Social Security Number Removal Initiative: Is Your Policy Being Accurately Tracked and Updated?

October 9, 2017

The government constantly makes policy changes, particularly when it comes to the healthcare industry. One of the many policy changes underway is capturing the attention of the entire nation—the Social Security Number Removal Initiative. This initiative—the act of removing all Social Security number information from healthcare data— is a result of the CHIP Reauthorization Act of 2015 guidance to “ensure that a Social Security account number (or derivative thereof) is not displayed, coded, or embedded on the Medicare card issued to an individual […] and that any other identifier displayed on such card is not identifiable as a Social Security account number (or derivative thereof).” This requirement must be completed by April 2019. In addition, a recent GAO report suggests that federal agencies over-collect and over-use Social Security numbers, therefore putting people at risk of identity theft.

Keeping up with these changes to protect the identity of all American Medicare beneficiaries is a heavily burdensome process, and implementing a change is not an easy task. To address pressing challenges like this, LMI developed a suite of tools and processes to help effectively manage the change in policy, allowing policy makers to

  • quickly find all instances of relevant policy language,
  • accurately estimate the scope of policy change impacts on various documents,
  • effectively assign, track and manage language changes to these documents, and
  • ensure all relevant policy has been updated accordingly.

LMI developed OpenPolicy™ to organize and search complex documents using a customizable thesaurus. When a policy such as the Social Security Number Removal Initiative is to be introduced, the system quickly generates a report of every instance of the relevant language down to the paragraph level. In seconds, OpenPolicy™ can search for variations of “Social Security Number” across the entire Code of Federal Regulations (CFR) and the U.S. Code, more than 250,000 pages of written prose. This is delivered at a level of granularity allowing for quick action.

To launch the OpenPolicy™ search service, LMI first imports a context-based thesaurus that enables simultaneous searches on synonyms, alternate spellings, acronyms, and abbreviations. Then, by co-mingling documents and indexing them against the thesaurus, a user is able to sort through vast amounts of content via OpenPolicy™, achieving search results in seconds. Results are displayed and exported at the paragraph level with a corresponding tracking of the paragraph's origin. By enabling OpenPolicy™ search of the 50 CFR titles, we reduce the user’s search time by more than 90 percent, eliminating the need to find the specific reference, download and open the document, and conduct a document search.

OpenPolicy™ is coupled with other processes, such as LMI’s highly customizable, web-based agile workflow management service, so that policy change requirements can be best located, analyzed and detailed, managed, and implemented based on your organization’s needs.

Our agile approach enables customized dashboards that display easy-to-interpret change updates for policy administrators, and it allows us to maintain versioning of policy documents and supporting collaboration artifacts. Determined by the type of policy changes, the service can assign actions to the appropriate individuals and prompt them to review and approve the policy changes, making the change to the document right in the workflow management service to avoid version control issues.

LMI’s agile policy change method and tools illustrated here enable stakeholder collaboration, traceability, and version control for the duration of the policy change process. Policy stakeholders have continuous access to OpenPolicy for research and report generation, and our workflow service for tracing and tracking policy change requests.

Figure 1: LMI’s method reduces the burden on government by eliminating the need to search, organize, and manage changes to various policy documents themselves, allowing the opportunity to focus on the major issues at hand.

LMI has been helping government agencies to manage policy changes since 1961. Our project team has the tools and the subject matter expertise to undertake the most complex policy changes, from comment categorization and workflow management to detailed search results and version control. We can help your team map out the policy change process customized to your work environment and culture.


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