Ohio Department of Medicaid Clarifies EVV Rules

The Ohio Department of Medicaid has issued clarifications on rules that providers and software vendors need to follow for full EVV compliance. Many are generally in line with Medicaid guidelines, but providers need to be aware of them.

  1. Providers need to ensure the EVV software they use allows clear documentation of all changes to original records (Clock-in/outs) when employees forget or clock at the wrong time. Typically at least 10% of records will fall into this category. Connecting the action of clocking-in/out with getting paid for employees will help maintain a lower rate.
  2. At this point in time the Ohio Department of Medicaid does not plan on interfering with reimbursements if there is a large volume of edits.
  3. Providers need to enter a unique email address for all employees who have authority to edit attendance. This email address needs to be retained for 7 years and never be re-used.
  4. Alternate software vendors now need to demonstrate compliance in person at meetings in Columbus. Currently these demonstrations are being scheduled well into 2020.

More details are available here.

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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Ohio Providers Struggle to Find Approved Alternative Vendor

Ohio has a contract with Sandata to provide a state-wide EVV solution, beginning January 8, 2018. The state claims providers can use their own vendor instead of Sandata, but some providers are finding it difficult to get alternative vendors approved.

Only services provided through the fee-for-service Medicaid program are included. Services reimbursed through a managed care plan are not part of the EVV program at this time.

Programs Affected: State Plan Home Health Aide, State Plan Home Health Nursing, Private Duty Nursing (PDN), Ohio Home Care Waiver Nursing, Ohio Home Care Waiver Personal Care Aide, Home Care Attendant, and RN Assessment