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Two weeks ago, we printed the testimony of Ohio Council for Home Care and Hospice Executive Director Joe Russell regarding his state's chosen model to implement Electronic Visit Verification as mandated by the 21st Century CURES Act (see sidebar below). Ohio's model is controversial because, Russel testified, it places a burden on providers that have already implemented EVV in advance of the mandate, especially those using a vendor other than the one with which Ohio contracted to coordinate the mandated system.

We also printed a rebuttal to Joe's testimony by Sandata CEO Tom Underwood. He asserted that the Ohio system, supported by Sandata's technology, is centered around the principles of Provider Choice and Provider Involvement. He added that some of Joe's testimony was based on older information and that therefore some of his concerns were no longer at issue.

In our continuing effort to explore a topic that impacts so many of our readers, this week, we sought out the opinion of the CEO and technology partners of longtime EVV vendor Dial-N-Document. Don O'Rourke, CEO, introduced us to Prime Care Technologies, a Duluth, Georgia-based provider of flexible hosting, managed services and cloud-based software solutions since 2003. CEO Jim Hoey, COO Carl Mickiewicz, and Technology Solutions VP Russell Hertzberg talked to us in detail about a "Data Aggregator Service" model as a solution to CURES Act compliance.

Interestingly, this is variance to the 4th model described to us in detail by Tom Underwood last spring. (See HCTR, Aug. 16, 2017, "Four EVV Models States Might Choose; Three Lead to Disaster")

Prime Care Technologies’ model has an important distinction from Underwood's 4th model. It is better described as a separate, 5th model, where the state does not select an EVV system but rather requires providers to select an EVV system already in the marketplace that conform to state requirements. It requires EVV vendors to conform to, and pay for, interface specifications jointly developed by the states and Prime Care Technologies.

The state pays for the ongoing maintenance, support, and enhancements to the Repository and Aggregation services. No state-sponsored EVV system; minimal changes to EVV software solutions already in the state; no replacement or training costs to providers or MCOs that are already using an EVV system.

Prime Care Technologies' state-centric, Neutral Cloud Repository and Aggregation Model accepts EVV data from any vendor and delivers it to any state Medicaid system in that state's specified format. According to Hertzberg, this means skilled and non-skilled healthcare at home providers mandated to deploy EVV may continue to use their current EVV systems as long as their vendor implements the simple, flexible, open systems interface sponsored by PCT. He listed additional advantages of the aggregator model for us:

  • Providers avoid retraining costs, efforts and associated disruption of changing vendors
  • Multiple EVV vendors use a single repository
  • Providers reap the benefits of competition among EVV and EMR vendors, who will continue enhancements
  • Competitive pricing is established by each vendor rather than state mandate
  • Multiple state agencies may use the single, master EVV repository
  • Data silos are eliminated
  • Provider data can be analyzed and benchmarked by the state
  • Claims data can be integrated
  • During the four-phase implementation, eligibility data can also be included

About Prime Care Technologies
PCT has worked with a number of EVV vendors to promote the Aggregator model, including Dial-N-Document and CareWatch and the EVV Standards Workgroup for Home Care. Since 2003, the company has equipped healthcare providers, payers, and state agencies with flexible hosting, managed services and cloud-based software solutions that continue to evolve based on the ongoing needs of healthcare related service delivery. Based in suburban Atlanta and with a staff of 150, the company has deep experience in multi-vendor interoperability. Services include data integration from over 70 healthcare applications into the leading data warehouse in Long Term Post-Acute Care; 3,500+ EDI payer integrations, and technology-driven solutions installed in more than 6,500 customer locations in 47 states.


21st Century CURES Act on EVV

(6)(A) In the case in which a State requires personal care service and home health care service providers to utilize an electronic visit verification system operated by the State or a contractor on behalf of the State, the Secretary shall pay to the State, for each quarter, an amount equal to 90 per centum of so much of the sums expended during such quarter as are attributable to the design, development, or installation of such system, and 75 per centum of so much of the sums for the operation and maintenance of such system.

(2) At a minimum, the EVV system must meet the following requirements:
(A) Document and verify the participant’s identity, either by the participant’s personal telephone, a unique number assigned to the participant, or through alternative technology;
(B) Document and verify the attendant by the assignment of a personal identification number unique to the attendant or through alternative technology;
(C) Document the exact date of services delivered;
(D) Document the exact time the services begin;
(E) Document the exact time the services end;


Ohio specifications

(F) Support changes in the care plan which are approved by the Department of Health and Senior Services;
(G) Allow for the addition of services approved by the Department of Health and Senior Services
(H) Be capable of retrieving current and archived data to produce reports of services delivered, tasks performed, participant identity, beginning and ending times of services, and date of services in summary fashion that constitute documentation of services delivered.
Any report shall include an explanation of codes utilized by the provider/vendor (e.g. 10 –Personal Care) and include the vendor/provider’s identity by either name of vendor/provider and/or National Provider Identity (NPI); and
(I) Maintain reliable backup and recovery processes that ensure that all data is preserved in the event of a system malfunction or disaster situation



©2017 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.