By John Graham, Chief Executive Officer, MITC
If the stories in this edition of Connections are any indication, compliance with new Electronic Visit Verification (EVV) requirements are top of mind for I/DD providers of all shapes and sizes. Here are the top 40 most commonly asked questions we receive about EVV.
1. What is needed to be EVV compliant?
The 2016 CURES Act requires a GPS coordinate or a Caller-ID number to be captured in real-time at the start and end of a visit. Individual states may have additional regulations. For example, Louisiana will not accept Caller-ID as the state system (LASRS) does not support telephony.
2. What is the difference between GPS and Caller-ID?
GPS (Global Positioning System) is captured when using an internet-enabled device such as a smart phone. Caller-ID is captured when a telephone call is made from an internet-enabled device such as a smart phone, a cell phone only device or a land-line phone. GPS cannot be captured from a phone call.
3. What are Location Services?
Location Services connect an internet-enabled device with GPS. Employees must enable Location Services on their internet-enabled device to allow GPS to be captured. Agency Workforce Management can prevent employees from clocking-in/out if Location Services are not enabled. Using this option for EVV is important. If GPS was captured, Agency Workforce Management allows providers to see the location on a map where each clock-in/out was made from. For example, if the employee clocks-in at the supermarket 8 miles away from where the individual being served lives, the provider can see that on the employees attendance records even if Geo-Fencing and Out-of-Area Alerts are not in use.
4. What is Geo-Fencing?
Geo-Fencing is not available with most state provided EVV systems and not all time and attendance systems. Agency Workforce Management allows providers to set up a geo-fence around a house for example. If the employee attempts to clockin/out for an individual identified with that house, the employee cannot clock-in/out without being within the geo-fence area. The geo-fence area can be varied for each location.
5. What are Out-Of-Area Alerts?
If individuals receive services in the community, geo-fencing may not be practical. Often the place of service delivery is unpredictable. Agency Workforce Management allows providers to set up a service circle. If an employee clocks-in in Texas when the individual lives in New Orleans, for example, the provider would receive an alert. Out-of-Area Alerts are not available with most state provided EVV systems and not all time and attendance systems.
6. Why use Geo-Fencing and Out-of-Area alerts if EVV does not require it now?
The state is capturing GPS (or Caller-ID). At some point in the future an audit may reveal that the service was not provided in an area where the individual being served lives. Better safe than sorry later. In 2018 auditors in New York requested GPS information from a provider using smart phones for time and attendance even though EVV was not implemented. Plus the goal, regardless of EVV, is to ensure vulnerable individuals receive the services tax-payers are paying for. If the employee clocks-in/out in Texas and the individual being served is in Louisiana, clearly no service was delivered.
7. I’m concerned about privacy. Does GPS track the location of staff or attendants during the entire visit?
No. GPS coordinates are only captured at the moment of clock-in and clock-out by the employee. Agency Workforce Management is does not track location continuously during or after a visit. At the provider’s discretion, Agency Workforce Management does offer the option to capture GPS coordinates during a check-in at overnight awake locations, or when an employee is sending a secured message with myCommunications.
8. What is Caller-ID?
Caller-ID is the number of the phone (Land-line or cell) placing the call. In rural areas or areas where internet-service is unreliable, tracking visits by telephone may be the only option. Telephony is acceptable under CURES 2016 but not in all states.
9. Can employees call from any phone?
Caller-ID Validation and Rejection is not available with most state provided EVV systems and not all time and attendance systems. Agency Workforce Management allows providers to enter which phone numbers are approved. For example, the landline and/ or cell-phone associated with the individual being served. Any phone calls not associated with that individual can be flagged or rejected. There is no practical limit to the quantity of phone numbers that can be associated with an individual. Caller-ID Validation checks all the calls and flags any unrecognized phone numbers. Caller-ID Rejection only accepts calls from recognized phone numbers.
10. What if the employee blocks Caller-ID?
If Caller-ID Validation and Rejection is set up, calls with blocked Caller-ID will be rejected. These calls can also be tracked to see which employees are trying to use Caller-ID Block.
To see the complete list of the top 40 most frequently asked questions about EVV, download our FAQ sheet.
For over 28 years, John Graham has worked with agencies to design solutions made to meet their unique and complex needs. As CEO of ANCOR Gold Partner MITC, John has partnered with providers throughout the United States to deliver the most cost-effective and affordable solutions that result in reduced payroll costs, increased productivity, and compliance with state and DOL regulations.