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Electronic Visit Verification (EVV) Proprietary Systems Workgroup
1st Meeting
October 1, 2019
Steve Abshier
HHSC EVV Operations
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Housekeeping and Introductions (1 of 3)
• GoToWebinar Etiquette
• All participants will remain muted
• Questions or comments may be submitted using the Question feature
3
Housekeeping and Introductions (2 of 3)
• If you’re planning on using your phone for audio, it’s important that you follow the instructions that came with your invite.
• You may have audio issues if you don’t input the audio PIN after joining the webinar.
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Housekeeping and Introductions (3 of 3)
Roll Call
• Did everyone sign in that is here in person?
• We will have a log of all attendees on the phone from the meeting registration.
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Purpose of Workgroup
• Consult with Medicaid program providers to implement an open model EVV system.
• Obtain feedback on proposed processes.
• Use program provider experiences and feedback to improve or enhance where possible.
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Meeting Rules and Expectations
• All documents, concepts, and materials presented in this workgroup are considered informal drafts unless otherwise documented.
• Discussions must remain on topic.
• On-topic feedback will be collected, but HHSC will not provide a formal response to each comment.
• This workgroup will not make final decisions.
• Participation in the workgroup is not required to seek HHSC approval of your proprietary system.
• The proprietary system option is not an opportunity for software vendors to contract with the State of Texas.
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Workgroup Membership (1 of 5)
In our call for members, we requested:
• Program providers
• Local intellectual and developmental disability authorities (LIDDAs)
• Local mental health authorities (LMHAs)
• Financial Management Services Agencies (FMSAs)
To simplify discussions, we will refer to these workgroup members collectively as “providers.”
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Workgroup Membership (2 of 5)
Software vendor participation
• May only attend if invited by a provider.
• Providers are only allowed two slots and may use one slot for their software vendor, at their discretion.
• Provider must attend with software vendor.
• The proprietary system option is not an opportunity for software vendors to contract with the State of Texas.
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Workgroup Membership (3 of 5)
Provider and industry associations
• Arc of Texas
• Deaf-Blind Multihandicapped Association of Texas (DBMAT)
• Every Child, Inc.
• Providers Alliance for Community Services of Texas (PACSTX)
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Workgroup Membership (4 of 5)
Provider and industry associations
• Personal Attendant Coalition of Texas (PACT)
• Private Providers Association of Texas (PPAT)
• Texas Association for Home Care and Hospice (TAHCH)
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Workgroup Membership (5 of 5)
As a member of the workgroup, your role is to:
• Provide constructive feedback on proposed documents and processes.
• Share experiences that should be considered while developing the proprietary system option.
• Review materials in advance of meetings when possible and provide written feedback.
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Texas Medicaid & Healthcare Partnership (TMHP)
• TMHP is the state’s Medicaid claims administrator and is responsible for the Medicaid Management Information System (MMIS) where the EVV Aggregator resides.
• TMHP is also responsible for the EVV Portal, the EVV vendor pool, and coordinates all data exchange for EVV vendors and proprietary systems.
• Examples of TMHP responsibilities include, but are not limited to:
• EVV claims matching
• Oversight of the EVV Aggregator and EVV Portal
• Oversight of the HHSC EVV-approved vendors13
Let’s Identify Ourselves (1 of 3)
• Raise your hand if you deliver services which currently require the use of EVV and you are using the DataLogic Vesta system to perform EVV.
• Throughout this workgroup, we are going to call you current EVV providers.
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Let’s Identify Ourselves (2 of 3)
• Raise your hand if you deliver services which will require the use of EVV because of the Cures Act (and you are not currently using the DataLogic Vesta system to perform EVV).
• Throughout this workgroup, we are going to call you new EVV providers.
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Let’s Identify Ourselves (3 of 3)
• Current EVV providers and new EVV providers must use an EVV system in accordance with federal and state laws, regulations and policies.
• That means your choice to pursue the proprietary system option does not change your obligation to use EVV to be reimbursed for services.
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Jordan NicholsDirector
HHSC EVV Operations
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EVV in Texas
• Limited pilot began in 2011 with Dept. of Aging and Disability Services (DADS)
• Statewide implementation of DADS and HHSC services in 2015
• Implementation of STAR Kids in 2016
• 21st Century Cures Act passed in 2016 requiring all states to use EVV for Medicaid personal care services by Jan. 1, 2020*
* Texas has received a “good faith effort” exemption to delay to the Jan. 1, 2020 start date
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EVV in Texas (cont.)
• Texas already requires EVV for about 90% of personal care services required by the Cures Act
• An extension for the Cures Act expansion in Texas has been approved
• HHSC is currently working on a revised implementation plan and will communicate dates when available
• Providers currently required to use EVV must continue to use EVV under state law and HHSC policy
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EVV Proprietary System
What is an EVV Proprietary System?
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EVV Proprietary System
An EVV proprietary system is an EVV system that a program provider or FMSA may opt to use instead of an HHSC-approved EVV vendor system that:
• Is purchased or developed by a program provider or FMSA;
• Is used to exchange EVV information with the EVV Aggregator;
• Complies with:
• Section 531.024172 of the Texas Government Code, and its successors, and
• All other EVV standards and requirements; and
• Is approved by HHSC. 21
Other EVV Options
State EVV Vendor Pool
• TMHP contracts with select EVV vendors to provide EVV systems to Medicaid providers at no cost.
• EVV vendors contracted with TMHP are part of the state EVV vendor pool.
• These are also known as HHSC-approved EVV vendor systems.
• Available vendors are posted on the TMHP website.
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Other EVV Options (cont.)
Third-Party Integration
• EVV vendors in the state vendor pool support third-party integration with other management software.
• This allows for importing data such as:
• Schedules
• Attendant/employee data
• Contact the specific EVV vendor for additional information.
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Senate Bill 1991 (1 of 3)
• Passed during the 2019 Texas legislative session
• Amended Texas Government Code 531.024172
• Became effective Sept. 1, 2019
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Senate Bill 1991 (2 of 3)
• Removed a requirement that a proprietary system must be in use since at least June 1, 2014, to be approved by HHSC
• Clarified that a proprietary system may be purchased or developed by a provider
• Requires HHSC, if feasible, to reimburse providers for the use of their proprietary system
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Senate Bill 1991 (3 of 3)
Requires HHSC to:
• Develop an open model system in consultation with stakeholders and the EVV workgroup.
• Allow providers to use emerging technologies.
• Adopt rules governing data submission and provider reimbursement.
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Reimbursement
Texas Government Code 531.024172 (g-1) reads:
If feasible, the executive commissioner shall ensure a health care provider that uses the provider's proprietary electronic visit verification system recognized under Subsection (g) is reimbursed for the use of that system.
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Reimbursement (cont.)
• HHSC was not appropriated any funding specifically related to SB 1991 or to reimburse providers for the use of their system.
• Federal guidelines prohibit states from using federal matching funds to directly reimburse providers for EVV administrative costs.
• HHSC is exploring options to determine if reimbursement to providers is feasible.
• Feedback Request: Are there any ideas from providers about how you could be reimbursed?
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Questions
• Questions from the room
• Questions from GoToWebinar chat
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Break
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EVV Systems Overview
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Trish BurkettTechnology Program Manager
HHSC EVV
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Current EVV Process Flow
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EVV System Components (1 of 4)
EVV Data Collection Methods provide:
• Collecting of electronic data by attendants at time of service delivery.
• Current methods are: member’s home phone landline, alternative device and mobile application.
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EVV System Components (2 of 4)
EVV Systems provide:
• Scheduling visits (when required by Program rules).
• Verifying visits against schedule & Texas Medicaid data.
• Exporting visits to EVV Aggregator.
• Correcting errors in visit data and re-exporting to EVV Aggregator.
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EVV System Components (3 of 4)
EVV Aggregator provides:
• Statewide visit data storage.
• Statewide standardized claims matching.
• Claims forwarding with match results to MCOs.
• Claims Match Results to TMHP (CMS, Compass21), HHSC CARE and DSHS CMBHS.
EVV Portal provides:
• Search function for the status of visit validations and claims matches.
• Monitoring reports. 36
EVV System Components (4 of 4)
EVV Validations & Web Services provide:
• Centralized, standardized visit data validations.
• Medicaid Data to EVV systems for auto-population.
• Fee-for-service authorization data to EVV systems.
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CMS Definition and Characteristics of an Open Vendor Model
Definition: States contract with a single (or multiple) vendors, or build their own system, but allow program providers and MCOs to use other vendors.
Overview:
• States maintain oversight while also allowing vendor choice for program providers and MCOs who already have an EVV system in place.
• States can implement an open model in which a system aggregates EVV data from both the state contracted vendor(s) and third-party vendors.
• The state contracted vendor(s) serves as the default system for the state. 38
EVV Process Flow –Proprietary Systems
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Expectations of a Proprietary System
• Collect service delivery visit data.
• Manage client, provider, attendant and visit data.
• Accept and utilize Texas Medicaid data from TMHP.
• Transmit visit data to the EVV Aggregator.
• Receive and present EVV Aggregator results for visit correction and re-transmission.
• Ensure data accuracy and integrity throughout.
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Expectations of a Proprietary System (cont.)
These expectations will be managed through documents that govern different aspects of the proprietary system option, including:
• Texas Administrative Code (TAC) rules
• HHSC EVV Policy Handbook
• HHSC EVV Business Rules for Proprietary Systems
• Other supporting technical documentation
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Business Rules (1 of 3)
• The HHSC EVV Business Rules for Proprietary Systems describe the business outcome expected from the EVV system.
• These rules will not provide detailed design specifications about how the EVV system must operate.
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Business Rules (2 of 3)
These rules will cover business requirements in areas such as:
• User profile management
• Required data elements and data validation
• Scheduling
• Client service authorization management
• Electronic verification methods (clock in/out methods)
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Business Rules (3 of 3)
These rules will cover business requirements in areas such as (cont.):
• Visit maintenance (correction)
• Reason codes allowed by Policy
• Transmission of EVV visit data
• Reporting requirements
• Audit trail and data quality requirements
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Other Technical Documentation
• Trading Partner Testing (TPT) Packet
• Joint Interface Plan (JIP)
• EVV Aggregator Edits
• EVV System Test Cases
• Possibly others
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Questions
• Questions from the room
• Questions from GoToWebinar chat
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Break
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Jordan NicholsDirector
HHSC EVV Operations
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Expectations of a Proprietary System
• The rules set forth by HHSC will not cover all aspects of a program provider’s responsibilities when operating a system.
• For example, these documents will not cover HIPAA requirements or Department of Labor regulations.
• Program providers are still responsible for following all other applicable laws, regulations, and policies.
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TAC Rules
TAC rules will cover requirements such as:
• Data submission and integrity (high-level).
• Reimbursement (if feasible).
• Provider liability related to use of a proprietary system.
• Access by HHSC and MCOs to a proprietary system.
• Actions HHSC may take if a proprietary system is deficient.
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HHSC EVV Policy Handbook
The HHSC EVV Policy Handbook will cover requirements such as:
• Training responsibilities
• Process and expectations for changing EVV systems
• EVV Compliance and oversight
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Documents we Plan to Review
• Informal draft of Texas Administrative Code rules and EVV Policy Handbook Changes for EVV Proprietary Systems
• Informal draft of high-level Proprietary System Operator Onboarding Process
• Informal draft of HHSC EVV Business Rules for Proprietary Systems
• Other supporting technical documentation
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Draft TAC and Policy Handbook Rules
Proprietary System Operator
• A ‘Program Provider’ or ‘FMSA’ that uses an ‘EVV Proprietary System’ to meet HHSC EVV Business Rules for Proprietary Systems.
• Why define it? To distinguish roles in our documentation.
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Draft TAC and Policy Handbook Rules (cont.)
Draft TAC and EVV Policy Handbook Changes for EVV Proprietary Systems – to be reviewed in detail at second workgroup meeting on Oct. 22, 2019
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Onboarding Overview
Proprietary System Operator Onboarding Process –High Level Overview – to be reviewed in detail at second workgroup meeting on Oct. 22, 2019
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Timeline
Planned Workgroup Meeting Dates
• Oct. 1, 2019
• Oct. 22, 2019
• Nov. 12, 2019
• Dec. 3, 2019
• Jan. 7, 2020
• Jan. 28, 2020
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Timeline (cont.)
Planned Key Dates (subject to change)
• March 2, 2020: Publication of the HHSC EVV Proprietary Business Rules
• April 2020: Trading partner testing with TMHP opens; PSOs should plan for 60 to 90 days to complete testing
• July 31, 2020: Vendor selection and proprietary system go/no-go decision for new EVV providers
• Oct. 30, 2020: Proprietary system must be implemented for new EVV providers if a vendor is not selected
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Workgroup Member Role
• Review documents ahead of next meeting
• Provide feedback in writing to HHSC EVV mailbox (preferred)
• Provide feedback in one email from your organization (preferred)
• Use email subject: Proprietary workgroup feedback – [organization name]
• Provide feedback at the next meeting
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Proprietary Systems Webpage
• We are creating a webpage on the HHSC EVV website to post information about the proprietary system option, including materials for these meetings.
• Once created, a link will be emailed to all workgroup members.
• The webpage will accessible by the public, not just workgroup members.
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Questions
• Questions from the room
• Questions from GoToWebinar chat
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Action Items
Action Item Review
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Resources
HHSC
• Website: https://hhs.texas.gov/doing-business-hhs/provider-portals/long-term-care-providers/resources/electronic-visit-verification
• Email: [email protected]
• Sign up to get HHSC EVV notices: https://public.govdelivery.com/accounts/TXHHSC/subscriber/new?topic_id=TXHHSC_247
TMHP
• Website:http://www.tmhp.com/Pages/EVV/EVV_Home.aspx
• Email: [email protected]
