When Rounding Rules Differ Between Billing and Payroll

In some states with EVV mandates, providers are losing money because they must pay their employees more than than can bill for. This happens when rounding rules in the EVV legislation differ from payroll rounding rules set by the labor department.

Most programs will only pay for services in 15-minute increments, but EVV solutions capture exact clock-in/out times. This means that if a caregiver clocks out at 11:14, the provider may not be allowed to bill the last 14 minutes – even though DOL regulations require the provider to pay the employee for those minutes.

Recapturing “Missing” Minutes

“Missing” minutes are those extra minutes that do not add up to a billable unit. While some states don’t allow providers to capture “missing” minutes, Missouri does. The state’s EVV legislation says:

“In no way shall this rule prohibit the
vendor/provider’s ability to accrue partial units pursuant to 13 CSR 70-91.”

The Missouri Department of Social Services says providers may let these minutes accrue until they add up to billable units. For example, if a caregiver works 143 minutes in a billing period, the provider will bill 9 units and rollover 8 minutes to the following period.

Unfortunately, providers who cannot rollover minutes to the following billing period must find creative ways to reconcile rounding discrepancies. For example, an EVV system like Agency Workforce Management warns employees to not clock-out before a unit is complete. The system may suggest that the employee wait a few more minute to clock out.

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Does the EVV legislation in your state include different rounding rules? How do you avoid paying for more than you can bill?

Who Approves Alternative EVV Systems?

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 EVV UpdatesOhio, 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.

Texas EVV UpdatesThe 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.

Colorado EVV UpdatesThe 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

Virginia EVV UpdatesA 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 EVV UpdatesMissouri 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.”

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Has your organization chosen to use an alternative vendor? What was your experience? Let us know in the comments!

Missouri Favors Providers in EVV Re-Implementation

Missouri started using a form of EVV in 2016, but it does not meet all the requirements in the 21st Century Cures Act. So to comply with the law, Missouri has chosen to implement the open vendor model, allowing providers to choose their own systems and aggregating the data from these systems. The EVV systems must meet the requirements to interface with the aggregator.

Missouri is still in the planning stages of this solution. The state has not chosen an aggregator system yet.

Programs Affected: Services authorized by the Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS); PCS authorized by the Bureau of Special Health Care Needs and the Bureau of HIV, STD and Hepatitis of DHSS; and those authorized by the Department of Mental Health (DMH), Division of Developmental Disabilities (DD)