ABI Forum of the CT Community Nonprofit Alliance

Transcription

1 Date: January 16, 2017 ABI Frum f the CT Cmmunity Nnprfit Alliance T: The Hnrable Representative Abercrmbie Frm: Julia Wilcx, Senir Public Plicy Specialist, CT Cmmunity Nnprfit Alliance (The Alliance) Re: Cc: Prvider Cncerns and Recmmendatins re: Implementatin f Electrnic Visit Verificatin (EVV) Members f the Acquired Brain Injury (ABI) Frum f the CT Cmmunity Nnprfit Alliance Dear Representative Abercrmbie I hpe this finds yu well. First and fremst, n behalf f the Acquired Brain Injury (ABI) Frum f The Alliance, I wuld like t express my appreciatin fr all f yur effrts t imprve upn the scpe and prcesses related t Acquired Brain Injury (ABI) cmmunity services. We greatly appreciate yur nging supprt and cmmitment t the Legislative ABI Waiver II Advisry Cmmittee. As requested, n the fllwing pages yu will find extensive infrmatin related t the cncerns and recmmendatins f the ABI Prvider Cmmunity, in reference t the implementatin f Electrnic Visit Verificatin (EVV.) We greatly appreciate the pprtunity t submit this infrmatin fr yur review, and welcme the pprtunity t discuss any questins, cncerns r recmmendatins yu ay have, when we meet n Tuesday, January 17, Executive Summary f Electrnic Visit Verificatin (EVV) Implementatin Challenges fr Acquired Brain Injury Prviders The fllwing summary is the result f a cllabrative effrt by a grup f agency prviders serving individuals under Cnnecticut s Acquired Brain Injury Waiver. Our grup prvides services t ver half f the individuals enrlled in this waiver prgram. We are cmmitted and respected agency prviders lking t cntinue t prvide quality persn-centered services t ur participants. We lk frward t cntinuing ur partnership with the Department f Scial Services (DSS) t successfully integrate electrnic visit verificatin sftware int ur peratins. Hartfrd Office: 75 Charter Oak Avenue, Suite Hartfrd, CT Fax:

2 The Alliance Cncerns Re: EVV /ABI Waiver Page 2 f 5 EXECUTIVE SUMMARY: Electrnic Visit Verificatin (EVV) Implementatin Challenges fr Acquired Brain Injury Prviders DSS has mandated agency prviders t use Sandata s EVV sftware t bill all claims. While prviders wuld like t partner with DSS t incrprate EVV within ur peratins, substantial systematic changes t EVV must be made fr this t be manageable fr agency prviders. 1. THE CHALLENGE FOR PROVIDERS: The rllut was rushed and the system was nt fully develped. The system is nt well suited fr the ABI waiver. The administrative and financial burden is unwrkable fr agencies, many f whm are nnprfits already shuldering the effect f years f budget reductins. 2. TIMELINE REGARDING IMPLEMENTATION: While prviders appreciate the minimal extensins which have been granted, the time line frm initial rll-ut t the present, has been extremely challenging and prhibitive. (Refer t sectin 2 fr details.) 3. ADMINISTRATIVE BURDEN: Based n the structure f the ABI waiver, a client may receive upward f 6 different types f services in a 24 hur perid under EVV. This means that a caregiver in the field may be asked t lg in and ut f the EVV system up t 5 r mre times within an average shift. The sftware requires that these lgins may nly happen within the client s hme. Any lgins made while in the cmmunity becme exceptins, a limitatin which has drawn criticism fr infringing n persn centered service delivery. Due t the cmplexity f the EVV system, larger agencies are experiencing an increase f 466 hurs f new labr weekly, r a need fr 10+ full time emplyees. This is an unreasnable unfunded mandate. Sme agencies are pulling managers away frm prgram supervisin t help administer this system, time they culd be using t benefit the clients. The estimated cst f this additinal administrative wrk cupled with technlgy needs and training effrts can exceed $500,000 annually. There are HIPAA and privacy vilatins in the system. Several agencies have access t clients that they d nt serve. This gives access t phne numbers, addresses, last fur digits f scial security numbers, year f birth and Medicaid numbers. 4. EXPENSE: The cst f implementatin fr all prviders has been extremely prhibitive. (Please refer t sectin 4 belw fr details.) Example fr ne, sample Prvider: Ttal Unfunded Initial Cst $27,040; Ttal Unfunded Annual Cst $532, SUGGESTIONS TO PARTNER WITH DSS TOWARDS A SOLUTION Research Sandata s capability t utilize this system fr prgrams that may be 24 hur in nature with blended services. Eliminate the backgrund schedule in the EVV system. Eliminate multiple punches in a shift. Partner with agencies fr a test perid prir t mandating that billing be dependent n the system.

3 The Alliance Cncerns Re: EVV /ABI Waiver Page 3 f 5 DETAILED INFORMATION: ELECTRONIC VISIT VERIFICATION (EVV) IMPLEMENTATION CHALLENGES FOR ACQUIRED BRAIN INJURY PROVIDERS 1. THE CHALLENGE: DSS has mandated agency prviders t use Sandata s EVV sftware t bill all claims. EVV is an electrnic visit verificatin sftware that captures caregiver visits either telephnically r thrugh a mbile applicatin, cmpares them t a schedule, and autmatically bills services t DSS. When there are any discrepancies in the system it creates an exceptin which must be fixed manually. Unfrtunately there are several facets f using the system that have prven t be unfeasible. The rllut was rushed and the system was nt fully setup. Prviders were nt given an adequate amunt f time t train their caregivers r administratrs. The system is nt well suited fr a 24 hur blended service prgram, causing a plethra f exceptins and administrative wrk. The administrative requirement t run this system and fix the extrardinary number f exclusins is unwrkable fr agencies, despite many labr hurs attempting t manage the prcess. DSS has prjected a cst savings based n EVV implementatin. Fr Prviders, the ptential cst savings may be realized based n ur inability t bill fr services rendered due t the cmplex and unmanageable nature f the sftware. These savings fr DSS are actually translating int new csts t the prviders, many f whm are nnprfits already shuldering the effect f years f budget reductins and limited r n rate increases. 2. KEY DATES OF EVV ROLLOUT: Nvember EVV was annunced at a prvider frum held at CVH. During the pen questin perid, ABI prviders shared their cncern ver caregivers needing t lg in and ut multiple times per shift. July Prvider trainings were held by Sandata acrss the state. In these trainings prviders were tld that they wuld receive welcme packets within tw weeks which wuld give prviders access t the EVV system. Packets were nt received until at least 10 weeks later. Octber Prviders receive their welcme kits. At this time the implementatin was pushed t Nvember 1 st. Octber 2016 Thrugh prvider testing, it was discvered that the system did nt include all necessary services nr was it cnfigured in a way that wuld allw prviders t mve frward in building schedules, a necessary step t train caregivers and utilize the system. Octber 5, A prvider meeting was held at BIAC where prviders expressed cncern with EVV sftware issues t DSS. DSS asked fr an f cncerns. Octber 6, An was sent t DSS and HP detailing prvider cncerns with timeline and system issues. See attached. Oct 10, A letter was sent frm CT Cmmunity Nnprfit Alliance t DSS requesting an extensin and utlining system issue. See Attached. Ultimately the deadline was changed t January 1, Nvember 23, Additinal services were laded int the system, and the issue cncerning rles was fixed. This was the first pint in time when prviders culd actually start building the database. Prviders spent tw t three weeks building their data bases and ne t tw weeks t train caregivers. This left n time fr testing the system. Fr prviders with as many as hundreds f caregivers state wide, this was nt a reasnable expectatin. Nvember 23-Dec 31 st, Prviders individually reached ut t DSS requesting mre time and utlining the lgistical prblems and barriers t successful implementatin under such an unrealistic timeline.

4 The Alliance Cncerns Re: EVV /ABI Waiver Page 4 f 5 Prviders ultimately had 5 weeks t implement a huge peratinal transitin; 3 f thse weeks were hliday weeks. Jan 1 st, EVV went live. January 6 th, Present- Mst prviders have been unable t manage the system and are verwhelmed by the number f exceptins, effectively shutting dwn their billing departments. In a phne call with DSS, prviders were tld that if they face issues that prevent them frm making payrll t infrm the agency fr pssible interim payments. 3. ADMINISTRATIVE ISSUES WITH THE EVV SOFTWARE Based n the structure f the ABI waiver, a client may receive upward f 6 different types f services in a 24 hur perid. This means that a caregiver in the field may be asked t lg in and ut f the EVV system up t 5 r mre times within an average shift. The sftware requires that these lgins may nly happen within the client s hme. Any lgins made while in the cmmunity becme exceptins, a limitatin which has drawn criticism fr infringing n persn centered service delivery. Exceptin are caused when: There are last minute changes in the schedule; call uts, caregiver switches, refusal f services Caregivers run late r early t shift (even when replacing an existing caregivers) Any and all services that ccur in the cmmunity (a key cmpnent f many participant s recvery prgram) Caregivers frget t punch in r ut Caregivers frget t switch frm ne service t anther Caregivers frget t enter a task EVV mbile applicatin ges ffline Internet/phne service prvider ges ffline On average an agency with 60 r mre clients served n the ABI waiver is experiencing apprximately 200 exceptins per 24 hur perid. Weekly this ttals 1,400 exceptins. It takes apprximately 20 minutes t crrect ne exceptin. Fr the example given abve this wuld mean 466 hurs f new labr weekly, r 10+ full time emplyees. This is an unreasnable unfunded mandate. Sme agencies are pulling managers away frm prgram supervisin t help administer this system, time they culd be using t benefit the clients. The system is cnfusing fr caregivers, causing interruptin f services. There are HIPAA and privacy vilatins in the system. Several agencies have access t clients that they d nt serve. This gives access t phne numbers, addresses, last fur digits f scial security numbers, year f birth and Medicaid numbers. The interface with prviders existing payrll systems (e.g. ADP) was nt able t be created prir t implementatin date because there was n test perid. This is causing caregivers t have t call r clck int tw separate systems (a further interruptin t services). Agencies are the nly prviders mandated t use this system. Private prviders, while receiving the same reimbursement rates, are nt subject t these cstly mandates. All services are nt currently available in EVV, which will cause duplicatin f effrt and will require the additinal burden f retraining all caregivers when new services are added in the near future. Prviders recmmended t DSS that the system shuld launch when all services are available t reduce this burden prir t January 1 st. That request was denied. Per DSS new services are anticipated t be available at the end f February. 4. EXPENSE The fllwing is an example f ne agency s actual cst t run Sandata s EVV system. This agency serves 60 clients.

5 The Alliance Cncerns Re: EVV /ABI Waiver Page 5 f 5 Technlgy (payrll interface, tablets, internet) Initial $18,500 *this agency received grant funding t aid the cst f this line item Onging annual $30,480 Training Initial (230 caregivers, 2 hurs) $5,980 Onging annual (60 caregivers, 2 hurs) $1,560 Administrative Supprt Initial (setting up database, 160 hurs) $2,560 Onging annual (prjected based n calculatin abve fr 10 FTE) $500,000 Ttal Unfunded Initial Cst $27,040 Ttal Unfunded Annual Cst $532, SUGGESTIONS TO PARTNER WITH DSS TOWARDS A SOLUTION It is recmmended that DSS explre Sandata s capability t utilize this system fr prgrams that may be 24 hur in nature with blended services. This system was well described as trying t make a square peg fit int a rund hle. Are there any ther prgrams in the natin similarly structured t the ABI waiver that utilize Sandata s EVV system? Eliminate the backgrund schedule in the EVV system. This wuld limit exceptins and administrative maintenance. Eliminate multiple punches in a shift. Have the caregiver lg in when they arrive and ut when they leave. This ensures the visit happens and the state is reimbursing frm the time the caregiver started and ended. Let the agency then split that time int the different service rles. This eliminates interruptin f services, and lessens exceptins. Partner with agencies fr a test perid prir t mandating that billing be dependent n the system. It is suggested that a test perid last tw r three mnths allwing system bugs t be identified and fixed. Additinally, this wuld give Sandata time t address Cnnecticut specific issues. With this additinal time, Sandata will be able train their custmer service caregivers n these issues s they are better able t supprt the prviders. Meanwhile the additinal time will als allw prviders t spend mre time training caregivers, thereby reducing exceptins. Thank yu again, Representative Abercrmbie. We lk frward t the pprtunity t partner with yu and DSS t reslve these cncerns and implement recmmendatins, in a cllabrative effrt t enhance the system f ABI services. Please d nt hesitate t cntact me at any time, with any questins r suggestins, r fr additinal infrmatin. Sincerely, Julia Wilcx Senir Public Plicy Specialist JWilcx@ctnnprfitalliance.rg ext. 1025