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What Are the EVV Compliance Rules in Your State?

Looking for the basics of EVV in home care? Get up to speed before the Jan. 1, 2020 deadline.

Electronic visit verification (EVV) compliance is still a developing story in most states. With the Jan. 1, 2020 deadline looming, only a handful of states have successfully implemented solutions to meet the federal EVV mandate, but most have a plan in place, or at least in the works.

What do personal care agencies need to know to get started with EVV compliance? That depends entirely on your state.

How EVV Compliance Varies by State

The federal mandate requiring EVV is part of the 21st Century Cures Act. It outlines key data points that must be collected and electronically verified, but states create their own systems. They decide how to gather and report data that EVV vendors use, and whether to include additional EVV compliance rules.

There are a few basic models EVV regulations can take from state to state.

  • Open Vendor: Providers can use a state-sponsored vendor free of charge or choose another EVV vendor at their own cost.

  • State Mandated External Vendor: Providers must use a state-sponsored vendor.

  • State Mandated In-House System: States build and manage their own EVV system that all providers must use.

  • Provider Choice: Providers select their vendor of choice and are responsible for the cost.

  • Managed Care Organization (MCO) Choice: MCOs select a vendor for all their agencies to use.

Most states are selecting a state-sponsored vendor. That’s because EVV systems operated by the state or by a state-sponsored vendor qualify for enhanced federal medical assistance percentage (FMAP) matching funds — 90 percent for implementation, 75 percent for ongoing costs, according to the Congressional Research Service.

States also decide how to verify data, which can be done using:

  • A GPS-enabled mobile app installed on caregiver smartphones.

  • Interactive voice response (IVR), which allows caregivers to call a toll-free number from the client’s home phone.

  • A dedicated EVV device at the client home.

EVV compliance deadlines also vary by state. The federal mandate requires EVV for personal care services (PCS) beginning Jan. 1, 2020, and for home healthcare services (HHCS) beginning Jan. 1, 2023. However, some states already require EVV for both or will implement both at the same time. Some plan to roll out new EVV compliance rules before the federal deadline, and others will ask for an extension. Under the federal mandate’s “good faith effort” exemption, states may request up to an additional year if they can prove they’ve tried to implement on time but have encountered unavoidable delays, according to the Center for Medicaid and CHIP Services (CMCS).

Getting Started With EVV Compliance

Regardless of where your state stands with EVV, home care agencies need to be ready to comply when the state says “go.” That means understanding the new state system, implementing a state-approved solution, training staff to use it, and testing the tech for kinks before it affects Medicaid reimbursement.

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For providers in many states, it also means deciding how to deploy mobile EVV solutions. Taking a Bring Your Own Device (BYOD) approach — where caregivers are expected to use their own smartphones to verify visits — can create security and reliability challenges. Staff who are required to use their personal phones and data plans for work will also expect some form of mobile stipend. With corporate-owned devices, agencies can ensure devices are secure, reliable and only used for work.

To help make mobile EVV more affordable for agencies, Samsung has partnered with leading software providers such as Tellus EVV and Actsoft to offer bundled packages that include smartphones, a data plan and an EVV solution that meets all state and federal requirements. So, no matter where your state stands, you’re ready to go.

Where does your state stand? What do you need to know about the new system?

EVV State by State Overview

Alabama

EVV Model: State Mandated External Vendor

Alabama implemented EVV in October 2017. The AuthentiCare Electronic Visit Verification and Monitoring (EVVM) system is now required for all in-home visits that Medicaid covers through the Home and Community Based Waiver Services program, including PCS and HHCS, according to Alabama Medicaid. The solution includes a mobile app, IVR and a backend system that automatically creates claims for agencies to review and submit via a web portal.

Alaska

EVV Model: Undecided

Alaska has yet to formally introduce an EVV system, but has been soliciting input from agencies, patients and families and EVV vendors. In an August 2018 presentation by Alaska Senior and Disabilities Services (DSDS), officials said the state was considering either an open vendor model or a state-run EVV solution. You can follow the DSDS website for updates.

Arizona

EVV Model: Open Vendor

Arizona and Hawaii are working together to implement EVV, with Sandata Technologies as the vendor, according to the Arizona Health Care Cost Containment System (AHCCCS). Providers can use Sandata’s mobile EVV solution for data collection or choose an alternate vendor that integrates with Sandata’s data aggregator. The states will fund the implementation of Sandata and are still considering helping providers pay for mobile devices. Arizona plans to have the solution fully implemented by October 2019.

Arkansas

EVV Model: Open Vendor

Arkansas has selected Public Consulting Group (PCG) as its state-sponsored vendor, according to the Arkansas Department of Human Services (DHS). In-home caregivers can use PCG’s Careify mobile app or a state-approved alternative vendor. All Arkansas EVV vendors are required to send their data to PCG’s third-party data aggregator. From there agencies can review and submit claims. PCG will onboard agencies in phases, beginning in August and wrapping up by late fall, so agencies should look out for notices about their implementation dates, according to the Arkansas DHS.

California

EVV Model: State Mandated In-House System

California already uses two systems to monitor agencies that provide Medicaid-funded PCS: the Electronic Services Portal (ESP) and the Telephonic Timesheet System. The state plans to integrate EVV features into these systems so that providers can access the EVV solution using any internet-connected device or landline telephone. Upgrading these systems will take a couple years, so the state will seek a “good faith effort” exemption.

Colorado

EVV Model: Open Vendor

Colorado has also selected Sandata as its state-sponsored vendor, according to the Colorado Department of Health Care Policy and Financing (DHCPF). Agencies can use Sandata’s mobile app/web portal or IVR solution, or an alternative EVV solution that successfully integrates with Sandata’s data aggregator. Colorado will implement EVV for HHCS and PCS simultaneously, rather than waiting until the 2023 federal deadline for HHCS. The state will also require EVV for services that are not mandated in the Cures Act, according to the DHCPF.

Connecticut

EVV Model: State Mandated External Vendor

Connecticut implemented a closed EVV model, with Sandata as the state vendor, in 2017 according to the Connecticut Department of Social Services (DSS). Both PCS and HHCS already require EVV, including some services not mandated in the Cures Act, according to Connecticut DSS.

Delaware

EVV Model: Open Vendor

Delaware plans to implement EVV for PCS and HHCS simultaneously by the 2020 deadline, according to Delaware Health and Social Services (HSS). Agencies may continue working with their existing vendors, but Delaware is currently in the process of selecting a state-sponsored vendor with an EVV solution that agencies can use and a statewide data aggregator that agencies must use.

Florida

EVV Model: Open Vendor

Florida’s Agency for Health Care Administration (AHCA) will simultaneously implement EVV for PCS and HHCS, as well as private duty nursing. Agencies must submit claims through the ACHA EVV claims system, which is powered by Tellus. Agencies may choose their own EVV vendor for data collection or use the state-funded Tellus mobile app with provider dashboard. Some Florida health insurers have already begun requiring EVV, and Florida projects full implementation by October.

Georgia

EVV Model: Open Vendor

Georgia plans to choose a state-sponsored vendor, but providers can use third-party vendors as long as they integrate with the state system. The state has not yet named a vendor, but Georgia Medicaid has provided an EVV overview and a list of services that will be affected.

Hawaii

EVV Model: Open Vendor

Hawaii is working with Arizona to implement EVV, because Arizona provides the IT infrastructure for Hawaii. Providers can use Sandata’s mobile EVV solution for data collection or choose an alternative vendor, but Sandata will aggregate all the data for claims processing. The states will fund the implementation of Sandata and are still considering helping providers pay for mobile devices. Arizona expects to implement EVV by October.

Idaho

EVV Model: Undecided

Idaho recently conducted its stakeholder survey and plans to announce an EVV model later this summer. The state’s Department of Health and Welfare (DHW) has already released a projected timeline, with plans to go live by July 2020. DHW also has a list of affected services.

Illinois

EVV Model: State Mandated External Vendor

Illinois’ Department of Human Services (DHS) implemented Sandata’s EVV solution for its Home Services Program in 2014. Providers have multiple verification options, including mobile apps, IVR and verification devices installed in client homes.

Indiana

EVV Model: Open Vendor

Indiana selected Sandata as the state-sponsored EVV vendor and required aggregator. Providers may use alternate vendors, if those vendors meet the requirements for Sandata’s aggregator. Indiana plans to onboard agencies for a soft launch beginning in September and to be ready by the 2020 PCS deadline.

Iowa

EVV Model: Undecided

Iowa has gathered feedback from agencies and is currently working with MCOs to develop and implement an EVV program. The state has not announced its model or whether it plans to meet the 2020 deadline.

Kansas

EVV Model: State Mandated External Vendor

Kansas began requiring MCOs to use the AuthentiCare EVV system for home-based services in 2014, according to KanCare. Providers do not have the option to use alternative vendors.

Kentucky

EVV Model: Undecided

Kentucky is currently in the process of updating the state IT infrastructure and shopping for an EVV vendor, according to its Department for Medical Services (DMS). The state has not yet announced its EVV model or whether it will meet the federal deadline.

Louisiana

EVV Model: Open Vendor

Louisiana began requiring EVV for PCS in February 2018, with Statistical Resources Inc. (SRI) as the state-sponsored vendor and data aggregator, according to its Department of Health. Agencies may use third-party vendors that integrate with the state system. EVV data must be gathered using smart devices with GPS. The state does not pay for these devices. Agencies can manually create or edit entries in the EVV system, but at least 90 percent of claims must have digital verification or the state will temporarily block some claims.

Maine

EVV Model: Open Vendor

Maine partnered with Sandata for its state EVV system, according to MaineCare Services. To collect EVV data, agencies may use Sandata’s mobile app or IVR solution, or work with a state-approved alternative vendor. Agencies can already access the new state system. Beginning Jan. 1, 2020, PCS claims will be denied if EVV is not complete. Maine will not require EVV for HHCS until Jan. 1, 2023, but agencies can use the state system to implement EVV for both types of services in 2020.

Maryland

EVV Model: State Mandated In-House System

Maryland already had a phone-based EVV system in place, as part of its Long Term Supports and Services (LTTS) system. The state plans to update the system to meet Cures Act requirements, and is currently developing an implementation plan to onboard providers that weren’t previously using the system, according to the Maryland Department of Health.

Massachusetts

EVV Model: Open Vendor

Massachusetts has chosen Optum for its state-sponsored vendor. Agencies can either use Optum’s MyTimesheet EVV app, or an alternative EVV vendor that leverages GPS and successfully integrates with the state’s data aggregator. According to its estimated timeline, alternative EVV systems will go live by Sept. 1, and the state system will go live on Nov. 1.

Michigan

EVV Model: Open Vendor

The Michigan Department of Health and Human Services (DHHS) plans to create a state-run EVV solution and data aggregator, but will allow agencies to use third-party vendors. The state has not yet announced what the state EVV solution will look like or whether it will be implemented by the federal deadline.

Minnesota

EVV Model: Open Vendor

Minnesota plans to choose a state-sponsored EVV vendor and data aggregator, but will allow for alternative vendors that meet state requirements. The state’s EVV information page features a list of affected services and EVV requirements, but has not yet announced a timeline or state-sponsored vendor.

Mississippi

EVV Model: State Mandated In-House Model

Mississippi implemented its own telephone-based EVV solution, Medikey, in 2018. Agencies cannot use alternative vendors.

Missouri

EVV Model: Open Vendor

Missouri began requiring EVV for several PCS waiver programs in 2016, so many agencies are already using an EVV solution. However, several programs that did not require EVV under state law will require it under the federal mandate. Missouri is in the process of drafting a new state EVV plan and will select a state-sponsored vendor and aggregator. Agencies can use the state vendor or continue using their existing solutions, if those solutions integrate with the state’s aggregator.

Montana

EVV Model: Undecided

Montana has not announced its EVV compliance plans.

Nebraska

EVV Model: Open Vendor

Nebraska plans to choose a state-sponsored EVV vendor and aggregator, but to allow third-party EVV solutions that integrate with the state system, according to its DHHS. The state has not announced its vendor.

Nevada

EVV Model: State Mandated External Vendor

Nevada will require all PCS to be verified using the AuthentiCare mobile app or IVR solution, according to its Division of Health Care Financing and Policy. The state is currently onboarding agencies and expects to go live by August 2019.

New Hampshire

EVV Model: Undecided

New Hampshire is a managed care Medicaid market, so the state has been working with MCOs to develop an EVV plan. New Hampshire began shopping for vendors earlier this year, according to its DHHS, but has not announced any details about the state’s chosen EVV model.

New Jersey

EVV Model: Undecided

New Jersey reportedly plans to use an open model, with a state-sponsored vendor and data aggregator that allows for third-party EVV vendors, according to the New Jersey Association of Community Providers. However, the state has not officially announced its plan and will likely ask for additional time under the “good faith effort” exemption.

New Mexico

EVV Model: State Mandated External Vendor

MCOs in New Mexico are currently implementing the state’s new AuthentiCare EVV system. The state already requires EVV for certain PCS visits, and MCOs will onboard everyone else by the federal deadline. EVV compliance rules and implementation procedures may vary by MCO. For example, BlueCross BlueShield of New Mexico (BCBSNM) requires the agencies that it manages to use IVR whenever possible. Otherwise, caregivers may use the AuthentiCare mobile app and be reimbursed for data usage. If neither option is possible, BCBSNM will provide restricted-use Android tablets.

New York

EVV Model: Undecided

The New York Department of Health currently requires EVV for some Medicaid programs but is redesigning its EVV model to comply with the Cures Act. The Department of Community Health is hosting community meetings throughout the summer to gain input from agencies, members and other stakeholders.

North Carolina

EVV Model: Open Vendor

North Carolina’s Medicaid Division of Health Benefits will choose a state-sponsored vendor and aggregator, but will allow agencies to use alternative EVV solutions that meet state requirements. The state has not yet announced a vendor or implementation timeline.

North Dakota

EVV Model: Undecided

North Dakota held public meetings in 2018 to gather stakeholder input but has not announced any details about its chosen EVV model or implementation schedule.

Ohio

EVV Model: Open Vendor

Ohio already requires EVV for its fee-for-service Medicaid program, including both PCS and HHCS, and is currently onboarding other affected programs. Agencies and MCOs may use the state vendor, Sandata, or an alternative vendor that integrates with the state system. Ohio encourages providers to use mobile EVV apps but will permit IVR when there’s not a mobile option.

Oklahoma

EVV Model: State Mandated External Vendor

Oklahoma will use the AuthentiCare EVV solution and data aggregator. Agencies may use the mobile app or IVR, but cannot use alternative EVV vendors. The state has not announced an official timeline for implementation.

Oregon

EVV Model: State Mandated In-House System

Oregon has updated its electronic billing system, Express Payment and Reporting System (eXPRS), to gather and report required EVV data. The new system includes a mobile-friendly website for in-home caregivers, or they can access the system using a computer, according to eXPRS. Caregivers that provide affected PCS must begin using the system by July 16, 2019, according to Oregon’s DHS.

Pennsylvania

EVV Model: Open Vendor

Pennsylvania’s DHS is working with Sandata to develop an EVV system that integrates with PROMISe, the state’s Medicaid management information system. Providers can use Sandata’s mobile app or IVR solution, or use alternative EVV vendors that integrate with the state system. Pennsylvania has published a list of affected services and programs, and anticipates a soft launch in October.

Rhode Island

EVV Model: Open Vendor

Rhode Island’s Executive Office of Health and Human Services (EOHHS) has chosen Sandata for its state-funded EVV vendor and data aggregator, but agencies and MCOs may use alternative vendors that integrate with the state system. Rhode Island has not published an official timeline but plans to implement by the federal deadline.

South Carolina

EVV Model: State Mandated External Vendor

South Carolina already uses EVV for some services but has not yet announced its plans to meet the federal mandate.

South Dakota

EVV Model: State Mandated External Vendor (with exceptions)

South Dakota’s DHS has chosen Therap as its state-sponsored EVV vendor and data aggregator. The state strongly encourages agencies to use this solution, but if a provider “determines utilization of the State’s EVV system is not feasible,” they can request a waiver and be granted permission to use an alternative solution. However, the agency will be responsible for uploading EVV to the state system. The Therap EVV solution has an IVR option, but the state says caregivers should use the web or mobile application whenever possible. South Dakota will also use Therap to replace other paper-based billing forms.

Tennessee

EVV Model: MCO Choice

Tennessee implemented EVV in 2010 when it began using MCOs for Medicaid programs, according to the National Association of States United for Aging and Disabilities (NASUAD). Each MCO can select its own EVV vendor for agencies to use. Self-directed providers use a financial supports broker system, which has an EVV system. Agencies that provide PCS funded by Tennessee’s Department of Development and Intellectual Disabilities are not managed by MCOs and have not previously been required to use EVV. Tennessee is requiring these agencies to use the Sandata EVV solution or the PLL system for self-directed providers.

Texas

EVV Model: State Mandated External Vendor

Texas’ DHHS implemented EVV for most home-based care in 2015, but has revised its model to comply with the federal mandate. Agencies (or their MCOs) had two EVV options in the past but will now have only one: Vesta EVV. Providers are required to use the mobile app.

Utah

EVV Model: Provider Choice

Agencies in Utah may partner with any EVV vendor that meets federal EVV and HIPAA requirements. Utah will update its Medicaid policy this summer to include EVV compliance rules.

Vermont

EVV Model: Open Vendor

The Department of Vermont Health Access has selected Sandata as the state-sponsored vendor and data aggregator, but agencies may use third-party EVV solutions that integrate with the state system. Vermont has not published any further details at this time.

Virginia

EVV Model: Provider Choice

Agencies that provide Agency Directed services in Virginia may choose their own EVV vendors, but must have a solution in place by Oct. 1 for PCS as well as respite and companion services, according to Virginia’s Department of Medical Assistance Services. MCOs will be responsible for collecting EVV data and submitting to the state. If an agency is involved with the Consumer Directed program, the Fiscal/Employer Agent will provide an EVV system.

Washington

EVV Model: Provider Choice

The Washington State Department of Social and Health Services (DSHS) already requires EVV for home care agencies that provide Medicaid services, including PACE-contracted Home Care Agencies. Providers choose their own EVV vendors and will be responsible for ensuring their solutions meet the new federal EVV requirements. In addition to the data required by the federal mandate, DSHS requires EVV systems to track services at a task level and include client verification of services performed. All EVV vendors must integrate with the ProviderOne billing system, and Washington is currently working on a phased implementation to ensure agencies are ready by the 2020 deadline.

West Virginia

EVV Model: Open Vendor

West Virginia’s Department of Health and Human Resources will have a state-sponsored vendor but allow agencies to use alternative EVV solutions. The state has not yet chosen a vendor.

Wisconsin

EVV Model: State Mandated External Vendor (or Open Vendor)

Wisconsin has selected Sandata as its state-sponsored vendor and has proposed a closed model where all agencies must use the Sandata EVV solution. However, the state is currently considering whether to implement Sandata’s data aggregator, which would allow agencies to use third-party EVV vendors that integrate with the system.

Wyoming

EVV Model: Undecided

Wyoming has not yet selected an EVV model or announced details about implementation.

Register for our webinar on August 13, 2019 to learn how Samsung’s solution made in partnership with Actsoft streamlines the EVV process. Or, explore Samsung’s healthcare solutions to see the cutting edge of innovation and compliance with increasing regulations.

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Taylor Mallory Holland

Taylor Mallory Holland is a professional writer with more than 11 years of experience writing about business, technology and healthcare for both media outlets and companies. Taylor is passionate about how mobile technology can reshape the healthcare industry, providing new ways for care providers to connect with patients and streamline workflows. She stays on top of emerging trends and regularly speaks with healthcare industry leaders about the challenges they face and how they innovate using mobile technology. Follow Taylor on Twitter: @TaylorMHoll

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