Electronic Visit Verification General Stakeholder Meeting August 18, 2020 1
Our Mission Improving health care access and outcomes for the people we serve while demonstrating sound stewardship of financial resources 2
WELCOME Stakeholders • HCPF Introductions • Housekeeping 3
The purpose of this meeting is to engage providers, members, and other stakeholders as the Department works to implement EVV for community based services offered through both the State Plan and Waivers. Meeting And specifically to: Purpose • Review EVV, the legislative mandate, and the scope of implementation • Discuss EVV Project Updates • Provide a platform to gather stakeholder feedback 4
We ask that you: • Mind E-manners • Identify yourself when speaking Meeting Guidelines • Share the air • Listen for understanding • Stay solution and scope focused 5 5
Introductions Brief Overview of EVV EVV Mandate Department EVV Memos Program Updates Sandata Call Center Report Agenda Department Data Analytics Resources Training Support Stakeholder Engagement Open Forum 6
Overview of EVV 7
• Electronic Visit Verification (EVV) is a technology solution which verifies information through mobile application, telephony, or web-based portal • EVV is used to ensure that home or community- based services are delivered to people needing those services by documenting the precise time service begins and ends What is • Section 12006 of the 21st Century Cures Act EVV? requires all state Medicaid agencies implement an EVV solution • States that do not implement EVV will incur a reduction of Federal funding • The Department will implement and mandate EVV for all Colorado required services on August 3, 2020 8 8
State EVV Solution Technologies Mobile Application Telephony Provider Web Portal 9
TYPE OF SERVICE INDIVIDUAL DATE OF THE PERFORMED RECEIVING THE SERVICE What must SERVICE EVV Capture? LOCATION OF INDIVIDUAL TIME THE SERVICE SERVICE DELIVERY PROVIDING THE BEGINS AND ENDS SERVICE 10
Which Services Require EVV?* Personal Care Independent Living Skills Training (ILST) • • Pediatric Personal Care Life Skills Training • • Home Health: RN, LPN, CNA, PT, OT, SLP Physical Therapy (provided in the home) • • Private Duty Nursing Occupational Therapy (provided in the home) • • Hospice Speech Therapy (provided in the home) • • Homemaker Behavioral Therapies (provided in the home or • • community) Respite (provided in the home or community) • Pediatric Behavioral Health • Consumer Directed Attendant Support Services • (CDASS) Youth Day • • In-Home Support Services (IHSS) • Durable Medical Equipment (select services) *Subject to change 11
Service Types Groupings Consumer Directed Consumer Directed Home Health – Behavioral Home Health – Home Health – Attendant Support Attendant Support Occupational Therapies Services – SLS Certified Nurse Aide Nursing Services Therapy Health Maintenance Independent Living Home Health – Skills Training Home Health – In-Home Support Speech/Language Homemaker Hospice - In Home Physical Therapy and Services Therapy Life Skills Training Occupational Pediatric Behavioral Pediatric Personal Private Duty Personal Care Physical Therapy Therapy Therapies Care Nursing Respite and Youth Speech Therapy Day 12
• EVV services happen in the home and in the community. • EVV does not disrupt this flexibility of Service service location. Location • Facility-based services are exempt from EVV unless otherwise noted. • Capture location where the service occurs 13 13
Colorado selected a vendor that will provide EVV solutions, while also allowing providers to use alternative/existing EVV systems if they meet state specifications: State EVV • Providers choosing to use an alternate Model: vendor must ensure that their system is configured to Colorado EVV rules and Hybrid requirements. • Provider Choice Systems must connect to the Data Aggregator 14
Questions 15
EVV Mandate 16 16
Colorado EVV Mandate • EVV is required by section 8.001 of the Colorado Code of Regulation • The Department will monitor compliance and outreach provider agencies who are not fully utilizing EVV • Providers who are experiencing unavoidable delays should contact the Department • Providers not making a earnest effort to utilize EVV may be subject to Compliance Monitoring, Request for Written Response, or Overpayment Recovery • On January 1, 2021, claims without corresponding EVV will deny 17
Colorado EVV Implementation Timeline • 9/18/19: Good Faith Effort Exemption request approved by CMS • 10/1/2019: State EVV Solution and Data Aggregator went live • 10/1/2019 – 8/2/2020: Soft-Launch • 8/3/2020: EVV mandate, providers must use EVV • 10/1/2020 – 12/31/2020: Post payment claims review for providers who are not making an earnest effort to use EVV • 1/1/2021: Prepayment claims review, claims will deny without corresponding EVV 18
Implementation Reminders • The State EVV Solution and Data Aggregator is live and available for use • Opportunity for caregivers to practice EVV collection and for members to become accustomed to EVV • Opportunity for providers to use EVV before claims integration. Claims will continue to pay and EVV errors will appear on Remittance Advice (EOB 3054) without consequence. • Implementing early helps everyone by helping the Department identify and develop supplemental training materials 19
Department EVV Memos 20 20
• Department memos are available online* Department • All salient points are discussed in Memos stakeholder meetings; memos may be used as references and official guidance from the Department *Direct link to Department Memos 21
• Policy Memo regarding State Statute (ACP)* Memo • Supersedes previous ACP EVV PM 20-007 Guidance (PM 20-001) Electronic Visit Verification (EVV) • How providers and caregivers can Address Confidentiality Program (ACP) Guidance use EVV while protecting ACP participants *Direct link to EVV & ACP Memo 22
• Policy Memo regarding Code of Colorado Regulations inclusion of Memo DME in the EVV program* PM 20-006 • DME removal from the EVV program Durable Medical Equipment Electronic Visit Verification (EVV) • Functionally removed, removal Exemption from rule forthcoming *Direct link to EVV & DME Memo 23
• Operational Memo (1) clarifying Code of Colorado Regulations EVV compliance timeline (2) Memo • Supersedes previous EVV Mandate OM 20-079 Timeline (OM 20-012) Electronic Visit Verification (EVV) Compliance Timeline • Discusses the stages of the EVV compliance timeline and multiple supports for EVV users (1)Direct link to EVV Memo (2)Direct link to rule 24
First Compliance Timeline Stage: Compliance Monitoring • Beginning August 3, 2020, providers not using EVV must submit a written plan to the Department outlining their intent to utilize EVV and when compliance is expected. • Provider Expectations: Training must be completed immediately • Client and employee data must be entered immediately • Providers must make an earnest effort to collect EVV data • 25
Second Compliance Timeline Stage: Over-Payment Review • Beginning October 1, 2020, in addition to the August 3, 2020 enforcement requirements, all claims subject to EVV requirements will pay initially, but paid claims that do not have valid matching EVV records may be subject to Department review and recoupment as Over-Payment Recovery. • Provider Expectations: Improve the percentage of non-compliant claims billed • Establish communication with the Department regarding any issues impeding • implementation Respond to Department guidance appropriately • 26
Third Compliance Timeline Stage: Pre-Payment Claim Adjudication • Beginning January 1, 2021, in addition to the October 1, 2020, enforcement, all claims submitted to the Department that require EVV records must be matched to valid EVV records to pay • January 1, 2021 also marks the beginning of tying EVV compliance directly to the Colorado Medicaid Provider Agreement • Provider Expectations: All EVV records are collected appropriately and transition into claim integration is as • smooth as possible 27
Compliance Timeline Memo: User Supports • State EVV Solution interim option • Switching to a different EVV vendor • CDASS vendor switching • Implementation coaching (As discussed in support pathways) 28
Questions 29
Program Updates 30 30
Live-in Caregiver Touchbase Live-in Caregivers may be exempt from EVV • Provider agencies may choose to collect EVV from Live-in Caregivers • Live-in Caregiver Attestation Forms must be submitted to the provider • agency or FMS vendor At this time, the Department only collects Live-in Caregiver Attestation • Forms for Part C: Extenuating Circumstances Do not send Part A or Part B forms to the Department • Live-in Caregiver Attestation Forms must be updated annually or when • information becomes outdated 31
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