Tuesday, April 15, 2014

What happened to the Massachusetts exchange?

In the "people's republic of Massachusetts," the Pioneer Institute often gets a bad rap as a conservative think tank.  The Democratic establishment does its best to ignore it, but I have found the Institute to do good work and raise issues in a thoughtful and rigorous manner.

One recent topic followed by the Institute concerns the failure of the Massachusetts health exchange.  Recall that this exchange worked quite well for years before the Accountable Care Act, but then it went into a tailspin during the compliance process for the new law.  Analyst Josh Archambault notes:

As a result of the failed Connector website, 160,000 Massachusetts residents are on temporary public Medicaid coverage even though they don't qualify for MassHealth. Failure at the Connector will cost Massachusetts taxpayers over $100 million dollars this year.  So, Pioneer has questions about how Massachusetts went from having a well-functioning Exchange to one of the worst performances of any state in the Union.

This week legislators on Beacon Hill are finally convening a second hearing in the seventh month since open enrollment started under the ACA, on the failures at the Connector.

This follows a recent Congressional hearing featuring the executive director of the Connector, and a February hearing in Boston where legislators simply vented at officials from the Commonwealth.

Yet, even with these two hearings, little information has been released to the public on how the state got into this mess in the first place.

Pioneer asks 100 questions that it asserts, "need to be answered regarding just what happened during implementation"  I include the first 43 here for your perusal.The kinds of questions raised by Josh are essential to conducting a root cause analysis to understand what went wrong, in the hope of doing better on this kind of project in the future.
  1. Why did the Commonwealth decide to completely rebuild its website exchange? Why did it not work off the foundation of its old website?
  2. Why did the University of Massachusetts Medical School hold the contract for the exchange development? Did the Connector and MA HHS shape the Early Innovator Grant application?
  3. Why were the University of Massachusetts Medical School principal leads on the contract both policy experts, not technical experts?
  4. What was the bidding process that led to the selection of CGI? What factors were considered?
  5. What other companies bid on the contract?
  6. What state employees provided technical expertise to design the website contract?
  7. Were any of the website contracts granted on a sole-source basis?
  8. Why did the state's IT department (ITD) play a limited role in implementation and contracting?
  9. It is clear to outside auditors that the original deal with CGI was too ambitious. Did state employees or CGI include the level of bells and whistles in the original contract? 
    (Background: The promise was a Rolls Royce exchange.)
  10. Problems arose early with conversations about scaling back the original contract starting as early as January 2013, when did serious problems first start to emerge? 
  11. How quickly were issues escalated and to whom? What exactly was the escalation process? 
  12.  When did senior staff at UMass Medical School first know about the problems? 
  13. When did Connector senior staff first know about the problems?  
  14. When did Mass HHS senior staff first know about the problems?
  15. When did the Governor first know about the problems?
  16. When did the CMS state officer assigned to Massachusetts know about the problems?
  17. How frequently were these groups updated about the depth of the problems with the website?
  18. Is there a precedent for reworking IT contracts multiple times in the Commonwealth during such a short engagement?
  19. What are the guidelines for reworking state contracts? Were they followed?
  20. Technical staff under contract with UMass Medical were removed from quality review committees because of their critical assessment of CGI's work, why?
  21. Independent reviewers criticized the Commonwealth for being understaffed in multiple areas of this project, and for high staff turnover, why was this the case?
  22. Best practices for project management were not followed. Which were not, and how will things be different going forward?
  23. Why was no firm pull the plug date set for the project?
  24. When was the decision made to go live, even with the well-known lack of basic functionality?
  25. What percentage of the website was expected to be functional on October 1st?
  26. What percentage was functional on October 1st?
  27. Why did the Connector spend significant advertising money in mid-October to increase traffic to the website with all of the known issues?
  28. Why were the Governor and other senior Connector staff denying that the website had major problems until early November 2013?
  29. Was it ever discussed to simplify MassHealth (Medicaid) eligibility rules during the design process? 
    (Background: Massachusetts has over 250 eligibility rules, and has added enormous complexity to the site design.)  
  30. Did state officials mislead the Federal government on the progress of the project at any point? 
    (Background: Independent reports have noted that code was often submitted with limited to no testing, and the Committee on Oversight has raised questions about security protocols being followed during the entire project.)
  31. Were security agreements signed by state officials truthful for the level of security provided by the website to users?
  32. (Background: As one example, a Minimum Acceptable Risk Standards for Exchanges agreement was signed by the executive director of the Connector and the HHS Secretary in September 2013. Yet independent auditors in September listed the lack of a testing schedule to determine the basic security of the system as a major concern. The Chairman of the U.S. House of Representatives Committee on Oversight has raised security concerns about the state connecting to the federal data hub.)  
  33. What was the standard of proof required by the federal government for the state to pass each "gate review" for the readiness of the site?
  34. Why was the Commonwealth habitually slow in turning around the review of CGI code?  
  35. How many citizens have paid for their plan and still lack an insurance card? 
    (Background: At one point the number was over 2,200)
  36. Why were there no basedlined deliverable and baseline dates updates as the project progressed? (Background: Independent auditors document a lack of baseline in August 2013, with the last being submitted in February.)
  37. How many staff who worked on the UMass Medical School contract have been moved over to other departments or contractors still working on the project?
  38. Why was CGI allowed to change delivery dates without consulting state officials? (Background: This has been a criticism by independent auditors.)
  39. Why were changes to the project allowed "without formal approval and assessment of downstream impacts.."? (Background: This has been a criticism by independent auditors.)
  40. Once the severity of the technical problems became overwhelming, why was contingency planning understaffed by both the Commonwealth and CGI? (Background: This has been a criticism by independent auditors.)
  41. Why was the site allowed to go live without any UAT (user acceptance testing), a standard for any IT project?
  42. When did CMS grant the Commonwealth a delay for testing under the CCIIO Blueprint Test Scenarios? (Background: Independent auditors have noted the state missed the 8/23/2014 delayed deadline.)
  43. Why was there no "formal method for holding individuals and organizations accountable for achieving agreed-to deadlines for project tasks"? (Background: This has been a criticism by independent auditors.)
  44. Why was it announced to the public that CGI was being "fired" before the state had developed the terms of that separation? 


Anonymous said...

This sounds like pretty much a carbon copy of what went on in Maryland, minus the exchange having existed beforehand. The entire thing was scrapped and its head honcho fired, again at great cost to taxpayers. Now we are importing CT's system because it worked.

The tale of two cities (or many states) as to why some states' exchanges worked well and some bombed, is a worthy root cause in itself. It would be interesting to see what the failed states and the successful states had in common in their respective categories.

nonlocal MD

Robert said...

My daughter and family reside in Marshfield. They were thrown off of their insurance plan and now await coverage with a backlog of 55,000 families ahead of them. What a disgrace!