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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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?