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According to Sandata CEO Tom Underwood, there are four models that states might use to implement Electronic Visit Verification, which every state must do by January, 2019 to comply with the 21st Century CURES Act. Three of them lead to failure. We sat down with Underwood after his standing-room-only presentation for the Home Care Association of Florida last month.
The CEO defined EVV as "a modular technology solution that provides transparency into home-based care delivery, supporting provider network optimization while improving the member's quality of care." Typical EVV systems include a scheduling module and a visit verification module, usually using a mobile phone or the patient's phone, though a fixed EVV device is another option.
In December 2016, President Obama signed into law a bill mandating EVV implementation in home care but giving each state leeway in how to comply. Underwood identified four models that have emerged so far among the 18 states that mandated EVV before the CURES law required it.
Model 1: Provider Choice
In Washington, Missouri and New York, the state requires the provider community to self-fund, select and implement an EVV solution of their choosing, generally by a required deadline. Some states have offered a preferred vendor list from which providers select one, while other states have simply established a minimum set of standards for vendor product features. Along with standards, some states also require a minimum set of reporting on EVV activity.
Conclusion: Not recommended.
Model 2: MCO Choice
In New Mexico, Iowa and Tennessee, MCOs that manage Medicaid beneficiaries select and implement an EVV solution from the vendor of their choosing. States may set minimum standards for vendor product features and require a minimum set of reporting on EVV activity.
Conclusion: Not recommended.
Model 3: State Choice
In Alabama, Connecticut, Illinois, Kansas, Mississippi, Oklahoma, Oregon, Rhode Island, Texas and South Carolina, the state Medicaid program contracts with a single -- or sometimes two or three -- EVV vendors and mandates that all provider agencies must use that vendor's system.
Conclusion: Mixed. Least costly for the state and smallest home care providers. Bad news for providers with existing EVV systems in place.
Model 4: Open Vendor Hybrid
In Ohio and Florida, beginning next year and this fall, respectively, a new, hybrid model is being tried. It allows the state to select a vendor to provide EVV solutions while allowing all providers and MCOs that already have a system in place to keep their existing system. Providers without EVV already implemented can select the system that best suits its needs.
In this model, States establish the technology requirements and configuration, rules and policies regarding the program, and purchase an EVV system on behalf of and at no cost to their Providers who do not currently have an EVV system of their own. States that offer this elect to “open the model” to third party EVV systems. In this Open EVV Model, once a visit is completed, a vendor agnostic Aggregator system takes in data from all EVV systems and applies standardized business rules to ensure the visits are properly verified and ultimately paid, generates alerts as needed and provides comprehensive oversight over the entire program – regardless of EVV system used.
Conclusion: Highly recommended, provided measures are put in place to keep all state MCO partners on the same EVV system.
Underwood's strong feelings about the pitfalls of the first three models should be heeded by state Medicaid officials who are currently researching their options. No EVV CEO has had interaction with as many state Medicaid offices, no EVV vendor has tried as many different models and learned, sometimes the hard way, what works and what does not. He concludes his presentations, and emphasized to us, the same admonition.
"Each state must carefully evaluate its unique environment in order to select the EVV model that is right for its own program while complying with the new mandate. Factors to consider include concerns impacting fraud, waste and abuse, impacts to the provider network, overall service quality, and how states are using Managed Care companies to deliver services."
Next week, this series continues with part 2 of our interview with Tom Underwood, Sandata's summary of each models based on how favorable they are to the state using the following measures:
Compliance: Measured in terms of rate of adoption of the mandated EVV technology
Cost: Cost to the state to implement (assumes enhanced federal match of 90%)
Business Burden: How much time and effort the state must expend to implement and manage the program
Ease of Implementation: How easy or challenging is the program to implement on a statewide basis
Outcomes: How much savings will the state expect to recoup based on impacts to fraud, waste and abuse.
Editor's note: readers are urged to be our eyes and ears in their own state. When you learn of hearings or decisions made, or just that a state official is leaning in a certain direction, please let us know. email@example.com
©2017 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. firstname.lastname@example.org