Over the past year, the Ohio Council for Home Care and Hospice has been advocating for the state Department of Medicaid to make changes to its Electronic Visit Verification system. This month, OCHCH announced that those efforts have produced some results. A report summarized four areas:
- How EVV impacts HIPAA
- ODM led “EVV Lab” at OCHCH’s Center for Excellence
- Implementation and Rule Delay
- Changes to EVV edits
We have posted the entire, unedited message to OCHCH members elsewhere in this week's issue. To deepen our understanding, we spoke with Joe Russell, Executive Director. A former lobbyist, Russell summarized our lengthy conversation with one piece of advice to his counterparts in other states:
"Get to know the people in your state's Medicaid office, starting with the ones designing your EVV plan. Engage early. Engage often. Make friends with the state people. Make sure they know you want to work collaboratively to achieve the best outcome for patients, providers, and their budget."
He added that he was appointed OCHCH Executive Director less than a year ago, after the planning process was already well along. "I don't like to be reacting after the fact and asking for changes," he told us. "I prefer to be helpful to the process from the beginning."
Along with his advice to colleagues, Russell recounted the policy message he had given Ohio Medicaid providers. We all have to work collaboratively with officers in the Ohio Department of Medicaid, even if we are not completely in agreement with what they are doing. Our fear is, if their plan does not work out well, we would be blamed for sabotaging it because they know we are not happy with what they are proposing."
To avoid the appearance of sabotage, he added, "We told ODM that we had some major concerns but wanted to make it work. Since then, our relationship has been good. They have listened to our proposals, even though they have not proposed changes of their own after hearing our concerns."
One of the positive things that came out of these discussions was a series of "EVV Summits," which are attended by OCHCH members and ODM officials. The first summit was held last December and, in Russell's words, was a big success. "Our members saw what ODM wanted and they saw what our members wanted. We brought up five points and, though their team did most of the speaking, they walked through each point and let the audience ask questions."
At the second summit, ODM director Barbara Sears attended. "What an eye-opener that was for her!" Russell said. "Those conversations have led to more and more support from ODM staff. Today, they meet monthly with our EVV stakeholder group." The whole premise of the summits, Russell added, is based on "if this doesn't work, it's not going to be because home health providers were not ready or did not have enough support to get ready."
The former lobbyist was quick to add the political dimension. "EVV is a federal mandate to be carried out by each state," he explained. "We didn't want to derail the intent of the rule because that would only have resulted in ODM being penalized. And we would still have to implement EVV."
Specific provider issues with Ohio plan
Russell outlined for us the components of the Ohio EVV plan his members would like to see changed.
- Tying EVV to billing. This mandate has already been discarded after OCHCH members convinced ODM regulators that it can take a caregiver up to four minutes to access the system and register her arrival at a home after knocking on the door, and her departure after completing her tasks. Requiring billing hours to match EVV in and out times turned out to be completely unworkable. "Take those 8 minutes per visit and multiply them by hundreds of visits per week and an agency is suddenly losing substantial revenue," Russell said. The state's solution was to require EVV data to correspond to billed units, not to precisely match clock time.
This, Russell emphasized, solved one problem while creating another. "ODM is paying all claims today but letting providers know if a claim would not have been paid because of an EVV discrepancy. This is great, educational for our members, but when they switched from matching clock time to matching units, that programming change disabled their ability to know -- and to tell a provider -- why a claim would have been denied. They only report now that it would have been denied, not why, making the service useless.
- Vendor choice. The plan calls for Sandata to act as data aggregator, receiving EVV data from other vendors and compiling it so that state systems receive data in only one format. The problem is that ODM must approve every vendor wanting to do business with Ohio providers. "The specifications imposed on EVV vendors are quite technical," Russell told us. "So much so that it is not clear exactly what they are looking for. Some vendors have been approved and others are still wading through the 90-day process. And they will not tell us how that process is progressing."
Russell elaborated on this issue. "Now, the 21st Century CURES Act allocates money to states for implementation and training on EVV requirements. The amount of money a state can receive, however, appears to be tied to the number of providers electing to use the preferred vendor, the one acting as data aggregator. Is the state doing things to encourage more people to use that system? We do not know for sure."
- Cost. The way the state contract is written, Sandata's basic EVV system is underwritten by state funds and free to providers. However, the basic system does not include Sandata's scheduling or billing add-ons. Those must be purchased from Sandata. Many providers are reasoning, "if I have to spend money to get a full-featured system, I might as well consider all my options." Other vendors receiving ODM approval so far include Alora Health, McKesson (Change Health), MaximCare Mobile (for Maxim branch staff), Celltrak, ContinuLink, Rhinobill, Ampersand International, and Maxim. Some of these are standalone EVV systems, others are embedded into EMR software and only available to users of that EMR.
- The GPS issue. Ohio requires GPS to confirm EVV even though the federal law does not. "There are three problems," Russell began. "Most of our people are using telephony for EVV and, of course, there is no GPS on a patient's landline telephone. Second, the disabled community is giving us pushback about 'the world knowing where I am.' They are fearful, feeling vulnerable, about their GPS location being shared via a computer system they do not trust. Lastly, our members are reporting occasional, wildly inaccurate GPS data, such as a person in Columbus being told he is checking in from Cleveland -- that kind of inaccuracy."
- The devices. To offset device and data plan costs that are typically born by providers in other programs, ODM elected to deploy stripped-down mobile devices kept in each patient's home. CEO Tom Underwood told us the devices are being widely used by caregivers in Ohio. He added that they have the potential to add significant value to care deliver, far beyond the six data elements required by the CURES Act. One examples would be capturing health status changes, relaying that status to a case manager, and potentially avoiding an ER visit or hospitalization.
Still, Russell reminded us, they are essentially cell phones and subject to all the maladies every cell phone suffers from: not being charged, getting lost or broken, or simply not working at times. "Anything that can happen to any other mobile device has been happening to these Mobile Visit Verification devices," Russell concluded.
Joe Russell had a lot more to say when we ran out of time for this interview. He does, however, make the offer that his peers at other state associations are welcome to contact him. He will be happy to prepare them to work collaboratively with their own state Medicaid officers.
©2018 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