The state Agency for Health Care Administration (AHCA) will roll out a GPS tracking pilot program as part of its effort to crack down on Medicaid fraud.
This "electronic visit verification" program was originally planned for the entire state, but after feedback from providers and parents, EVV will first be tested in Broward, Miami-Dade, Monroe, Indian River, Okeechobee, St. Lucie, Martin, and Palm Beach counties starting in September.
Behavior analysts and other types of therapists who work mostly with children on the autism spectrum will be tracked through a smartphone application that verifies when and where they're working.
Andrew Houvouras, president of the Florida Association for Behavior Analysis (FABA), said their members are cautiously optimistic.
"The pilot is going to be important for the people who do pilot it to see how efficient and effective it is, to make sure it doesn't impair our ability to provide quality services to families of children who are experiencing behavior problems,” Houvouras said.
The EVV – and other changes to the Medicaid program that funds ABA therapy – are part of a year-long crackdown on fraud discovered in South Florida under former contractor Beacon Health Options.
The cost of applied behavior analysis therapy to the state more than doubled from 2016 to 2018 as unqualified providers bilked taxpayers for unnecessary services. Some of that could be attributed to a rising need for the services as more children are diagnosed with autism spectrum disorder.
The state also does not have a licensure process for the behavior analysis field, just a certification. Houvouras said this opens the state up to providers who aren't qualified to offer BA services, and are more likely to commit fraud.
The amount of money the fraud itself cost the state is unknown. FABA and WUSF have made requests for the information from AHCA, with no response.
Shevaun Harris, the Assistant Deputy Secretary for Medicaid Policy and Quality for AHCA, during a series of webinars, the last two a re-broadcast, said: "EVV has been in place for Medicaid-funded home health services for many years and has proved to be an effective deterrent to fraudulent billing practices.”
Houvouras said EVV has not been piloted yet with behavior analysts so it’s difficult for FABA to have a position about whether it’s good or bad, but they’re happy AHCA is collecting data during the pilot program to make an informed decision about whether to later expand the pilot statewide.
But providers are still concerned about privacy breaches, cellular reception or wi-fi issues, and micro-management that could cause delays in Medicaid reimbursement payments, or flags in the system for potential fraud that isn’t actually fraud.
Electronic Visit Verification services for behavior analysis will be provided through an Agency contracted vendor - Tellus, LLC . The cost of the contract will be $1.2 million annually. The costs are eligible for a 50% federal match, so only $600,000 is attributable to state funding under the Contracted Services portion of the Medicaid budget.
The appropriation was made during the 2019 Legislative session for State Fiscal Year 19-20.
Other changes include:
The Agency will not change rates for behavior analysis services in 2019 after being flooded with phone calls and emails from providers and parents.
“We have received requests to never change the rates. Here’s our commitment: When we review rates again, we will not start with our own assumptions and data. We will use your salary and cost data as a starting point to help us understand the driver. This will be done collaboratively with the Florida Association for Behavior Analysis,” Harris said.
AHCA also clarified clinic licensure requirements, answered questions about proper documentation, and discussed another controversial pilot program called “Multidisciplinary Team Approach,” or MDT, which will be rolled out in Baker, Clay, Duval, Flagler, Nassau, St. Johns, Volusia, Brevard, Orange, Osceola, and Seminole counties.
The Agency is requesting federal permission to partially lift the BA provider enrollment moratorium in Miami-Dade and Broward counties. – Includes registered behavior technicians, lead analysts, and board certified assistant behavior analysts seeking enrollment to participate as a member of provider group that is already enrolled in Florida Medicaid. The moratorium will remain in effect for new group providers and lead analysts practicing independently.
“We’ve started to be heard by AHCA,” Houvouras said. “They have been receptive and reached out to us…we felt like AHCA is attempting to understand the perspective of our parents, our providers, and our association.”
But he says there are still delays in services, and providers are upset over authorization clogs, frozen payments, and credentialing issues that meant some children lost their services temporarily or permanently last year and in eary 2019, while others sit on clinic waitlists.
Houvouras says the changes are a team effort, and providers need to also look inward and make sure they’re diligent about their documentation, and are ready to have hard conversations about how many hours of therapy a child actually needs.
And perhaps most importantly, he says, parents need to continue to reach out to their elected representatives.
“The key for all this change will be fostered by parents. You can be the most credentialed, respected, most prolifically published behavior analyst in the world and it’s the story of a parent and a child that’s going to move the legislature to act,” Houvoura said. “This is not a track meet; it’s a marathon and we have to be ready to run it.”
You can view the webinar that outlines the new changes in both video and PDF form.
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