Over 30,000 Coloradans receiving Home and Community Based Services through the state will be impacted by the federal mandate of electronic visit verification (EVV.) The federal mandate goes into effect on the first day of January 2019. The verification system must be in place in order to continue to receive a 50 percent match from the Centers for Medicare and Medicaid Services (CMS). Stakeholder groups are meeting with representatives from the Department of Health Care Policy & Financing throughout the state to become educated about the verification system requirements.
In an interview with Catherine Strode, the state’s Director of Benefits and Services explains Electronic Visit Verification (EVV), how the state will implement it and what concerns are being expressed by clients and providers. In Part One of this interview, Colin Laughlin explains how Colorado will do a “soft rollout” of the Electronic Visit Verification with the formost concern being protection of privacy.
Some of the states that have moved really quickly are running into some unforeseen issues. We want to make sure that with a thoughtful approach, we are able to consider all the angles before we flip on a switch and upset a system that we believe works well.” — Colin Laughlin
What is Electronic Visit Verification?
“EVV (electronic visit verification) is a federal mandate. It is part of the 21st Century Cures Act, a piece of legislation that was passed in 2016. The Act is 312 pages long. The specific part that talks about EVV is about two and a half pages. Initially, there was not a whole lot of federal detail that was given. Essentially what it does is require electronic verification of services that are either home health or personal care services in nature. The intent is to ensure there are not inappropriate billing practices or misaligned billing practices. The intent is also to ensure that people are not submitting something that is incorrect and billing the state when the services in that method may be not fully rendered. It requires six points of data. It’s the ‘who’: who is receiving the service, who is rendering the service. It’s the ‘when’: time and date are required. It’s the ‘where’: where are they doing the service. It’s the ‘what’: what type of service are they providing.”
How is EVV implemented?
“The approach varies state by state. There are different ways to do it. Colorado is approaching it from a hybrid model which allows for the greatest flexibility in meeting this mandate. That allows for provider agencies who are delivering some of these services to use their own electronic verification technology. A lot of providers in this state have already been using EVV in some way, shape, or form. It also allows them, if they don’t already have it, to connect directly to the state system with whatever vendor we’re using. With the flexibility we are requiring, you can verify different ways. You can verify through a telephone. You can verify through geographical positioning. If someone is uncomfortable with being ‘GPS’ed’, they don’t have to use GPS. We are going to (within the space that we can) allow for the most flexibility within those services.”
How will Electronic Visit Verification impact clients?
“In Colorado, we are trying to roll this out with the most flexibility as possible. We want to make sure we are not materially changing how people receive services. Colorado has historically been one of the leaders in Community Based Services. In fact, we are typically one of the top three, top five, in the country in those types of delivery of services. We also have a very large percentage of people who receive services in the community as opposed to a nursing facility placement. We don’t want to impact those numbers. We believe people are better served in the community. We believe that the choices people are able to make about their services is critical and a philosophical cornerstone in what we do. We don’t want to impact that. Our goal is to not impact the client as best as we can. It is going to be a shift for service providers. They are going to have to learn how to use this technology. We expect there to be some growing pains and so what Colorado is doing is what we are calling a soft roll out.”
What is a soft roll out?
“A soft roll out means we are not going to tie it to claims at least for the first six months. We are going to require the verification components but we are not going to say it’s directly tied to payment. We want to make sure those records exist. We are mandated to do this by the Centers for Medicare and Medicaid Services (CMS) in order to receive our 50 per cent match for services. We know there are going to be some bumps here and there and so we’re not going to do anything right away. We’re not going to flip a switch that could potentially create situations where people aren’t receiving payment. We are going to do all that we can to allow for some flexibility and some growth to make sure we can work out all the kinks before we move forward.”
We’re going to be doing some myth busting. We want to keep this as minimally as invasive as possible.” — Colin Laughlin
How are you addressing the privacy concern?
“We have a subcommittee dedicated to this topic. We’re going to be doing some myth busting. There are some people who have heard they are requiring us to take a picture when they first get there. Also, that they are requiring us to verify a location by going outside of their house and taking a picture. Those are not things we are going to require. We want to keep this as minimally as invasive as possible. We are not going to require pictures. We are not going to require voice recordings. We are not going to require someone to carry a monitor device. We’re not going to require someone to turn on geographical positioning (GPS) unless they are okay with that. There are a lot of different ways you can go about verification. You can call. You can have a locator in your phone where it doesn’t track anything. It just is a button that says, ‘Yes, I’m here.’ It does not require us to go to some of the extents that I think people are concerned about. This does require verification of the component of knowing where people are. We are trying to be as considerate and thoughtful as possible about this process. That is why we have dedicated an entire subcommittee to this conversation. We have an open dialogue with our federal partners. We are continuing to say, ‘There is a concern about this approach. Is there another way we can do this verification?’ Here in Colorado, we are trying to emphasize flexibility in these options.”
What concerns of providers do the meetings address?
“The providers are concerned how we get this data to ensure we are compliant. There are a lot of moving parts. The training talks specifically about how to utilize the system and what pieces of information must be verified. The system design talks about the actual design, what it looks like and how it interacts. We talk about: on my cell phone how does this application work? How do I go about making sure this data goes back to the aggregator? How do I make sure I can check in if I am in a place with spotty cell service? Those types of things. We are going to be working with our vendor to make sure there is robust training. The training component is to ensure people can use our system correctly and are able to verify the six points of data. We have 12 training visits scheduled throughout the state. We’ll be going to regional locations: Grand Junction, Durango, and Pueblo to talk about what this is, what this looks like for providers. We anticipate that a lot of people who are receiving services want to know what this is too.”
What do the meetings with clients receiving services address?
“We have stakeholder groups on participant direction. We have two service delivery methods in Colorado: In Home Support Services and Consumer Directed Support Services. Participant direction is speaking directly to services offered under those models. When they have the ability to hire, fire and pay their own attendants, they have different concerns than a home health agency. That allows for an uninterrupted service modality. Someone can receive personal care which is a more skilled type of service as well as support from a homemaker who can help them with their dishes or help them prepare lunch. It is a service option that allows people to receive services across three different services uninterrupted. It is different than a provider who would go in and provide 15 minutes of personal care and then 15 minutes of homemaker services. There are concerns because there is some fluidity on how those services are provided. It is a bit of a different approach. We are trying to address those specific concerns that community has.”
Why are you holding the stakeholder meetings?
“We are very aware this is a big change and a big system rollout. Some people, I think, are still unsure of what this overall means. When you have 60 plus people in a room and you are talking about this very large thing, not everyone’s questions are going to be answered. We want to give people the venue to have those conversations. We want to have those meetings where people can talk about the things that are concerning to them.”
Catherine Strode is Advocacy Denver’s Communications and Policy Specialist. She holds a Masters degree in Public Administration with an emphasis in Health Care Policy. Catherine publishes Policy Perspective, featuring interviews with state policy makers on issues that affect the work and mission of Advocacy Denver.