In 2010, the Missouri Department of Health and Senior Services (DHSS) established a pilot project for In-Home Services (IHS) and Consumer-Directed Services (CDS) providers to test the implementation of electronic telephone tracking systems, also known as Telephony. Participation in the program, at that time, was voluntary.
On July 1, 2015, the telephone tracking system became a requirement by law, for IHS and CDS providers. Residential Care Facilities, Assisted Living Facilities, and Adult Day Centers are not required to use telephony. The telephony requirements for IHS providers are found at RSMo 660.023.1. The requirements for CDS providers are found at RSMo 208.909.1. Theses statutes define specific requirements that a telephony system must meet, in order to be implemented by an IHS or CDS provider. They say, at a minimum, the telephone tracking system shall:
- Record the exact date services are delivered.
- Record the exact time the services begin and the exact time the services end.
- Verify the telephone number from which the services were registered.
- Verify that the number from which the call is placed is a telephone number unique to the client.
- Require a personal identification number unique to each personal care attendant.
- Be capable of producing reports or services delivered, tasks performed, client identity, beginning and ending times of service, and date of service in summary fashion that constitutes adequate documentation of services.
For IHS, the system shall also be used to process payroll for employees and for submitting claims for reimbursement to the MO HealthNet division. For CDS, the system shall also be capable of producing reimbursement requests for consumer approval that assures accuracy and compliance with program expectations for both the consumer and vendor.
DHSS, Division of Senior and Disability Services (DSDS) published a state regulation entitled, “Electronic Visit Verification”. This rule further explains the telephony requirements. It states that the system may be telephone and computer-based (telephony), or the system may utilize some other form of electronic technology (EVV). In addition, DSDS published Policy Clarification Questions and Answers. This Q&A addresses several categories of questions for Home and Community Bases Providers including Telephony/EVV.
Missouri Medicaid Audit and Compliance (MMAC) has published website posts regarding telephony in September 2014, June 2015, July 2015, and August 2015. The August 2015 post provides a Telephony Tool for IHS and CDS providers. This tool supplies providers with questions to ask potential telephony or EVV vendors, in order to help ensure the vendors’ systems meet the necessary requirements.
It is important for providers to know that small companies are not exempt from the telephony requirement. On July 1, 2016, the telephony statutes will have been in effect for one year. MMAC encourages providers to ensure they are compliant with the laws and regulation, to avoid possible sanctions. Telephony is a requirement to be an IHS or CDS provider.
Please contact MMAC at firstname.lastname@example.org with any questions.