A Comprehensive Guide to Compliance and Best Practices

The Office of Developmental Programs (ODP) is vital in overseeing services for individuals with developmental disabilities in Pennsylvania. With the introduction of Electronic Visit Verification (EVV) mandated by the 21st Century Cures Act, ODP has become even more critical in ensuring that service delivery is compliant, accurate, and transparent. This article explores the essential aspects of ODP, the role of EVV, and how home care providers can maintain compliance, particularly with regard to rounding rules and clean process management.

Understanding ODP and EVV

ODP, a division of the Pennsylvania Department of Human Services (DHS), manages services for individuals with intellectual and developmental disabilities through various waivers. These waivers, including the Consolidated Waiver, the Person/Family Directed Support (P/FDS) Waiver, the Community Living Waiver, and the Adult Autism Waiver, offer support services designed to enhance daily living for individuals in need.

The EVV system, required by law, captures key data points during service delivery:

1. Type of service(s) provided

2. Individual receiving the service(s)

3. Date of service(s)

4. Location of service(s) delivery

5. Care worker(s) providing the service(s)

6. Time the service(s) begins and ends

These data points are then submitted to the DHS EVV Aggregator, a system that consolidates data from various EVV systems to validate claims and ensure accurate billing.

The Importance of Rounding Rules

Accurate timekeeping is crucial for compliance with the Office of Developmental Programs (ODP) guidelines. ODP has established specific rounding rules to ensure that service units are billed correctly. Below are the rounding rules and examples of how they apply in real-world scenarios:

For 15-Minute Units:

• 0 to 14 minutes: 0 units

• 15 to 29 minutes: 1 unit

• 30 to 44 minutes: 2 units

• 45 to 59 minutes: 3 units

Example Scenarios

1. 15-Minute Unit Example:

   • Scenario: A Direct Support Professional (DSP) provides in-home support for a client from 10:00 AM to 10:20 AM.

   • Calculation: The total time spent is 20 minutes.

   • Rounding: According to the rounding rules, 20 minutes falls within the 15 to 29 minutes range.

   • Billing: The provider should bill for 1 unit.

2. Multiple Units Example:

   • Scenario: A DSP provides home health care services from 1:00 PM to 2:10 PM.

   • Calculation: The total time spent is 1 hour and 10 minutes, which equals 70 minutes.

   • Rounding: According to the rounding rules, 70 minutes falls within the range for 4 units (1 hour and 10 minutes is 4 units: 3 units for the first 45 minutes, plus 1 unit for the next 15 minutes).

   • Billing: The provider should bill for 4 units.

3. Non-Billable Time Example:

   • Scenario: A DSP provides quick support for a client for 10 minutes from 3:00 PM to 3:10 PM.

   • Calculation: The total time spent is 10 minutes.

   • Rounding: Since 10 minutes falls within the 0 to 14 minutes range, this time does not qualify for a billable unit.

   • Billing: The provider cannot bill for this time.

These scenarios demonstrate how the rounding rules apply in practice. Each unit represents 15 minutes, and it’s essential to accurately record the time to ensure proper billing and compliance with ODP guidelines.

Ensuring a Clean Process and Compliance

To maintain compliance and ensure a smooth process, home care providers must implement several best practices:

1. Regular Training and Updates:

   • Ensure that all Direct Support Professionals (DSPs) and administrative staff are thoroughly trained on EVV systems and updated on any changes in ODP or EVV guidelines. This includes understanding the importance of accurately capturing service delivery times and locations.

2. Regular Review of EVV Data:

   • Routinely monitor and review EVV data before submitting claims. This can help identify any discrepancies or errors that need correction before claims are processed. The EVV Compliance Report available in the DHS Aggregator is a valuable tool for this purpose.

3. Manual Adjustments with Documentation:

   • When manual adjustments to EVV records are necessary (for example, if a check-in or check-out time was not captured correctly due to technical issues), ensure that these adjustments are fully documented. The rationale for each adjustment should be clear, and records should be resubmitted to the DHS Aggregator before claims are processed.

4. Compliance with Place of Service Codes (POS):

   • Accurately enter the correct place of service codes on claims, as these are essential for claims validation. ODP services are associated with specific POS codes that must match the EVV records to avoid claim denials.

5. Avoiding Overlapping Shifts:

   • In cases of 2:1 staffing ratios, ensure that overlapping shifts do not result in multiple care workers clocking in simultaneously. If this occurs, it could trigger error status codes and lead to claim denials. Adjustments should be made to reflect accurate time records, with overlapping shifts minimized or manually corrected.

6. Routine Compliance Monitoring:

   • Leverage ODP's resources, such as the EVV Manual Threshold Compliance monitoring and the Quarterly Progress Notices, to stay informed about compliance status. Regularly reviewing these notices and reports can help prevent issues before they arise.

7. Documentation and Support:

   • Maintain detailed records that demonstrate compliance with all ODP and EVV requirements. These records should include all service plans, time logs, and any manual adjustments made. In the event of an audit or dispute, thorough documentation can be invaluable.

Conclusion

The Office of Developmental Programs and its associated Electronic Visit Verification system are essential in ensuring that services for individuals with developmental disabilities are delivered with integrity and transparency. For home care providers, understanding and adhering to ODP guidelines, particularly regarding rounding rules and compliance processes, is crucial for successful operations.

By implementing best practices, regularly reviewing EVV data, and ensuring all staff are well-trained and informed, providers can maintain a clean, compliant process that meets all state and federal requirements. Staying proactive and vigilant in these areas not only ensures compliance but also enhances the quality of care provided to individuals with developmental disabilities.

For more detailed information and resources, visit the ODP EVV resources page​ (ODP-EVV-Guidance_Versio…).