Full report attached. Observations below.
From: Bostick, M. Renee <mrbostick@voryshcadvisors.com>
Sent: Tuesday, May 1, 2018 1:19 PM
To: Anita Allen <AAllen@opra.org>
Cc: Suzanne Scrutton <sjscrutton@aol.com>
Subject: EVV
Thought you might be interested in this latest release from NASUAD on EVV. There are a couple of sections I have highlighted below that may be of interest particularly around the commitment to stakeholder involvement in order to successful
implementation.
Addressing the Unique Concerns of Participants with Disabilities
Effective and transparent stakeholder engagement is critical to the success of EVV in self-direction
programs. The NAMD/CMS survey of states found that 14 states indicated that they
plan to integrate their EVV system with their existing self-direction management systems and
processes. As noted above, the FM/FE providers already have systems that collect much of this
information.
Some participants and other disability advocates have expressed concerns about
EVV, including PCS or HHCS aides not getting paid, technology limitations in rural areas, and
invasion of privacy that will accompany GPS-enabled systems in particular.
Active and engaged
discussions with stakeholders is critical to addressing issues such as:
•
Accommodating service delivery locations with limited or no internet access;
•
Affording participants the flexibility to schedule their services based upon their own needs and preferences;
·
Ensuring that the system does not require rigid scheduling and can accommodate last minute changes;
•
Enabling services to be provided at multiple locations for each individual;
•
Allowing for multiple service delivery locations in a single visit; and
•
Providing participants with the ability to review and approve all timesheets.
Readiness Review
Several states with existing EVV systems stressed the importance of a robust readiness review
process. This process is necessary to ensure that the information technology infrastructure is
complete and operational prior to implementation, and ensures that providers, health plans,
and the state have adequate staffing and appropriate processes in place to properly use the EVV
systems. The
readiness review should also include testing to ensure that all EVV systems are
interoperable and can effectively share information with each other appropriately.
Set forth in section 12006, the CURES
Act mandates that states implement EVV for PCS
by January 1, 2019, and HHCS by January 1, 2023.
The Act also requires meaningful
stakeholder engagement and training in order to successfully launch and operate the EVV system.
CMS has provided significant technical assistance including detailed promising practices, all of
which is available on Medicaid.gov. Some states are positioned well, and have already deployed
EVV, while others are in the beginning of a statewide assessment or procurement. There are
also states in the process of launching an EVV system, and their experience can provide insight
on both successful approaches, and pitfalls to avoid. A key to success is clear and transparent
communication about the goals for the program as well as ongoing involvement by affected
parties. With those elements in place, implementation of the CURES Act mandate is more likely
to create minimal disruption to participants and providers.
Reneé
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M. Reneé Bostick, MPA
Fax: 614.719.4893 |
Vorys Health Care Advisors LLC is a wholly owned affiliate of Vorys, Sater, Seymour
and Pease LLP.
Vorys Health Care Advisors is not engaged in the practice of law or the provision of
legal services.
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