Electronic Visit Verification

Today’s Presenters

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Jen Burnett

Damon Terzaghi

Electronic Visit Verification (EVV)

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A technology solution which electronically verifies that home and

community-based services are delivered to people needing those services.

Includes: • Capture: field tracking

mechanisms and devices• Storage: central database for

data and analytics or dashboards

What is EVV?

How EVV Works

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Electronic Check-in:

• Direct care worker initiates a technology-based action that confirms that they have arrived or departed a beneficiary-designated site of service

• Could occur in a residence or an alternate location

• Could leverage the beneficiary’s landline, personal, or agency technology

Telephone timekeeping/ Telephony

Web-based Verification

One-time password generator

Biometrics

EVV Technology

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Global Positioning System (GPS)

State Medicaid Agency

Managed Care

Organization

Provider AgencyBeneficiary

Consumer Directed Care

Worker

Who is Affected

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“ While the aims are noble – reducing fraud and improving quality of care – the practical considerations

of understanding and implementing EVV will be a tremendous challenge for many states, managed care

organizations, providers, and beneficiaries.”

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice State-

Mandated External Vendor

State-Mandated In-House System

Open Vendor

Provider Audit

• Providers select and self- fund their EVV vendor-of-choice

• States can recommend a preferred list of vendors

• Single or small provider agencies may find it technologically or financially burdensome

• States will need a data aggregation system

• May be more beneficial for a state with high EVV utilization among providers

Provider Choice

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CMS’s 5 Design Models of EVV + 1 Additional

• MCOs select and self- fund their EVV vendor-of-choice

• States may set minimum standards for EVV vendor selection and require certain data collection from MCOs

• Applicable to HCBS using MCOs for service delivery

• Providers may require additional administrative support if multiple MCOs use different EVV systems

• States will need a data aggregation system

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice

• States contract with a single vendor for all providers/MCOs

• The state is directly involved in the management and oversight of the program and is guaranteed standardization and access to data

• Providers with no existing EVV system may benefit from efficiencies and negligible maintenance cost

• Providers and MCOs already operating an EVV system will have to adopt a new system

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice State-

Mandated External Vendor

• States create, run, and manage their own EVV system directly, with standardization and access to the data

• Could be built into the existing MMIS structure

• States can hire a contractor/vendor(s) to assist in building its customized system

• States need to consider knowledge, capacity, and financial resources to implement and maintain the model/system

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice State-

Mandated External Vendor

State-Mandated In-House System

• States contract with a single EVV vendor/build their own system, but allow providers and MCOs to use other vendors

• The state-system serves as the default

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice State-

Mandated External Vendor

State-Mandated In-House System

Open Vendor

• States receive funding and maintain oversight

• States will need a data aggregation system

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CMS’s 5 Design Models of EVV + 1 Additional

Provider Choice

Managed Care

Organization Choice State-

Mandated External Vendor

State-Mandated In-House System

Open Vendor

Provider Audit

• Providers to establish EVV; State confirms compliance via audit

• No state RFP or interoperability standards, no state aggregator or data

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• Type of service performed• Individual who received the

services• Date of service• Location of service• Individual who provided the

service• Time at which the service

began and ended

• Personal Care Services

• Home Health

21st Century Cures Act Requirements

• Consultation with agencies and entities

• Stakeholder engagement/ training

Services Verification Elements Implementation

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

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EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 17

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 18

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Increase financial accountability of provider agencies and managed care organizations

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 19

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Recognize growth of home and community-based services

Increase financial accountability of provider agencies and managed care organizations

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 20

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Collect data currently lacking

Recognize growth of home and community-based services

Increase financial accountability of provider agencies and managed care organizations

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 21

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Improve patient and provider safety

Collect data currently lacking

Recognize growth of home and community-based services

Increase financial accountability of provider agencies and managed care organizations

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 22

EVV in the 21st Century Cures Act

Why is EVV in the Cures Act?

Increase Quality Improvement

Improve patient and provider safety

Collect data currently lacking

Recognize growth of home and community-based services

Increase financial accountability of provider agencies and managed care organizations

Deter and reduce fraud, waste, and abuse

Strengthen insufficient controls for monitoring and fraud, waste, and abuse 23

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Program Integrity

Quality

Electronic Visit Verification (EVV) as a FWA and Quality Tool

Web-based Verification

Controls Prohibiting Caregivers

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Stakeholder Concerns

Restrictions to Consumer-Directed

Service Models

Additional Administrative

Burdens to Navigate

Concerns About

Privacy

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CMS’s Role in EVV Implementation

Guidance and Support

Sharing information via surveys, webinars, technical assistance, FAQs, best practices for training individuals who furnish PSC and HH services, sub regulatory guidance, State Medicaid Director letters

Increased Federal Medical Assistance Percentage (FMAP) for systems and facilitating an Advanced Planning Document process for FMAP

Related Oversight

Monitoring national and state-level progress, including implementation timelines

Review and approve APDs

Making adjustments to FMAP globally and as states implement

Promising Practices for Success

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Soft launch with error

resolution to target training

Inventory/identify all

training target populations

Understand the variations of the EVV model used

Establishing a training plan

Train on an ongoing basis

Provider, beneficiary and

caregiver surveys

Use multiple approaches for notification of

training

Stakeholder input,

advisory groups,

public forums

Informational sessions and educational materials

Measurement,reporting, data transparency

CMS 7 Promising

Practices include:

Study period prior to denial

of claims

Other Promising

Practices include:

Assess state resources and

capacity for training

Create various approaches for

customer service

Partner with provider

associations, FMS vendors

User-friendlyand robust

website

Openness to adopting new

technology post implementation

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State Examples

Florida Connecticut

Tennessee Oklahoma

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Florida

• Implemented EVV in 2010 using voice

biometrics and telephony

• Experienced challenges with restrictive

nature of land-line system

• Re-procured system and is implementing a

GPS enabled EVV for PCS

• Separate systems for MCOs and FFS – MCO

choice model & State will audit

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Connecticut

• Stressed stakeholder engagement

• Began EVV implementation in November 2015 with a provider meeting to outline the process and implementation schedule

• Initially delayed rollout due to provider challenges with the system

• System became operational on January 1, 2017, for in-home services that are paid on an hourly basis, and then on April 1, 2017 for home health services

• Uses a single statewide contract with an external vendor

• One system integrated with the existing MMIS vendor

• Providers must use the state contracted system for scheduling, service authorization, EVV, other

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Tennessee

• Implemented MCO choice model in 2010 as part of their MLTSS roll-out

• All three plans initially used same vendor; two plans subsequently changed vendors

• Some disconnect with larger providers who contract with multiple plans/ hard to use different systems for internal scheduling/tracking

• No procurement expenses to providers, but still experienced administrative costs

• Lots of training required

• Concerns about ways to aggregate date: State access vs. timely information for MCO claims

• Created a parallel system through FMS Vendor to ensure that self-direction flexibility and consumer direction was maintained

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Oklahoma

• Piloted in 2009; became a statewide requirement in 2010 as part of the ADvantageWaiver Program (APD waiver)

• Procured an EVV vendor and requires all applicable waiver providers to utilize the state-contracted EVV vendor

• The one-vendor system provides the state with capability to have real-time access to the data input into the EVV web portal through all check-in/check-out methods, as well information regarding providers’ claims and billing at the provider and participant level

• The utilization of the EVV one-vendor system in Oklahoma, allows the state to assist with EVV training, billing and claims resolution and utilize data from a host of reports to assure health and safety of the waiver participants

QUESTIONS?ANY

• NASUAD May 2018 Publication: Implications for States, Providers, and Medicaid Participants: http://www.nasuad.org/newsroom/nasuad-news/nasuad-releases-paper-electronic-visit-verification-hcbs

• CBO publication: “Direct Spending and Revenue Effects for H.R. 34, the 21st Century Cures Act”: https://www.cbo.gov/sites/default/files/114th-congress-2015-2016/costestimate/hr34amendment5.pdf

• Medicaid and CHIP 2015 Improper Payments Report: https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicaid-and-CHIP-Compliance/Downloads/2015MedicaidandCHIPImproperPaymentsReport.pdf

• CMS Training on Monitoring FWA in HCBS PCS: https://www.medicaid.gov/medicaid/hcbs/downloads/hcbs-3a-fwa-in-pcs-training.pdf

• 2012 OIG Portfolio: https://oig.hhs.gov/reports-and-publications/portfolio/portfolio-12-12-01.pdf

• 2011 OIG Spotlight On...Medicaid PCS: https://oig.hhs.gov/newsroom/news-releases/2011/personal_care_services.asp https://oig.hhs.gov/oei/reports/oei-07-08-00430.pdf

• 2010 OIG report: Improper Claims for Medicaid PCS: CMS Booklet titled “Preventing Medicaid Improper Payments for Personal Care Services”: https://www.cms.gov/Medicare-Medicaid-Coordination/Fraud-Prevention/Medicaid-Integrity-Education/Downloads/pcs-prevent-improperpayment-booklet.pdf

Resources

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CONTACT US

JEN BURNETTPrincipaljburnett@healthmanagement.comwww.healthmanagement.com

DAMON TERZAGHISenior Director

dterzaghi@nasuad.orghttp://www.nasuad.org