Your definitive guide to EVV compliance

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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.

For most of the country, electronic visit verification (EVV) compliance is still a developing story. 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 their state.

How EVV compliance varies by state

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

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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 caregivers’ smartphones
  • Interactive voice response (IVR), which allows caregivers to call a toll-free number from the client’s home phone
  • A dedicated EVV device in the client’s 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, while 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. This would give them until Jan. 1, 2021, before penalties are applied. The Centers for Medicare and Medicaid Services (CMS) has compiled a list of states that have applied for an extension and the status of those requests.

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.

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 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, including 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? And what do you need to know about the new system?

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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. 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. However, Alabama has experienced some technical issues that could affect federal compliance, so it has asked for (and received) a good faith effort exemption that gives the state until January 2021 to meet CMS requirements.

Alaska

EVV model: Undecided

Alaska has not formally announced an EVV system but has solicited input from agencies, patients and families and EVV vendors. In an August 2018 presentation by Alaska Senior and Disabilities Services, officials said the state was considering either an open-vendor model or a state-run EVV solution. Alaska has been granted a good faith effort exemption and may delay implementation until January 2021 without being penalized by CMS. Check the Department of Health and Social Services (DHSS) website for updates.

Arizona

EVV model: Open vendor

Arizona and Hawaii are working together to implement EVV, with Sandata Technologies as the vendor. 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 is onboarding providers in stages and expects full implementation by mid-2020. The state has applied for a good faith effort exemption to extend the CMS compliance deadline.

Arkansas

EVV model: Open vendor

Arkansas has selected Public Consulting Group (PCG) as its state-sponsored vendor. 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 is onboarding providers in phases, so agencies should look out for notices about their implementation dates, according to the Arkansas DHS. Arkansas has received a good faith effort exemption from CMS, so the state has until January 2021 to become fully compliant.

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 Telephone 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 has been granted a good faith effort exemption to delay implementation until January 2021.

Colorado

EVV model: Open vendor

Colorado has also selected Sandata as its state-sponsored vendor. 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. However, the state has received a good faith effort exemption, which allows an additional year (until January 2021) to complete implementation. Colorado will also require EVV for services not mandated in the Cures Act.

Connecticut

EVV model: State-mandated external vendor

Connecticut implemented a closed EVV model, with Sandata as the state vendor, in 2017. Both PCS and HHCS already require EVV, including some services not mandated in the Cures Act, according to Connecticut DSS. Connecticut has been granted a good faith effort exemption, so the state has until January 2021 to ensure full compliance with CMS guidelines.

Delaware

EVV model: Open vendor

Delaware plans to implement EVV for PCS and HHCS simultaneously by the 2020 deadline. 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 they must use.

Florida

EVV model: Open vendor

Florida will simultaneously implement EVV for PCS and HHCS, as well as private duty nursing. Agencies must submit claims through the Agency for Health Care Administration (ACHA) EVV claims system, 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 the state will require all agencies to use it by Dec. 1, 2019.

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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 announced a vendor or timeline, 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. Sandata is already onboarding providers, and Arizona has applied for a good faith effort exemption to buy more time for implementation.

Idaho

EVV model: Undecided

Idaho has released a projected timeline, with plans to go live by July 2020, and drafted a list of affected services. Idaho has requested a good faith effort exemption, and the state’s Department of Health and Welfare (DHW) hosted a webinar on Dec. 10, 2019, to update stakeholders on the status of the project.

Illinois

EVV model: State-mandated external vendor

Illinois 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 clients’ homes.

Indiana

EVV model: Open vendor

Indiana has chosen 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 began a soft launch in September and expects agencies to have a solution in place by the 2020 deadline. However, the state has applied for a good faith effort exemption and plans to closely monitor the program during the first quarter of next year to ensure it meets CMS requirements before becoming subject to penalties in January 2021.

Iowa

EVV model: Undecided

Iowa has gathered feedback from agencies and is currently working with MCOs to develop and implement an EVV program. CMS has granted Iowa a good faith effort exemption, so the state has until January 2021 to implement a system.

Kansas

EVV model: State-mandated external vendor

Kansas began requiring MCOs to use the AuthentiCare EVV system for home-based services in 2014. Providers cannot use alternative vendors.

Kentucky

EVV model: Undecided

Kentucky is currently in the process of updating its IT infrastructure and shopping for an EVV vendor. The state has not yet announced its EVV model but has received a good faith effort exemption from CMS and has until Jan. 1, 2021, to implement a system.

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. 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. To collect EVV data, agencies may use Sandata’s mobile app or IVR solution or work with a state-approved alternative vendor. Maine has received a good faith effort exemption from CMS and has set a new implementation statewide deadline of July 1, 2020. Agencies can already access the new state system and may use it for both PCS and HHCS, but Maine will not require EVV for HHCS until Jan. 1, 2023.

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.

Massachusetts

EVV model: Open vendor

Massachusetts has chosen Optum as 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, Masschussetts plans to meet the federal deadline.

Michigan

EVV model: Open vendor

Michigan plans to create a state-run EVV solution and data aggregator, but will allow agencies to use third-party vendors. The state will likely apply for a good faith effort exemption.

Minnesota

EVV model: Open vendor

Minnesota plans to choose a state-sponsored EVV vendor and data aggregator but will also allow 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. CMS has granted the state a good faith effort exemption, giving Missouri until January 2021 to implement EVV.

Montana

EVV model: Undecided

Montana has conducted stakeholder meetings to gather feedback but has not announced its EVV compliance plans. CMS has granted the state a good faith effort exemption, giving Montana until January 2021 to implement a system.

Nebraska

EVV model: Open vendor

Nebraska plans to choose a state-sponsored EVV vendor and aggregator but also to allow third-party EVV solutions that integrate with the state system. The state has not announced its vendor but has applied for a good faith effort exemption.

Nevada

EVV model: State-mandated external vendor

Nevada now requires every PCS to be verified using the AuthentiCare mobile app or IVR solution. The solution went live in September 2019.

New Hampshire

EVV model: Open vendor

New Hampshire is a managed care Medicaid market, so the state has been working with MCOs to develop an EVV plan and select a state-sponsored vendor. New Hampshire has applied for a good faith effort exemption to delay implementation until January 2021.

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. 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

New York currently requires EVV for some Medicaid programs but is redesigning its EVV model to comply with the Cures Act. The Department of Community Health hosted meetings throughout the summer to gain input from agencies, members and other stakeholders. The state is now soliciting information from EVV vendors to help develop a system and has applied for a good faith effort exemption to delay implementation until January 2021.

North Carolina

EVV model: Open vendor

North Carolina will choose a state-sponsored vendor and aggregator but will allow agencies to use alternative EVV solutions that meet state requirements. North Carolina has not yet announced a vendor and has applied for a good faith effort exemption, which would allow the state an additional year to implement a solution.

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. The state has applied for a good faith effort exemption, which would allow the state to delay implementation until January 2021.

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. Ohio has applied for a good faith effort exemption, which would allow the state an additional year to onboard remaining providers.

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. Oklahoma has not announced an official timeline for implementation but has received a good faith effort exemption, which gives the state until January 2021 to meet CMS requirements.

Oregon

EVV model: State-mandated in-house system

Oregon has updated its electronic billing method, 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. Oregon began requiring agencies to use the system in July 2019.

Pennsylvania

EVV model: Open vendor

Pennsylvania 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 began a soft launch in October.

Rhode Island

EVV model: Open vendor

Rhode Island 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 received a good faith effort exemption and has until January 2021 to implement statewide.

South Carolina

EVV model: State-mandated external vendor

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

South Dakota

EVV model: State-mandated external vendor (with exceptions)

South Dakota 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. South Dakota has applied for a good faith effort exemption to delay implementation until January 2021.

Tennessee

EVV model: MCO choice

Tennessee implemented EVV in 2010 when it began using MCOs for Medicaid programs. 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 Public Partnerships LLC (PPL) system for self-directed providers.

Texas

EVV model: State-mandated external vendor

Texas 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

In Utah, agencies may partner with any EVV vendor that meets federal EVV and HIPAA requirements. Utah began requiring electronic verification for all PCS and HHCS under Medicaid on July 1, 2019, but the state has applied for a good faith effort exemption to delay the federal compliance deadline. This would give the state and providers until January 2021 to ensure all agencies meet federal requirements before the state becomes subject to CMS penaltes.

Vermont

EVV model: Open vendor

Vermont 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. CMS has granted Vermont an additional year to onboard and train agencies, but the state must meet the federal mandate by January 2021.

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Virginia

EVV model: Provider choice

In Virginia, agencies that provide Agency Directed services may choose their own EVV vendors but needed to have a solution in place by October 1, 2019 for PCS, as well as respite and companion services. MCOs will be responsible for collecting EVV data and submitting to the state. If an agency is involved with the Consumer-Directed Personal Assistance Program (CDPAP), the fiscal/employer agent (F/EA) will provide an EVV system. Virginia will continue to pay claims without electronic verification through the end of the year but will deny EVV-less claims starting January 1, 2020.

Washington

EVV model: Provider choice

Washington 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. CMS has granted Washington a good faith effort exemption, which allows the state an additional year to implement before being subject to penalty.

West Virginia

EVV model: Open vendor

West Virginia will have a state-sponsored vendor but also allow agencies to use alternative EVV solutions. The state has not yet chosen a vendor and is working with CMS to establish an implementation timeline. West Virginia has received a good faith effort exemption, which delays the federal deadline to January 2021.

Wisconsin

EVV model: Open vendor

Wisconsin has selected Sandata as its state-sponsored vendor and data aggregator, but agencies can use third-party EVV vendors that integrate with the system. Wisconsin will permit various types of solutions — including mobile apps, IVR and dedicated EVV devices. Wisconsin has been granted a good faith effort exemption, which extends the federal compliance deadline until January 2021. The state plans to start a “soft launch” soon and have a hard launch before the new deadline.

Wyoming

EVV model: Undecided

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

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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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