Who Approves Alternative EVV Systems?

June 21, 2018/1 Comment/in Colorado EVV Updates, EVV Updates, Florida EVV Updates, Indiana EVV Updates, Louisiana EVV Updates, Missouri EVV Updates, Nebraska EVV Updates, Ohio EVV Updates, Texas EVV Updates, Virginia EVV Updates /by Carolyn Dingee

Providers who supposedly have the freedom to choose alternative EVV vendors over state systems are starting to wonder whether the process is actually feasible.

Some states have chosen a “hybrid” implementation model, in which providers may use the free state-contracted system or another system that meets requirements. This solution serves to mollify providers who are unhappy with the state system, but some of those providers find it nearly impossible to get an alternative system approved.

Ohio, for example, has a contract with Sandata to provide a state-wide EVV solution beginning January 2018. The state claims providers can use their own vendor instead of Sandata. However, providers who start that process are connected with a Sandata representative. The state offers an “EVV Provider Hotline” which directs to Sandata. Emails to EVV@medicaid.ohio.gov receive replies from Sandata. In other words, Sandata has the ultimate power to approve or deny competing vendors.

The situation in Texas is similar. DataLogic Vesta, which operates the statewide system, must approve any alternative EVV system that providers want to use. Will DataLogic Vesta’s profits suffer if it approves alternative vendors? If so, will the company let any other vendor take away its customers without an extremely burdensome process?

Lack of Clarity in Some States

Many other states do not clarify which organization or agency approves alternative vendors. In Louisiana, Florida, Indiana, and Nebraska, alternative EVV systems must integrate with the statewide system. It is not yet clear how straightforward the integration requirements are.

The difficulty in predicting problems providers might face is that each state implements EVV in a different way, even if it uses the same vendor as another state. Colorado, like Ohio, has a contract with Sandata for a statewide EVV system, but that doesn’t necessarily mean the situation is identical. Colorado says providers are free to use any EVV system they choose, as long as it meets federal guidelines and is capable of communicating with Sandata through a data aggregator. The state does not specify whether Sandata needs to approve the alternate system.

Good Examples of Provider Choice

A few states appear to have a relatively easy approval process. Virginia declared that “Virginia Medicaid does not and will not approve EVV vendor systems…it is the responsibility of the provider to ensure that it meets Virginia Medicaid’s requirements.”

Missouri says it will obtain “a vendor neutral aggregator system to compile all data” from providers’ various EVV systems. The aggregator system “will allow the state to maintain quality oversight while providing flexibility in vendor selection.”

Louisiana Providers Shoulder Unnecessary Costs

June 19, 2018/3 Comments/in Louisiana EVV Updates /by Carolyn Dingee

Louisiana providers are struggling with the costs of the state’s EVV requirement. Although the 21st Century Cures Act allows telephony to verify visits, Louisiana declared that providers must use mobile devices with GPS functionality. And, whether they use the state system or an alternative one, providers must bear the cost of the technology themselves.

Some providers, especially those with many employees, expressed apprehension about the massive cost of the mobile devices. On March 23, 2018, the Department of Health answered these concerns saying: “The state is providing the EVV system free of charge to providers. It is set up to be accessed from a device with internet access (smart phone, tablet, or computer). A provider agency who decides to provide the device for login should consider getting one device per participant, not per DSW.”

The state has not taken any further steps on the matter. Providers that do not spend what is necessary to comply with the EVV mandate may receive Medicaid reimbursements.

The True Cost of State-Mandated Systems

June 19, 2018/0 Comments/in EVV Updates, Louisiana EVV Updates /by Carolyn Dingee

As organizations and associations debate the various EVV implementation models, provider choice is strongly preferred across the board by providers who don’t want to get stuck with a limited and out-dated state system. Nevertheless, some states procure a state-mandated system without allowing alternative vendors. The only benefit for agencies in this model is that the system is free. But as it turns out, even that isn’t quite true.

State-mandated systems carry many hidden costs. The top three, according to agency feedback, are devices, inefficiency, and redundancy.

The Cost of Devices

Some states choose to put the cost of devices on the provider. Louisiana providers have no choice but to use the statewide system, which itself is free but requires mobile devices to function. Providers must bear the cost of the mobile devices themselves. And not just the devices, but also the data plans to operate them.

To manage this requirement, some providers use a BYOD (bring your own device) policy. However, a Louisiana provider told MITC: “We are losing seasoned staff who are very good at their jobs because they cannot afford the device and data plan required. Instead of being able to focus on the service provided they feel overwhelmed.”

The Cost of Inefficiency

According to reports from providers, most of the state-mandated systems are inefficient. They rarely have strong reporting capabilities, lack payroll integration, comprehensive training, or even documentation capture. They don’t integrate with other workforce management tools like scheduling software. These shortcomings raise the likelihood of errors like under- or over-billing.

The Cost of Redundancy

A lot of providers manage multiple programs – some are required to use EVV and others are not. When providers have a state-mandated system for some of its programs, they must use another system for their other programs. This causes an immense load of redundant data entry. Payroll, in particular, is a nightmare!

Most providers prefer to use the same software vendor across all programs. When states allow providers to choose an EVV vendor, they can often use their existing software or find something that works for the entire agency. But when states mandate a vendor, a lot of providers are stuck using two systems. As a result, they have to pay more overtime or hire people to complete all the extra work.

Louisiana on Third Attempt at EVV Implementation

May 1, 2018/0 Comments/in Louisiana EVV Updates /by Carolyn Dingee

The first two times Louisiana mandated EVV, the state selected a single vendor that all providers were required to use. In 2013, the state contracted with Sandata and in 2015 it contracted with First Data. Both attempts ultimately failed. Now, Louisiana is again implementing EVV to comply with the 21st Century Cures Act, but it is taking a different approach.

Louisiana contracted with LaSRS for a statewide EVV system, but is allowing providers to use another system as long as it integrates with LaSRS. Effective May 1, 2018, any providers who do not comply with the EVV mandate — including those who manually enter data into LaSRS — will receive corrective action. The state made it clear that non-compliant providers may not receive reimbursement for billed services.

Programs Affected: HCBS direct-care services delivered outside of the home, including center-based, vocational, and transportation services