The deadline for electronic visit verification (EVV) is fast approaching. Beginning January 1, 2020, home care agencies that provide personal care services (PCS) must have an EVV solution in place or risk having their Medicaid claims denied.
Part of the 21st Century Cures Act, which was passed in 2016 with bipartisan support, the EVV mandate is meant to curb healthcare fraud and waste. According to the federal mandate, states must require electronic verification for PCS visits starting next year, and for home healthcare services (HHCS) visits by January 1, 2023.
What does this mean for home care agencies? What will it take to be compliant? The answer depends largely on the state.
What Is the EVV Mandate?
The 21st Century Cures Act defines electronic visit verification and suggests some possible approaches, but it lets states decide exactly how to gather and report EVV data. In other words, it doesn’t tell states how to create an EVV system for home care — just that they must do it.
States that don’t comply with the EVV mandate could lose up to 1 percent of their Federal Medical Assistance Percentage — the federal government’s contribution to Medicare and Medicaid claims. That means states will have to pay a larger share of the bill.
Several states have already implemented an EVV system for home care, others are still scrambling to get solutions in place and some might be granted an additional year before implementation. The mandate provides “limited exception for the first year of the requirement if the state has both made a good faith effort to comply with the EVV requirements and has encountered unavoidable delays in implementation of an EVV system.” States that need additional time must request it by July 2019.
Regardless of where each state stands, agencies that provide PCS and HHCS need to be ready to comply sooner rather than later.
What Is Electronic Visit Verification?
EVV means being able to provide electronic proof of each caregiver visit. At a minimum, an EVV solution must verify:
- Type of service provided
- Individual receiving the service
- Date of service
- Location of service delivery
- Individual providing the service
- Time the service begins and ends
States can require additional information and set their own policies about how and when EVV data should be submitted.
Which Services Must Be Electronically Verified?
According to the Centers for Medicare & Medicaid Services (CMS), “All services requiring an in-home visit that are included in claims under the home health category or personal care services category on the CMS-64 form are subject to the EVV requirement.”
Simply put, if a personal care or healthcare service is provided in a private home, and if Medicaid or Medicare is paying for it, EVV is required. Care services that are provided to hospital inpatients or nursing home residents do not require EVV.
How Can Service Be Electronically Verified?
The federal government has suggested several possible EVV models but each state gets to decide which are acceptable for the agencies within its borders. These options include:
- Mobile EVV apps that leverage GPS tracking
- Telephone calls placed from the patient’s landline at the beginning and end of service delivery
- Biometric sensors installed in patients’ homes
Most states and agencies are opting for mobile solutions because they are less expensive than biometric scanners and more reliable than landline phones, which many people no longer have.
Can Agencies Choose Their Own EVV Solutions?
That varies dramatically from state to state. CMS suggests five major EVV system models that states might choose from:
- Provider Choice Model: Agencies choose their own EVV vendor and fund the implementation. States set EVV standards and data collection requirements. States using this model may or may not provide an approved list of EVV vendors. (Missouri currently operates a provider choice model. Alaska, New York, West Virginia and Utah reportedly plan to adopt this model.)
- MCP Choice Model: Agencies work with Managed Care Plans (MCPs) that select and reimburse EVV vendors. (New Mexico, Tennessee and New Jersey are using or planning to adopt this model.)
- State Mandated In-House Model: The state develops and operates its own EVV system. Under this model, the federal government will fund 90 percent of the system implementation and 75 percent of ongoing costs. (Maryland currently operates a state mandated in-house model, and Massachusetts plans to create one for PCS.)
- State Mandated External Vendor Model: States select and contract with a single EVV vendor to implement a state-wide solution. The federal government also helps cover the costs for this model. (Twelve states currently use or report plans to adopt this model: Arizona, Connecticut, Florida, Illinois, Kansas, Mississippi, Montana, Ohio, South Carolina, Washington, West Virginia and the District of Columbia.)
- Open Vendor Model: In this hybrid model, states contract with at least one EVV vendor or operate their own in-house system, but also allow providers and MCPs with existing EVV solutions to continue using their current vendors. (Louisiana and Texas currently use this model. North Dakota and Massachusetts report plans to do so as well.)
What Happens if Agencies Fail to Comply?
That also depends on the state, but considering how much federal funding states stand to lose if they fail to comply, most will consider EVV mandatory.
Texas, for example, began requiring an EVV system for home care in 2015, a year before the 21st Century Cures Act was passed. If home care agencies in Texas submit a Medicaid claim without EVV, the state denies the claim and withholds reimbursement. If agencies fail to comply with EVV policies, the state will place the provider on a corrective action plan or cancel the agency’s Medicaid contract altogether.
What Are the Benefits of EVV for Agencies?
The Congressional Budget Office expects EVV systems to save the federal government $290 million over 10 years by preventing Medicaid fraud. That’s great news for taxpayers, but what advantage does EVV provide agencies, aside from just compliance?
For smaller agencies that haven’t already invested in mobile solutions, EVV is yet another reason to embrace digital transformation. With the right software integrations, smartphones can provide agencies with many benefits, including the ability to:
Communicate with caregivers in the field via multiple channels such as talk, text and video
Boost caregiver productivity by enabling real-time charting and documentation
Automate timekeeping for payroll
Track mileage and other care provider costs
Monitor caregiver safety
Provide caregivers with turn-by-turn directions to patients’ homes
Optimize caregiver schedules and routes for greater efficiency
Integrate with electronic health records (EHRs)
By deploying smartphones to field workers, home care agencies will be able to do more than just meet the EVV mandate: They can also improve communications and enhance business processes.
In other words, EVV doesn’t have to be just another burdensome government shift for home care agencies. It can also be a timely opportunity to future-proof organizations and eip caregivers with tools that help them work faster and smarter, and deliver the best possible patient experience.
Regardless of who is paying for devices, EVV doesn’t have to break the bank. Learn more about affordable, HIPAA-compliant Samsung smartphones.