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FROM A LEADER IN AGENCY WORKFORCE MANAGEMENT SOLUTIONS ALL YOU NEED TO KNOW ABOUT ELECTRONIC VISIT VERIFICATION AND HOW EVV BENEFITS AGENCIES www.mitcsoftware.com

All you need to know About electronic Visit Verific Ation And ......All you need to know About electronic Visit VerificAtion And how eVV benefits Agencies to save the situation. Managers

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Page 1: All you need to know About electronic Visit Verific Ation And ......All you need to know About electronic Visit VerificAtion And how eVV benefits Agencies to save the situation. Managers

FROM A LEADER IN AgENcy WORKFORcE MANAgEMENT SOLUTIONS

All you need to know About electronic Visit VerificAtion

And how eVV benefits Agencies

www.mitcsoftware.com

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All you need to know About electronic Visit VerificAtion And how eVV benefits Agencies

why Are so mAny Agencies interested in eVV?

Agencies managing growing HCBS programs face unique challenges not found in other programs. Home and community-based services (HCBS) provide opportunities for Medicaid beneficiaries to receive services in their own home or community outside of facilities. These programs serve a variety of targeted populations, such as people with mental illnesses, intellectual or developmental disabilities, and/or physical disabilities at remote locations where staff are working relatively unsupervised.

Vocational workshop programs are being slowly phased out or defunded in favor of HCBS programs. For agencies who have never managed an HCBS program before, it will be a new world with new challenges.

The growth of HCBS coincides with wider use of Managed Care and Fee-for-Service. Agencies relying on paper timesheets or ineffective attendance systems are increasingly at risk. Agencies need to be able to manage billing outcomes and cash flow on a faster cycle than before, which means real-time information is a necessity.

1. Authorized serVicesIn most states, individuals have a plan of care that authorizes hours of service(s) in different components, such as home making and respite. These budgets are often further subject to restrictions over usage, sometimes as small as weekly amounts, sometime quarterly. The challenge for an agency managing a HCBS program is to ensure all the authorized services, but no more, are delivered within the requisite timeframe. Services delivered outside of the authorization or budget may not be reimbursed leading to a payroll obligation with no matching revenue (loss). Services not provided may result in lower revenues (profit).

2. AttendAnceWithout real-time attendance verification, it is impossible for agencies to manage this delicate balancing act of not under or over servicing the client. Managers and executives need visibility into attendance by client as well as individual employee and the ability to intervene in the time

“Agencies managing growing HCBS programs face unique challenges not found in other programs.”

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All you need to know About electronic Visit VerificAtion And how eVV benefits Agencies

to save the situation. Managers and executives cannot deal effectively with issues in HCBS that were not spotted for days or weeks later.

3. oVertime for home cAre workersHCBS programs that incur overtime or third-party staffing costs significantly undermine the profit of providing services. Since 2016, all states in the USA are required to pay home care workers overtime if they work more than 40 hours a week.

4. schedule silosIn the absence of any alternative, managers in HCBS often resort to contacting employees who are most likely to want the hours. This practice further contributes to the cost of overtime. Without the ability to search for available, qualified staff, publicize open shifts and vacancies easily, and simply schedule employees across the agency, HCBS managers resort to using their immediate reports to fill open shifts. The result can be missing the opportunity to provide extra hours to a part-time employee and incurring more overtime costs. If overtime is only avoided 10–20% of the time, that represents a significant savings.

5. documentAtionAs well as tracking time & attendance, agencies are often required to document the services provided in HCBS programs. Collecting the documentation and ensuring staff are using current documentation is challenging without an automated system.

6. low-leVel PAPer timesheet frAud And errorsStaff members who work with individuals in the community are relatively unsupervised. If staff members falsify attendance, the client loses services that they are entitled to. If staff make an error (enter the hours for the wrong client), embarrassing billing issues can arise during audits.

7. comPlex PAyroll And billing rulesOver the years, many agencies have sought to address staffing needs and periodic tight labor markets by introducing incentives for employees to work overnight shifts, with difficult clients, and on holidays. Often, employees are paid multiple rates. Different services need to be tracked by client and billed separately, even if the billing rate is the same. These rules have had two major impacts:

a) Lengthy manual pre-payroll and pre-billing procedures requiring skilled staff.

b) Difficulties in implementing generic time and attendance systems which may not be able to handle both payroll and billing rules. The rate of failed implementations is quite noticeable among agencies with complex payroll and billing rules.

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All you need to know About electronic Visit VerificAtion And how eVV benefits Agencies

8. eVV PAyroll And billing integrAtionEliminating data entry to payroll and billing saves agencies a lot of time, as well as improving accuracy and eliminating embarrassing audits problems if payroll and billing do not match.

9. emPloyee communicAtionToday’s effective organizations are leveraging technology to provide employees with schedule reminders, schedules by email, and access to employee self-service to help remind employees of their obligations and remove problems such as when managers fail to respond in a timely manner to PTO requests, schedule change requests, expenses form reimbursement, and more. Without these tools, agencies with HCBS programs are likely to suffer from higher rates of absenteeism and turnover.

10. emPloyee PreferencesPay is only one factor in attracting and retaining employees. Having the ability to address employee preferences and restrictions can be as, or more, important. If managers are not aware of employee preferences or restrictions, managers may inadvertently ask employees to fill shifts the employee does not or cannot take. Causing conflicts with employees’ personal lives, such as child care arrangements, is not useful when trying to retain employees.

11. rePortingMany agencies lack the HCBS reporting systems that are vital to manage the program. Without budget variance, authorization, utilization, and client profitability reports, managers and executives are unable to address problems where they are occurring that are having a negative impact on the agency.

12. time & AttendAnce frequent offendersAgencies contemplating implementing an automated time & attendance system, or with an existing time & attendance system, need to ensure the long-term benefits are not undermined over time by frequent offenders. Frequent offenders are employees who deliberately decide not to clock in and out when late or leaving early and request an edit from their manager. Any system must be able to detect such behaviors.

“Many agencies lack the HCBS reporting systems that are vital to manage the program.”

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13. AwAke shiftsIf employees sleep while on duty during overnight awake shifts at client locations, agencies become vulnerable.

14. mileAgeHome care aides, nurses and therapists who serve elderly, disabled, and chronically ill patients across the United States drove 7.88 billion miles and made more than 718 million home care visits in 2013. Of these 718 million visits, about 218 million were Medicare home health and hospice visits, and about 338 million were Medicaid home care visits, according to a report by the Foundation for Hospice and Homecare.

There has been an over 200% increase in the estimated total number of miles driven by home care providers in recent years. In 2006 for instance, the estimated number of miles driven in home care services totaled 4.76 billion. The rise in miles traveled over the last seven years is attributed to increases in Medicaid home care, Medicare home health growth, and Medicare hospice utilization. The average number of miles per visit in the U.S. in 2013 totaled 10.97, the study found. The state that recorded the highest average miles per visit that year was Maine, with 35.2. Agencies with HCBS programs in rural states are the most affected by mileage claims.

whAt is electronic Visit VerificAtion (eVV)?Electronic visit verification is widely used by agencies and government entities. Agencies use it for compliance and quality assurance, to verify employee’s locations, complete documentation, verify hours of work for payroll and billing, and streamline payroll and billing.

The two main technologies used for EVV are Telephone Timekeeping with Caller-ID verification and Web Clock with GPS verification. Both technologies have their advantages and disadvantages. Both are generally acceptable to Medicaid auditors in preference to paper timesheets, as long as the technology is compliant with Medicaid regulations for electronic documentation.

“There has been an over 200% increase in the estimated total number of miles driven by home care providers in recent years.”

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how does eVV work?Both Telephone Timekeeping and Web Clock require the employee to clock in with a unique ID, often known as an Employee PIN (Personal Identification Number). The Employee PIN replaces the employee name and signature on a paper timesheet.

Both systems identify the client being served, typically using a client PIN. If the client receives multiple services, the employee enters a service code for billing.

Telephone Timekeeping requires staff to use the client’s landline phone. While many clients may no longer have landlines or the phone may be out-of-service, enough (57%) still do, to make this a practical possibility. According to the Centers for Disease Control as of July 2015, two percent of people have no phone, nine percent have just a landline, 48 percent have a landline and a cellphone, and 41 percent have just a cellphone. Obviously, the big plus of Telephone Timekeeping is that apart from paying for the 800 number calls if the call is long distance (typically 1c), there is no equipment or data plan to have to provide.

If the client does not have a landline phone, there are government programs that provide subsidized phone service. If the client’s landline phone is out-of-service, usually Medicaid will accept a call from a cell phone in preference to resorting to paper timesheets.

Web Clock has the advantage of not being dependent upon the presence of a landline phone. However, the downside is the cost of the phone(s), data plans and internet access (or lack of it), and employees forgetting to charge the battery (with GPS enabled and active, battery life is shorter than usual). GPS is accepted as verification of services. If Web Clock is combined with Employee Self-Service, the employees have access to their timesheets, schedules, PTO balances, PTO requests, open positions, training classes, W-2s, payroll check stubs, client information, and more all from their smartphone.

Other features of EVV include:

�No-show alerts report missed visits in real time

�Optional text alerts for managers to confirm visits started

�Check awake calls for overnight shifts

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�Administrators and managers can watch or review visits as they take place

�Variance to schedule, budget and authorization reporting

� Restricted clock-in if budget exceeded

�Capture documentation

�Voicemail messages to pass client updates on to caregivers, such as “Mary’s meds have changed”

�HR alerts regarding training, licenses, and more

whAt fAVorAble outcomes hAVe Agencies AchieVed?Clearbrook is the largest provider of home-based services in Illinois, supporting over 7,000 individuals as well as their families in 14 counties, in over 160 communities, and 50 locations throughout Chicago, the suburbs, and northern Illinois. Carrie Zielinski, IT Technical Trainer at Clearbrook explains:

“The in-home program clock in via the client’s phone. This saves a ton of time. 70% of staff uses the phone, as do the small residential homes.”

Paraquad, based in St. Louis, MO, manages a large Consumer Directed Services (CDS) program regulated by the Department of Missouri Medicaid Audit and Compliance Unit. Consumer Directed Services pose unique challenges for agencies seeking to automate time and attendance, as the attendants who provide services are employed by the consumer, not the agency. In addition, in Missouri the use of telephony to verify visits has to meet criteria the Department of Missouri Medicaid Audit and Compliance Unit’s requirements for telephony. In 2012, Paraquad implemented a large telephony and web-based time & attendance solution from MITC for 1,200 attendants to comply with the requirements of Missouri’s mandate for Consumer Directed Services (CDS). Alyssa Schafer, CDS Timesheet Compliance Manager remembers what the old system was like.

“Prior to using MITC, attendants would submit paper timesheets. We had a whole team who checked and submitted them. Then we had an entire team dedicated to entering the timesheets into the system. They have been combined in to one team.”

In addition telephone timekeeping for the 1,200 attendants integrates with Paraquad’s CYMA payroll, eliminating data entry, and additional risk of inaccuracies.

“The in-home program clock in via the client’s phone. This saves a ton of time.”

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Alyssa Schafer, CDS Timesheet Compliance Manager recalls some of the challenges.

“The consumers were very leery because they don’t like change, but most love MITC now that they’ve gotten used to it. We tell consumers we’ve found the best company we know of to do this for us.”

The Arc of Burlington County in New Jersey offers a wide range of services to 157 clients, including 11 community residential homes and apartments for adults, five adult day programs, a developmental day care center for infants and toddlers from birth to three, a month-long summer camp for individuals 13 and older, and an extensive recreation program open to adults throughout Burlington County with developmental disabilities. The Arc recently added in-home supports and self-directed programs to provide staff who work with individuals in the community that need assistance with life skills, money management, shopping, medical appointments, and a range of other activities, while still maintaining independence in their own homes.

Renae Malfetone, Assistant CFO, remembers that “the whole process took two days”. Today, Renae thinks the process is easier after implementing a MITC Agency Workforce Management solution.

“All employees are clocking in and out by telephone or web. The approval process has a timeframe of 8:00 am–10:00 am, but the managers have usually approved timesheets by 9:00am. Managers can approve via the web from any location using any internet-enabled device. The Arc of Burlington uses schedules to compare with actual.”

Shift differentials, overtime, holiday pay, and holiday uplift are now calculated automatically.

The approved payroll is uploaded electronically into ADP, eliminating data entry.

The Arc of Burlington County let employees clock in and out by telephone or web clock.

Having both systems provides for flexibility and backup, according to Karl Cina, CFO .

“Employees have the option of using whatever device they prefer to clock in and out in all programs. The Arc of Burlington County has both internet (web clock) and telephone timekeeping. If our internet goes down, the staff can use the telephone. In-home supports always just use the phone to clock in and out. Some use tablets if there is an internet connection.”

“All employees are clocking in and out by telephone or web. Managers can approve via the web from any location using any internet-enabled device. ”

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Medicaid regulations for EVV electronic documentation include:

�All administrative users must have unique passwords and unique user identifications.

� Ensure all demonstration, training, and testing passwords are removed before going live.

�Agency policies should explicitly forbid sharing of passwords.

�Access to edit procedures must be restricted to authorized users.

� Edit procedures available for non-Medicaid regulated entities should be disabled once the agency goes live or not available to staff managing EVV programs.

� The software must track any change to any record, date, time, and user identification.

�Changed records must be reported separately from originals.

� Each employee must have a unique Employee PIN.

telePhone timekeePing �Caller-ID should be used to verify the employee was onsite, where possible, by requiring the use of a landline phone or a cell phone “locked” in place.

�Caller-ID verification procedures should be in place and enforced. Regular checks of unrecognized phone numbers should take place and be documented.

� If calls from unrecognized phones are allowed, these should be identified and verified (call the phone number listed).

�Voice Identification sampling procedures should be implemented.

�An 800 number should be provided for long-distance calls.

smArtPhones � If a smartphone is used, GPS should be enabled. The agency will usually have to provide the smartphone to enforce usage and GPS monitoring.

� The smartphone and data plan should be provided by the agency to avoid DOL complaints about non-reimbursement or class action lawsuits regarding privacy infringements. Alternatively, the agency can reimburse the employee for using their personal phone.

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stAte And federAl goVernment mAndAtesElectronic visit verification is viewed by State and Federal governments as a way to help cut down on fraud and ensure that people receive the documented care they need. EVV is mandated in certain programs to help verify that services billed for home healthcare are for actual visits made. The Affordable Care Act included provisions for the cut down of fraud and over-payments, requiring states to stop Medicaid payments to providers when there is credible evidence

of fraud. Some states implemented an office of inspector general to oversee Medicaid fraud investigations, with many moving towards a system of verifying home healthcare visits in order to help reduce fraud.

Several states have introduced electronic visit verification with some mandating it. The 2016 Cures Act enacted by Congress and signed into law by President Obama contains provisions for expanding the use of EVV to all states.

Different states have taken different approaches to implementing EVV.

In Missouri in 2015, over 600 providers of in-home services and consumer-directed service programs were required to choose a EVV provider that met requirements. This approach minimizes disruption for agencies who have already implemented EVV and allows agencies the flexibility to choose the solution and training plan that best integrates into the way their agency operates and with their existing time and attendance systems and payroll. The roll out in Missouri was largely successful and positively received by most agencies. Reimbursement can be provided for by the state in the rate.

In Louisiana, the state started but failed to implement two different mandatory EVV systems using only a single vendor with little training or transition time. This approach was unpopular with providers in Louisiana. Currently, the Louisiana Department of Health (LDH) is in the process of implementing electronic visit verification (EVV) to better manage home and community-based services and supports for Medicaid participants. The Department plans to pilot two new EVV mechanisms. In addition, LDH will work with providers that currently have their own EVV system in place, allowing these providers to continue using systems familiar to their staff while reducing their costs for training and implementation of a new EVV system.

“Different states have taken different approaches to implementing EVV.”

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In Ohio, the Department of Medicaid plans to begin using EVV for many home and community-based services by late 2017. Services to be included in the EVV are State Plan Home Health Aide, State Plan Home Health Nursing, Private Duty Nursing (PDN), Ohio Home Care Waiver Nursing, Ohio Home Care Waiver Personal Care Aide, Home Care Attendant, and RN Assessment. ODM has contracted with a vendor to deliver Ohio’s EVV system, as well as to provide program orientation and training to providers. However, ODM it is open to providers using their own EVV systems as long as the alternate EVV systems meet ODM interface requirements. All alternate EVV systems must collect visit data, have GPS, and send visit information in near-real time.

Kansas introduced EVV in 2012 for Direct Service Workers (DSW) of (KDADS-HCBS) (FE, I/DD, PD, TBI, TA) and Money Follows the Person (MFP) (FE, I/DD, PD, and TBI) programs to document time worked and activities relating to service delivery. The utilization of the EVV system is necessary to meet documentation requirements in order to support claims submitted for reimbursement of services rendered.

In Texas, electronic visit verification (EVV) is required for certain home and community-based services provided by the Texas Health and Human Services Commission (HHSC), Texas Department of Aging and Disability Services (DADS), and certain Managed Care Organizations (MCOs). Like other states, Texas implemented EVV to verify that individuals/members receive the services authorized for their support and for which the state is being billed. Time is logged using an HHSC-approved EVV system and an individual/member home landline telephone, or a small alternative device for personal assistance services (PAS), personal care services (PCS), in-home respite, Community First Choice - PAS, and habilitation (HAB). Texas permits agencies to choose among different vendors.

“In Ohio, the Department of Medicaid plans to begin using EVV for many HCBS programs by late 2017.”

“Like other states, Texas implemented EVV to verify that individuals receive the services authorized for their support and for which the state is being billed.”

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Problems with stAte mAndAted eVV for AgenciesThe state’s focus is eliminating fraud and making savings. One state planned to reduce reimbursements by $9 million per year by rolling out EVV. When the state is involved in the selection of the vendor, the needs of the agency providers can get forgotten. While all agencies want to help cut down on fraud and ensure that people receive the documented care they need, agencies need solutions that are cost-effective. Questions agencies need to consider are:

1. How will the state EVV system integrate with existing systems?

2. Will the EVV system integrate with my payroll?

3. What if staff get paid different rates for different clients, tasks, or services? How are these identified?

4. How will staff get paid?

5. What is the staff work in other programs not covered by the EVV mandate

6. If telephony is part of the solution, what happens if the client does not have a landline phone or the phone is out-of-service?

7. If smartphones/GPS are part of the solution, who pays for the smartphones and data plans? What if staff forget their agency phone or the battery is dead? Bring-your-own-device (BYOD) is not a solution that can withstand a legal challenge unless the staff is compensated for providing their own smartphone. Plus, there have been privacy concerns and lawsuits over forcing staff to use GPS tracking on a phone the staff provided.

8. How much training will be provided to agency administrators, managers, and front line staff?

MITC provides modular workforce management solutions and services

to support all the needs of agencies – time & attendance, scheduling,

HR, workforce analytics, payroll and billing integration, and more. Visit www.mitcsoftware.com

to learn more.

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