Get the latest updates on state EVV mandates.

The True Cost of State-Mandated Systems

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

Louisiana EVV UpdatesSome 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.

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If your organization uses a state-mandated system, tell us your experiences! Do you have to provide mobile devices and data plans? What other hidden costs have you encountered?

Nevada Yet to Decide Whether Providers Can Continue Using Current EVV Systems

Nevada announced it will mandate a single system for all Nevada providers. However, the state has not decided whether providers who currently use EVV systems may continue to use them instead of the statewide system.

Nevada Medicaid says providers will be able to use the state’s system free of charge. However, many state-mandated systems incur unforeseen expenses upon providers.

The RFP opened to EVV vendors on May 30, 2018. The anticipated contract start date is August 14, 2018.

Virginia Announces Provider Choice Model

Virginia has not finalized its EVV requirements, but it has announced that all providers must choose and implement an EVV system that works for them by January 1, 2019. The chosen system must comply with Virginia Medicaid’s reporting requirements:

  • The system must verify the attendant onsite with GPS or caller-ID
  • The system must maintain records for 6 years

Virginia Medicaid will have several system edits/audits (as detailed in the FAQ):

  • Standard edit processes such as member and provider eligibility
  • Verifying the claim or encounter is supported by and consistent with EVV data
  • Verifying the claim is supported by and consistent with a service authorization
  • Pricing the claim using the appropriate rate for the procedure code submitted
  • Checking for duplicate or overlapping service

Providers will have 60-90 days after the implementation deadline to test and refine the solution.

Why Provider Choice is the Best Choice

So far, the provider choice model (or the open vendor model) is the most successful EVV implementation model country wide. It allows providers to choose the EVV system that best meets their needs and it is minimally disruptive. For the many providers who manage programs that do not require EVV as well as programs that do, the provider choice model enables them to use the same workforce management software across all programs.

However, a few states continue to opt for state-mandated systems. Louisiana, for instance, implemented this model twice only to fail both times. Louisiana finally came around to the reality that every provider has different needs, but not without causing huge disruptions during those first two implementation attempts.

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What are your thoughts on the provider choice/open vendor models? Do you agree that provider choice is the best choice?

North Dakota Wraps Up Stakeholder Meetings

North Dakota held three public meetings for providers to submit input on the upcoming EVV implementation. The last meeting occurred June 5, 2018 – the state has not made any announcements since then.

In February 2017, North Dakota solicited information from potential EVV contract bidders. CMS indicated that North Dakota has chosen the open vendor model, but this information is not confirmed on the state’s websites.

Texas Temporarily Drops EVV Compliance Level

Due to the recent shakeup when Texas chose not to renew its contract with one of the two statewide EVV vendors, the state has temporarily dropped its EVV compliance level. Texas had a 90-percent minimum EVV Compliance Plan score for providers, but has decreased the requirement to 75-percent while providers are transitioning.

DHS states: “Effective June 1, 2018, all provider visits between March 1, 2018 and Nov. 30, 2018 must meet the minimum EVV Compliance Plan Score of 75-percent. The 90-percent minimum EVV Compliance Plan score will resume beginning with visits on Dec. 1, 2018.”

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Texas providers: Has the transition to one vendor affected your agency operations?

Wisconsin Defies Federal Deadline

The Wisconsin Department of Health has taken a stance against the January 2019 deadline for EVV implementation. The state says the deadline is impractical, so it will work with stakeholders and CMS to implement EVV within a more reasonable time frame. DHS has not announced that timeframe, but assures providers that they do not need to take action at this time.

Eventually, DHS plans to establish a single statewide EVV vendor.

Programs Affected: Personal care and home health services, including services provided through Medicaid and BadgerCare Plus fee-for-service, BadgerCare Plus health maintenance organizations (HMOs), Supplemental Security Income HMOs, Family Care, Family Care Partnership, IRIS (Include, Respect, I Self-Direct), and Children’s Long-Term Support Waiver

Oregon Providers Share Concerns about EVV

In a recent stakeholder meeting, Oregon providers and ODDS representatives deliberated extremely tender topics about the upcoming EVV implementation. Providers were concerned about foreseen barriers to EVV compliance and the lack of clarity from ODDS.

Many Oregon providers are already familiar with eXPRS, which captures a lot (but not all) of the information the 21st Century Cures Act requires. To reduce the impact of the EVV implementation, the state plans to expand eXPRS so it is fully EVV-compliant. But providers worry about the cost of any mobile devices and data plans necessary for EVV.

They also presented questions like:

  • How will a PSW clock in/out if the reception is poor or overcrowded?
  • If agencies provide mobile devices to their PSWs, how will PSWs share the devices?
  • Can eXPRS handle even more usage? It is already overloaded at certain times of the month.
  • Will clocking in/out in front of the client blatantly remind the client that he or she is dependent on others for daily activities?

The state tabled most of these topics until the next stakeholder meeting.

Programs Affected

Personal support workers (PSW)

Texas Will Not Renew Contract with EVV Vendor

In 2016, Texas mandated a “modified open vendor model” with two EVV vendors eligible for selection by provider agencies: DataLogic Vesta and MEDsys. MEDsys’ contract ends in November 2018 and HHSC announced it will not be renewing MEDsys’ contract due to their poor services. Providers using MEDsys have until September 30, 2018 to switch to DataLogic Vesta; they must begin the process before July 31st to allow sufficient time.

Alternatively, providers may choose their own system, but DataLogic Vesta must approve it.

Programs Affected: Personal assistance, personal care, in-home respite services

Louisiana on Third Attempt at EVV Implementation

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

West Virginia Plans to Mandate Single Vendor

West Virginia is researching and planning for its statewide EVV implementation, and plans to enter a contract with a single EVV vendor. The state has not yet announced which vendor.

Programs Affected: Hands-on, direct care services, such as those provided by the Aged and Disabled Waiver (ADW), Traumatic Brain Injury (TBI) Waiver, Intellectual/Developmental Disabilities Waiver (IDDW), and State Plan Personal Care Program