electronic visit verification (evv) proprietary systems workgroup ... · policy handbook update...
TRANSCRIPT
Electronic Visit Verification (EVV) Proprietary Systems Workgroup
2nd Meeting
October 22, 2019
Steve Abshier
HHSC EVV Operations
2
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.
4
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.
7
Meeting Rules and Expectations (cont.)
• 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
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 (cont.)
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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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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Timeline
Planned Workgroup Meeting Dates
• Oct. 1, 2019 – has taken place
• Oct. 22, 2019 – today’s meeting
• 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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Jordan NicholsDirector
HHSC EVV Operations
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Follow Up from Last Meeting
Reimbursement Feedback from 1st Meeting
15
Brian SmithBusiness Analyst
HHSC EVV Operations
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Onboarding Process –High Level Overview (1 of 8)
Topics covered in this document:
• Exploration
• Development
• Testing, Attestation and Training
• Production
• Maintenance
• Migration
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Onboarding Process –High Level Overview (2 of 8)
Exploration
• Workgroup sessions are used to collect feedback from interested Providers.
• Information sharing by HHSC can assist potential PSOs in making an informed decision about moving forward to the next step in the onboarding process.
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Onboarding Process –High Level Overview (3 of 8)
Development
• Each PSO will work with HHSC and TMHP to establish an implementation timeline.
Timeline Deadlines
• If a PSO does not anticipate implementation of their EVV proprietary system by 10/30/20:
• PSO must select an HHSC-approved EVV Vendor by 7/31/20 and begin the onboarding process with that Vendor.
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Onboarding Process –High Level Overview (4 of 8)
Timeline Deadlines (cont’d)
• If a PSO is currently submitting EVV visit transactions through an HHSC-approved EVV Vendor, these deadlines do not apply.
• PSO may continue to use that Vendor system until their EVV proprietary system has successfully passed the required testing, attestation and training.
• Data transfer may be required.
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Onboarding Process –High Level Overview (5 of 8)
Testing, Attestation and Training
• PSO must:
• Successfully complete trading partner testing with TMHP (the EVV Aggregator).
• Attest that their EVV proprietary system meets all state requirements.
• Train their users, including CDS Employers and Service Attendants, as applicable.
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Onboarding Process –High Level Overview (6 of 8)
Production
• PSO must:
• Capture EVV visit data in production
• Perform validations as directed by the HHSC EVV Business Rules for Proprietary Systems
• Submit EVV visit transactions to the EVV Aggregator.
• Work with TMHP to troubleshoot and resolve technical problems encountered in production.
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Onboarding Process –High Level Overview (7 of 8)
Maintenance
• Technical changes to interfaces:
• PSO will have a specified timeframe to make those changes and successfully complete testing with TMHP, if applicable.
HHSC PS Business Rule Changes
• PSO will have a minimum of 90 days to make needed system changes and successfully complete any required testing with TMHP, if applicable.
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Onboarding Process –High Level Overview (8 of 8)
Migration
• If the PSO decides to move from:
• One EVV proprietary system to another, they will complete the entire process again (Development through Testing, Attestation and Training) and work with TMHP to transition EVV activities to the new system.
• Their EVV proprietary system to an HHSC-approved EVV vendor system, they will complete the onboarding process with TMHP, and work with TMHP to transition EVV activities to the new system.
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Questions
• Questions from the room
• Questions from GoToWebinar chat
25
HHSC EVV Operations
Draft TAC Rules
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Draft Proposed TAC Rule Changes for Proprietary Systems (1 of 16)
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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Draft Proposed TAC Rule Changes for Proprietary Systems (2 of 16)
• Disclaimer: The draft document provided contains concepts which HHSC is considering drafting into Texas Administrative Code (TAC) rules.
• The document is not a formal rule draft.
• The concepts are presented in this format for ease of review and to obtain feedback from the EVV Proprietary Systems Workgroup.
• The final disposition, wording, location, and content will change.
• TAC rules pertaining to the use of an EVV proprietary system will follow the normal rulemaking process, including the opportunity for public comment.
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Draft Proposed TAC Rule Changes for Proprietary Systems (3 of 16)
• The document provided also contains proposed additions to the HHSC EVV Policy Handbook for EVV proprietary systems.
• HHSC plans to outline requirements for:
• The development/acquisition and operation of an EVV proprietary system in TAC
• The HHSC EVV Policy Handbook
• The HHSC EVV Business Rules for Proprietary Systems and
• Other supporting documentation.
29
Draft Proposed TAC Rule Changes for Proprietary Systems (4 of 16)
• The draft TAC rule changes, once reviewed by the Proprietary Systems Workgroup, will serve as the starting point for the TAC rulemaking and EVV Policy Handbook update processes.
• While the final wording will no doubt change during those processes, and additional items added, the intent of this document is to present a draft version of as much of that content as possible, to solicit feedback from the workgroup.
• Note that a Program Provider or FMSA interested in purchasing or developing their own EVV proprietary system is referred to in this document as a Proprietary System Operator. 30
Draft Proposed TAC Rule Changes for Proprietary Systems (5 of 16)
Definitions
TAC-01. State-defined EVV Standards and Requirements.
• State-defined EVV Standards and Requirements are all State-approved documentation that governs the establishment, operation and maintenance of an EVV proprietary system.
• State-defined EVV Standards and Requirements include, but are not limited to: EVV TAC Rules, HHSC EVV Business Rules for Proprietary Systems, HHSC EVV Policy Handbook and documentation governing the design, setup and use of electronic interfaces with the state - approved EVV Aggregator.
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Draft Proposed TAC Rule Changes for Proprietary Systems (6 of 16)
General
• TAC-02. EVV proprietary systems must comply with all State-defined EVV Standards and Requirements for EVV data collection, transmission, exchange, and reporting.
• TAC-03. The Proprietary System Operator must adhere to all state and federal laws, rules and regulations (HIPAA, ADA, etc.) in the design and operation of its proprietary system.
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Draft Proposed TAC Rule Changes for Proprietary Systems (7 of 16)
General (cont.)
• TAC-04. The Proprietary System Operator assumes all liability and risk for the use of their proprietary system.
• TAC-05. The Proprietary System Operator must ensure the accuracy of EVV data collected, submitted, exchanged or reported.
33
Draft Proposed TAC Rule Changes for Proprietary Systems (8 of 16)
General (cont.)
• TAC-06. The Proprietary System Operator must maintain system data, backup data and historical data to comply with and support all legal, regulatory and business needs.
• TAC-07. The Proprietary System Operator must complete an HHSC Data Use Agreement (or an updated agreement for PS?) before using a proprietary system.
34
Draft Proposed TAC Rule Changes for Proprietary Systems (9 of 16)
Changes
• TAC-08. The Proprietary System Operator must inform the state if it is not compliant with State-defined EVV Standards and Requirements.
• TAC-09. The Proprietary System Operator must provide the state with advance notice of any proposed changes to its approved proprietary system that conflict with any State- defined EVV Standards and Requirements.
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Draft Proposed TAC Rule Changes for Proprietary Systems (10 of 16)
Changes (cont.)
• TAC-10. The state will provide a minimum of 90 days for the Proprietary System Operator to make updates to their proprietary system and gain HHSC approval after a new version of the HHSC EVV Business Rules for Proprietary Systems is published. In the event an emergency change is required, an earlier effective date will be mutually agreed upon.
36
Draft Proposed TAC Rule Changes for Proprietary Systems (11 of 16)
Changes (cont.)
• TAC-11. The Proprietary System Operator assumes full responsibility to make updates to their proprietary system to gain HHSC approval for modifications by the effective date, when a new version of the HHSC EVV Business Rules for Proprietary Systems is published.
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Draft Proposed TAC Rule Changes for Proprietary Systems (12 of 16)
EVV System Access
• TAC-12. The Proprietary System Operator must provide access to their proprietary system to the state and any MCOs with which it has a contractual relationship, at no cost to the state or MCO.
• TAC-13. The Proprietary System Operator must limit MCO access to its respective member visit data only, and only for dates of service within the timeframe covered by the Proprietary System Operator contract with the MCO. This access must be allowed indefinitely after the Proprietary System Operator’s contract with the MCO ends (in accordance with applicable law).
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Draft Proposed TAC Rule Changes for Proprietary Systems (13 of 16)
Deficiencies
• TAC-14. The state may disapprove the use of a proprietary system at any time if it deems the system is unable to ensure data accuracy or integrity.
• TAC-15. The state will issue a written notice to the Proprietary System Operator specifying the reason(s) for disapproval of the use of their proprietary system if it deems the system is unable to ensure data accuracy or integrity. The state may require the Proprietary System Operator to submit a Root Cause Analysis and Corrective Action (RCCA) plan to the state. 39
Draft Proposed TAC Rule Changes for Proprietary Systems (14 of 16)
Deficiencies (cont.)
• TAC-16. The state may require the EVV Aggregator to reject all transactions from a proprietary system effective immediately if fraud, waste or abuse is suspected.
• TAC-17. Non-compliance with State-defined EVV Standards and Requirements may result in fraud, waste and abuse investigations in accordance with Texas Government Code fraud statutes.
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Draft Proposed TAC Rule Changes for Proprietary Systems (15 of 16)
Deficiencies (cont.)
• TAC-18. Non-compliance with State-defined EVV Standards and Requirements may result in the recoupment of funds for any claim that was paid based on inaccurate data.
• TAC-19. A provider payment based on inaccurate data submitted by a proprietary system may be subject to overpayment recoupment by the payer.
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Draft Proposed TAC Rule Changes for Proprietary Systems (16 of 16)
Data Ownership Feedback from Last Meeting
• HHSC has drafted a TAC placeholder to address it:
• The State will use accepted visits in the Aggregator as the system of record for Proprietary System Owner compliance and standard reports
• Do you have other feedback or ideas related to this topic?
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Break
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HHSC EVV Operations
Draft EVV Policy Handbook Rules
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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
45
Draft Proposed Policy Handbook Changes for Proprietary Systems (1 of 7)
General
• POL-01. The Proprietary System Operator must successfully complete trading partner testing and gain approval from the state and the state-approved EVV data aggregator before using the proprietary system.
• POL-02. The Proprietary System Operator assumes full responsibility for training all users on the proper use of their proprietary system.
46
Draft Proposed Policy Handbook Changes for Proprietary Systems (2 of 7)
General (cont.)
• POL-03. TMHP will assist the Proprietary System Operator in resolving production problems in their proprietary system related to EVV visit collection, visit maintenance, and functioning of the electronic interfaces with the state-approved EVV Aggregator.
• POL-04. All electronic visit verification methods must be approved by HHSC prior to use by the Proprietary System Operator.
47
Draft Proposed Policy Handbook Changes for Proprietary Systems (3 of 7)
Changing EVV Systems
• POL-05. The Proprietary System Operator must not collect EVV visit data in more than one system at a time and must transition all EVV visit collection activities to the new EVV system (state-approved EVV vendor or proprietary system) as of the onboarding effective date with the new system.
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Draft Proposed Policy Handbook Changes for Proprietary Systems (4 of 7)
Changing EVV Systems (cont.)
• POL-06. The Proprietary System Operator must follow the Provider User Transfer Process prior to beginning EVV visit collection activities in the new EVV system (proprietary or vendor), in the event the Proprietary System Operator decides to migrate from or to a state- approved EVV vendor system.
49
Draft Proposed Policy Handbook Changes for Proprietary Systems (5 of 7)
Changing EVV Systems (cont.)
• POL-07. The Proprietary System Operator is responsible for migrating all necessary data from one proprietary system to another prior to beginning EVV visit collection activities in the new system, in the event the Proprietary System Operator decides to migrate from one proprietary system to another.
• POL-08. The Proprietary System Operator is responsible for finalizing and transmitting all EVV visit data from the old EVV system to the EVV Aggregator within 60 days after the onboard effective date of the new EVV system. 50
Draft Proposed Policy Handbook Changes for Proprietary Systems (6 of 7)
Changing EVV Systems (cont.)
• POL-09. The Proprietary System Operator will be able to do visit maintenance through the old EVV system after the visit maintenance timeframe (if approved by the payer).
• POL-10. The Proprietary System Operator will be able to do visit maintenance (on EVV visits captured through their old proprietary system) using their new proprietary system, if the Proprietary System Operator transfers the visit data to their new proprietary system.
51
Draft Proposed Policy Handbook Changes for Proprietary Systems (7 of 7)
Changing EVV Systems (cont.)
• POL-11. The Proprietary System Operator is responsible for importing EVV visit data into the new system (if needed) prior to decommissioning the old system.
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Questions
• Questions from the room
• Questions from GoToWebinar chat
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Trish BurkettTechnology Program Manager
HHSC EVV
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Draft EVV Proprietary System Business Rules (1 of 3)
• You will be provided a copy of the current draft business rules for Proprietary Systems
• Business Rules that are open for comment are identified with two **
• Please review all of the business rules in the document and provide any appropriate comments to those identified with the **
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Draft EVV Proprietary System Business Rules (2 of 3)
• In our next two workgroup meetings we will cover the business rules identified as open for comment from each major section of the draft business rules.
• Proprietary System Operators will be accountable for all the Proprietary System Business Rules.
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Draft EVV Proprietary System Business Rules (3 of 3)
Major Business Rule sections are:
• User Onboarding
• Establishing Service
• Electronic Verification Methods
• Service Delivery Verification
• Reporting Requirements
• EVV Proprietary System Specifications
• Operational Readiness
• Glossary
• Appendices57
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]
