  DSM/ICD Decisions and UOlizaOons

8.  Support dual processing (for old DOS requiring ICD-‐9 and new ICD-‐10)

(43)

Some Of Their To-‐Do’s

•  AdjudicaOon

•  Backwards mapping from ICD-‐10 to ICD-‐9

•  ContracOng

•  Systems upgrades, changes, programming

•  BH Carve-‐Outs

•  NavigaOng MulO-‐Payer Claims

•  Prior-‐authorizaOons and referrals

•  Claim edits

•  Policies

•  Formularies

Every other healthcare provider they oﬀer services to will also be in line

(44)

Payers: Are Challenged As Well

•  Samples

•  #1: Magellans website

(45)

(46)

(47)

Payers: Who Is Doing What When?

•  Everyone is doing something diﬀerent at diﬀerent Omes:

18 payer sources = 18 diﬀerent Mmelines

(48)

What Does All This Mean?

•  Expect changes mid-‐stream and ﬂip-‐ﬂops

•  We are entering a whole new era that will demand:

ü Accountability, Speciﬁcity

ü Demonstrable Progress and Concrete Outcomes

ü Medical Necessity thresholds increasing for our industry

ü DocumentaOon like we have never seen it before

ü Pay For Performance and Outcomes ONLY

ü MedicalizaOon of our industry

ü CoordinaOon of Care

ü An enOre culture shiu in thinking about how we treat individuals with

(49)

Contracts With Payers

•  Review your contract and accompanying fee schedule for any potenOal issues

•  Are you reimbursed based on CPT or diagnosis codes?

•  Look for words like:

•  Reimbursement formulas

•  Usual and customary

•  Fee Schedules – may be aXached separately from the actual contract

•  Covered/Not Covered Diagnoses

•  Language regarding ICD/DSM

(50)

Payer Contracts: What To Ask Them

•  Do you plan to change your reimbursement rates or fee

schedule for ICD-‐10 diagnosis codes?

•  What impact will ICD-‐10 have on coverage policies?

•  Do you plan to re-‐negoMate your contracts for ICD-‐10?

•  Are you going to re-‐negoMate the contracts when they are up

for renewal or prior to that date?

•  What impact, if any, will ICD-‐10 have on our fee schedule?

•  What impact will ICD-‐10 have on your medical review, audiMng,

and coverage?

•  Are there addiMonal diagnoses that you can get paid for?? (i.e.:

(51)

Internal ConsideraOons And QuesOons

1. 

How many payers do you have and what is their

respecOve revenue percentage?

2. 

What pre-‐exisOng claims problems have had with

any parOcular payer? What have your claim denial

rates been with them in the past?

3. 

How have they resolved claims problems in the past?

4. 

What is your Plan B for any parOcular party and how

big will the “hit” be?

5. 

Have contact informaOon: Phone numbers,

instrucOons, name of person handy

(52)

(53)

Your To-‐Do’s Regarding Payers

•  Give thought to asking the Payer how they will compensate you should a delay occur?

•  Have they made arrangements for interim payments if delays become unreasonable?

•  Consider requiring interim payments subject to retroacOve reconciliaOon if operaOons appear to be aﬀected—pull out your contract and see what leverage you may have

•  Appeals, or requests for reviews, will be your burden (Ome, cost) not unlike it is now

•  Recognize that you will get conﬂicOng, erroneous, and misleading informaOon from the Payer and their Provider Service Department

(54)

Assessing Internal Revenue Cycle Processes

•  Who determines the diagnosis code for the claim?

•  Best if the clinician does, not the billing oﬃce, administraOve assistant or

other 3rd_{party; CerOﬁed Coders are the excepOon}

•  Does the clinical documentaOon system provide the necessary

informaOon needed to code the diagnosis to the greatest level of detail?

•  What plans are in place to improve clinical documentaOon and

support the new, more speciﬁc diagnosis?

(55)

Inside The Billing Oﬃce: Denial RemediaOon

• 

Items to Address:

•  Analyze root cause of current denials and address process gaps

•  Improve pre-‐service CerOﬁcaOon and AuthorizaOon requirements

•  Access to contracOng and payer manual updates around Pre-‐CerOﬁcaOon

and AuthorizaOon rules

•  Items to Have Ready:

•  Track claim payment delays and resubmissions

•  Have contact informaOon: Phone numbers, instrucOons, name of person

handy

•  Establish a process of how denied claims get handled

•  May need 1-‐2 FTE’s the ﬁrst 4-‐6 months for this to expedite claim denial

(56)

Audit-‐Based Reimbursement Recovery

•  Tracking how things are going

•  Signiﬁcant disrupOon in clinical documentaOon habits

•  New clinical documentaOon requirements will increase audit-‐ failure rates if the documentaOon does not support the ICD-‐10 diagnosis

•  IF audits reveal a violaOon of the Clinical Coding and

DocumentaOon Requirements, then we have a problem!

•  That said, there is an industry understanding this will be a

(57)

Managing Payers

• 

Track tests, Omelines, payer issues & remediaOon

steps

• 

Realize a manual, Ome-‐consuming review of denial

reasons and resubmissions will be the worst in the

ﬁrst couple of months (thus the noOon of 1 FTE)

• 

Determine eﬀecOveness

• 

Communicate needs with partners

• 

Determine impact to revenue, including changes to

(58)

Every single system that holds, transmits, or analyzes

health data will need to be modiﬁed and tested

•  CMS on TesOng: “TesMng will ensure ICD-‐10 compliance across

internal policies, processes, and systems, as well as external trading partners and vendors”

•  Without thorough internal and external tesOng, you will have no idea

if you will be ready or what will happen to your revenue income auer October 1, 2015

•  Two Key Factors:

•  a) Can you connect AND exchange ICD-‐10 informaOon?

•  b) Can the payer handle, adjudicate, and process the claim

correctly?

(59)

TesOng And Risk MiOgaOon Strategies

Test

representaOve sample

Use diﬀerent code combinaOons (SU/

BH/primary-‐ secondary dx’s)

Emphasize tesOng with large pay

source Test diﬀerent

provider types (MD, aide, etc.)

Test per diems, bundles, individual

CPTs, etc.

Waterfall/ crossover billing

Ensure YOU can test (some restricOons here)

IncorporaOng the DSM in the system

(60)

CMS And “End-‐to-‐End” TesOng

•  CMS has run a series of tests to assess the state of readiness in the industry: Sample claims submissions to see how they are processed and adjudicated

•  So far, the results are encouraging:

•  81% of the claims were processed without problems

•  3% were denied for having an ICD-‐9 code on them

•  3% were denied for being an invalid submission of a ICD-‐10 diagnosis or

procedure

•  13% were denied because folks could not ﬁgure out how to set up the

test claims

•  What we don’t know: how many of these orgs were in our industry?

(61)

Lessons Learned From End-‐to-‐End TesOng

Providers are confused about when to use ICD-‐9 codes versus ICD-‐10 codes on claims

Providers are not using the correct ICD-‐10 codes, possibly due to using insuﬃcient diagnosis coding resources or uOlizing resources that contain errors in them

There is a high likelihood that you will experience some

percentage of rejected claims auer October 1, 2015 and the denial reasons will be numerous

(62)

Final Revenue Cycle Thoughts

•  How will the new ICD-‐10 codes align with exisOng contracts and reimbursements, billing and coordinaOon of beneﬁts

•  How will the new codes aﬀect consumers?

•  Eligibility and uOlizaOon management: Eligibility terms will need to be conﬁgured, medical necessity, policy checks and associated protocols will have to be updated to uOlize ICD-‐10 codes

•  Eliminate any “backlogs” prior to October 1, 2015

•  Quickly idenOfy enOOes with high rates of denials or rejecOons

•  Quickly idenOfy systems funcOonality problems brought to your aRenOon

(63)

The Rule

Claims for services provided on or aaer

October 1, 2015 must use ICD-‐10-‐CM

for diagnoses

CMS will not allow for any grace

period or extension. Non-‐compliant

claims will be rejected and will need to

(64)

Staﬀ Training ConsideraOons

Who, What,

When

Onboarding New

Staﬀ

Clinical

DocumentaOon

Improvement

(65)

Who Needs The Training?

Clinicians/Medical Billing/Revenue Cycle Intake / RegistraOon / _{Pre-‐CerOﬁcaOon}

Compliance/Quality (data collecOon, reporOng, other requirements)

What is a Mouse? How do I…..???

Pre-‐exisOng struggles with diagnosing or

(66)

When: Time The Training

•  When will dual coding and tesOng begin?

•  Recommend training 2-‐4 months prior to tesOng and dual coding start dates (may need to adjust this as we go along)

•  All training should be completed by July, 2015

•  Allow for peer-‐reviews of processes/documentaOons and diagnosis checks

•  Allow Ome for the revenue cycle tesOng feedback loop and to set up remediaOon plans

(67)

Steps In Se\ng Up The Training Program

•  Gather New Policies & Procedures

•  Clinical documentaOon standards, medical necessity, diagnoses manuals

•  Curriculum (Generally 3-‐4 Segments/Groupings of Trainings)

•  IntroducOon: Include ICD-‐DSM Interface

•  Speciﬁc Diagnoses

•  Clinical DocumentaOon Standards

•  Revenue Cycle Department

•  Develop and obtain materials (crosswalks, other reference materials)

(68)

PracOce: Dual Coding

(clinical and billing)

Peer Chart Reviews

Revise procedures

and be ﬂexible

(69)

Diplomacy Regarding CDI

§

Bad habits are hard to change

§

A\tudes interfere with change

§

Prepare your staﬀ and make this a team eﬀort

§

Acknowledge this is disrupOve to workﬂow

§

Be open to feedback from clinical staﬀ about

what works/does not work

(70)

Chart Review Strategies

Random Samples Most Frequent Diagnoses Known Problem Areas AddiOonal / Refresher Training

(71)

Desk Reference Material OpOons

Customized Internal Crosswalk (Excel)

Substance Use Tools

Clinical DiagnosOc Criteria Cheat Sheets

DocumentaOon Tips/Prompts

(72)

Other ConsideraOons

Training Groups: Size

Oﬀer opOons for sign-‐up due to vacaOons, etc. YouTube/Video tape TransiOon Basics

Group diagnoses for training (childhood, adult, and substance abuse)

Who needs what? Intake/pre-‐cerOﬁcaOon may need general diagnosis sets while clinical will need speciﬁcs

Run a report, extract the 30 most frequently used diagnoses and start with those

(73)

Policies And Procedures

•  Gather all P & P’s that involve:

•  Clinical documentaOon processes

•  Diagnosing

•  Revenue

•  Review, Assess, and Update

•  Decide if you want to include DSM/ICD language, Blue Book

(74)

What To Include In Your New Policy

•  Policy and Scope:

•  This secOon should name the state law and licensure requirements for

your facility

•  Acknowledge HIPAA, CMS, ICD and DSM enOOes

•  Purpose of Policy

•  Speciﬁcally outline your intent here for this policy, why it was created

and the intended uOlizaOon

•  Key Procedures and Revisions

•  Specify how staﬀ will handle the ICD-‐DSM dilemma

•  Responsibility

(75)

A Final Word…..

Ø This is an opportunity

Ø Improve documentaOon, review processes, standardize

Ø Build cohesiveness and alignment among everyone

Ø Look to your ICD-‐10 TransiOon Team

Ø Realize this is new for everyone

Ø Goals:

Ø Get through this with minimal revenue cycle disrupOon

Ø Improve organizaOonal best pracOces

(76)

Clinical Decision Support Logic

Other internal logic in place? HIE eRX Lab Orders Other? Practice Management Software Clearinghouse (s) Business Associates: electronic exchange of info Enrollment/Eligibility/I nsurance Verification Internal Auditing/Compliance Department

Reporting: State, other Public

Health/Syndromic Surveilance

(77)

Other Interfaces involving ICD-10 items Any other databases affected?

Metrics or Dashboard Implications

Consumer Portals? List other systems affected below:

(78)

claim remits denial reasons timeframe to correct *appeal process/deadline (do not miss these deadlines) Clinical Diagnoses Submission of Diagnoses Documentation Peer Reviews Interface with claims? Policies and Procedures Responsible party Approvals Staff Training Implications Business Intelligence/Metri cs

list subsytems here Front-End

(79)

Internal Auditing/Complia nce Department Paper Documentation (Superbills, etc) Business Associates Contracts and Service Level Agreements Intake or front-end procedures Receipt of outside records: management? Updating current diagnoses process Other?

(80)

list payers in RANK order and Start with #1 payer, move to #2, etc. Vendor/Payer #1 Vendor/Payer #2 Vendor/Payer #3, etc

(81)

Clinical Crosswalks Workflows Dual Coding

Manuals? Approach? Method? Documentation

Medical Crosswalks

Workflows Dual Coding

Administrative Intake/Pre-Certification Diangoses Only Workflows

Dual Coding

Billing/Revenue Crosswalks Workflows Dual Coding

(82)

document, track, process Clinical Staff Provide crosswalks, reference

Policy and Procedure decisions approved & communicated? Expectation for dual coding? Expectation for clinical documentation threshold? Claim Denial Processes Who is in charge?

Contact information ready? Appeal and corrected claim Payor Contracts Must Be Reviewed!! Other Items?

(83)

EHR Vendor Training Materials collected Vendors Readiness and Timelines

Payers Plans and Timelines

Contract Reviews with both Vendors and Payers Clinical Info/diagnoses

CDI and policies

Risk Mitigation: Id'ng the highest risk areas Testing: Who, When, How

Paper: rewrite superbills,

policies/procedures/other charge-capture Systems Inventory: Who does, by when Denial Processes: Development of a manual or

process

BI/Analytics and Reporting: Who does this/affect?