EVV Phase II
How Providers Can Start Forming Habits
As IDD Providers try to make sense of EVV, (the current timeline, the previous timeline, what Phase I providers are doing, what Phase I providers are being held accountable to, etc…) it is important to understand that EVV implementation is not just a new rule to comply with.
Rather, EVV implementation should be viewed as a three-part timeline. Providers should understand how each part plays a role in reaching compliance.
A Moving Time Line
The EVV timeline, at the Federal level, has not moved since the CARES ACT was passed.
What has shifted is the timeline that Ohio and other states have initiated to come into compliance with the Federal requirement. We don’t have to look outside of Ohio to look at MyCare, and Behavioral Health Re-design to understand the strategy that will likely be expressed in how EVV gets implemented.
In the final implementation of MyCare Ohio and Medicaid Re-Design, the timeline of full implementation continued to move and shift. It is false to assume that this was not part of the planning, as government tends to provide for this kind of flexibility in their overall strategy, realizing that complex pieces and parts coming together do not often occur easily.
The key takeaway is that two very large system-wide changes did go into effect. Even though final dates moved back from time to time, it was in order to continue training and changing habits around documentation and workflow by providers.
There are many, many providers that never made it to the finish line because they never worked on the inevitable and focused on stopping the implementation altogether. Whether it was not getting a new software system, training staff, or mapping out how to function under new rules of compliance, many providers went out of business, were sold or acquired by competitors.
Compliance and Penalties
EVV training in Ohio is being initiated. Next, providers will be expected to use the EVV system. Finally, the penalty phase will be initiated for either not using the system or not being able to use the system effectively to verify billing claims. Ohio has clearly stated that providers should be in the EVV system and using it regularly by early August 2019. It has been stated that, several months later, Ohio will initiate the penalty phase of EVV implementation. Ohio has time to comply with the Federal schedule, and is giving itself plenty of time to provide additional technical assistance, training, and even complete IT system improvements.
But, use of the system is required by August. Don’t confuse the fact that penalties may not go into effect at the same time, for penalties will never go into effect.
Habits are Hard to Break and Harder to Make
Our Ohio IDD agency providers are a paper-based system at worst and an after-the-fact digital documentation based system at best. Real-time documentation is not a habit that is on display in our field and it is on a direct path of conflict with EVV.
Direct Support Professionals in the field document at the end of their shift, not at the beginning, and rarely throughout their engagement and service to the individual. As a company that developed a system to encourage and allow for documentation of services to occur in real time, we see that for many of our customers, that is the goal but not the current expectation. Usually shifting to a digital system is the main focus, as this requires changes in workflow and personnel to make use of all the benefits that a digital solution provides.
EVV changes the timeline of creating a new habit for Direct Support Professionals. At minimum staff will need to document the beginning of services at the time services begin. This seems easy enough, but if you also happen to have a payroll system for them to access, and billing system for them to access, and paper that still addresses the gaps in your digital solution(s), be ready for a learning curve that needs time to develop that habit. Get started today, find the right partner, and implement a solution that addresses compliance, workflow and creates success.