How to create a mobile-first hospital

Get your free guide to modernizing clinical communications with smartphones.

Download Now
Hospital

What are the EVV compliance rules in your state?

Looking for the basics of EVV in home care? Get up to speed before your state’s deadline.

For most of the country, electronic visit verification (EVV) compliance is still a developing story. Only a handful of states met the federal EVV mandate deadline for personal care services on Jan. 1, 2020. The rest have a plan in place and received a “good faith effort” exemption, which provides an additional year to implement EVV and iron out any issues. Most states’ efforts have been hampered by COVID-19, but as of now, the Centers for Medicare & Medicaid Services (CMS) haven’t reextended the deadline.

What do personal care services (PCS) 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 for EVV is part of the 21st Century Cures Act. The legislation outlines key data points that need to be collected and electronically verified, but states can create their own systems. Each state decides how to gather and report EVV vendor data and whether to include additional compliance rules.

There are a few basic EVV models that states can choose from:

  1. Open vendor: State selects an EVV vendor and data aggregator. Providers can use state-sponsored vendor free of charge or work with another EVV vendor at their own expense. Usually, alternative EVV solutions have to be able to integrate with the state’s data aggregator.
  2. State-mandated external vendor: Providers must use state-sponsored, state-funded vendor.
  3. State-mandated in-house system: States build and manage their own EVV system that all providers must use.
  4. Provider choice: Providers select vendors and cover the costs. (Some states that chose this model will raise reimbursement rates to help offset the cost to agencies.)
  5. Managed care organization (MCO) choice: MCOs select the vendor and cover the costs, often with state support.

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:

  1. A GPS-enabled mobile app installed on caregivers’ smartphones
  2. Interactive voice response (IVR), which allows caregivers to call a toll-free number from the client’s home phone
  3. 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 — or Jan. 1, 2021 in states that received a “good faith effort” exemption. EVV isn’t required for home healthcare services (HHCS) until Jan. 1, 2023, but some states already require EVV for PCS and HHCS, or plan to implement both at the same time.

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 issues 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?

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 as a backup option and a backend system that automatically creates claims for agencies to review and submit through a web portal. However, Alabama has experienced some technical issues that could affect federal compliance, so it received good faith effort exemption that gives the state until January 2021 to work out the issues before they’re subject to CMS penalties.

Alaska

EVV model: Undecided (leaning open vendor)

Alaska has not formally announced an EVV system. 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, but in June 2020, the state requested proposals from EVV vendors. Alaska was 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. Arizona will require EVV for both PCS and HHCS on Jan. 1, 2021. 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 whether to help providers pay for mobile devices. Sandata is currently onboarding and training providers, and the system will “go live” in Arizona on Jan. 1.

Arkansas

EVV model: Open vendor

Arkansas selected AuthentiCare as its state-sponsored vendor, but providers can also use a state-approved alternative vendor. Providers were required to choose a vendor and enroll in Arkansas Medicaid’s EVV program by the end of September 2020. All caregivers must be trained prior to the “go live” date of Dec. 4, 2020.

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 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 has already implemented EVV for PCS and HHCS and will deny claims without electronic verification. Colorado also requires EVV for services not mandated in the Cures Act.

Connecticut

EVV model: State-mandated external vendor

Connecticut implemented a closed EVV model in 2017, with Sandata as the state vendor. 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, but will be subject to CMS requirements on Jan. 1, 2021.

Delaware

EVV model: Open vendor

Delaware is implementing EVV for PCS and HHCS simultaneously in 2020, with AuthentiCare as the state-sponsored vendor. Agencies may continue working with their existing vendors, if those vendors meet the requirements to submit data to AuthentiCare’s aggregator. AuthentiCare is currently training providers, and the state will require them to use EVV by Jan. 1, 2021.

Florida

EVV model: Open vendor

Florida currently requires EVV for PCS, HHCS and 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 its provider dashboard.

Georgia

EVV model: Open vendor

Georgia will use Conduent in partnership with Tellus as the state-sponsored vendor, and providers can also use third-party vendors that integrate with Tellus. COVID-19 slowed down implementation in Georgia, but the state plans to “go live” with EVV for PCS by July 1, 2021.

Hawaii

EVV model: Open vendor

Hawaii is working with Arizona to implement EVV, because Arizona provides Hawaii’s IT infrastructure. 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 currently onboarding and training providers in Hawaii, with plans to “go live” on Jan. 1, 2021.

Idaho

EVV model: Open vendor

Idaho will let providers choose whether to work with the as-of-yet unannounced state-sponsored vendor or a third-party vendor that meets data aggregation requirements. In an April 2020 update, the Idaho Department of Health and Welfare (DWH) announced that it would release temporary EVV rules by Jan. 1, 2021, and final rules by July 2021. DHW will host a webinar in December 2020 to update stakeholders about the implementation plan.

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 in-home client verification devices.

Indiana

EVV model: Open vendor

Indiana has chosen Sandata as the state-sponsored EVV vendor and required aggregator. Providers may use alternative vendors that meet the requirements for Sandata’s aggregator. The state received a good faith effort exemption, so PCS providers have until Jan. 1, 2021, to choose and implement a solution and train employees.

Iowa

EVV model: MCO choice

Iowa is currently working with the state’s two MCOs to implement EVV by Jan. 1, 2021. Both MCOs have chosen CareBridge EVV and will be responsible for training agencies to use it. In-home care providers will use the CareBridge mobile app, which they can download on their personal smartphones or employer-provided devices.

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: Open vendor

Kentucky has selected Tellus as its state-sponsored EVV vendor and data aggregator. Agencies can use Tellus free of charge or pay for another state-approved EVV vendor. Kentucky will require EVV for certain services in the following Medicaid waiver programs: acquired brain injury, acquired brain injury long-term care, home and community base, Michelle P. Waiver and Supports for Community Living. Providers can begin using Tellus on Nov. 17, 2020, and will be required to submit claims through Tellus beginning Jan. 1, 2021.

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 an alternative state-approved vendor. Maine received a good faith effort exemption from CMS, and to ensure agencies are on track to meet the Jan. 1, 2021, deadline, the state began requiring agencies to use EVV for PCS beginning on Oct. 1, 2020. During the short transition, there will be a three-day pending period during which providers can reconcile visit records with EVV data. After three days, claims without electronic verification will be denied. Agencies can already use the new state system for HHCS but aren’t required to do so 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 has updated the system to meet Cures Act requirements and is currently implementing EVV by region, starting with the eastern and western regions on Oct. 1, 2020.

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, Massachusetts plans to meet the new 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. Michigan received a good faith effort exemption that extended the EVV implementation deadline to Jan. 1, 2021, but the state will likely miss the new deadline as well. According to the Michigan Department of Health and Human Services (HHS) website, the department “is currently focused on activities related to COVID-19,” and “a timeline of when EVV will be rolled out in Michigan has not been established yet.”

Minnesota

EVV model: Open vendor

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

Mississippi

EVV model: State-mandated in-house system

Mississippi implemented its own telephone-based EVV solution, MediKey, in 2018. Agencies cannot use alternative vendors. Mississippi received a good faith effort exemption, so its EVV program isn’t yet subject to CMS requirements.

Missouri

EVV model: Open vendor

Missouri began requiring EVV for several PCS waiver programs in 2016, so many agencies were already using an EVV solution. Several waiver programs that did not require EVV under state law will require it under the federal mandate, so Missouri has drafted a new 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 hasn’t 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 has chosen Tellus as its state-sponsored EVV vendor and aggregator. Providers can use the Tellus mobile app to collect EVV data or use a third-party EVV solution that integrates with Tellus. Agencies must register with Nebraska’s EVV solution on Dec. 20, 2020, and must use it to submit claims beginning Jan. 3, 2021.

A complete mobile package for EVV compliance

icon of a documentWhite Paper

Samsung partnered with Sprint and Actsoft to deliver a complete EVV solution for home care agencies. Download Now

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, but according to the state’s EVV timeline, it doesn’t expect to choose a vendor until fall 2021 and won’t fully implement the solution until July 2022.

New Jersey

EVV model: State-mandated in-house system

New Jersey has selected HHAeXchange as its statewide EVV vendor and plans to implement the solution by the new deadline on Jan. 1, 2021. The following services will be affected: Personal Care Assistance, MLTSS Home-Based Supportive Care, DDD Individual Supports, DDD In-Home Respite and DDD Community-Based Supports.

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 should onboard everyone else by the federal deadline. EVV compliance rules and implementation procedures may vary by MCO.

New York

EVV model: Provider choice

New York already required EVV for some Medicaid programs but had to redesign its EVV model to comply with the Cures Act. New York elected a provider choice model, so agencies are expected to find their own EVV vendor and implement by the federal deadlines — Jan. 1, 2021, for personal care and Jan. 1, 2023, for home care.

North Carolina

EVV model: Open vendor

North Carolina has chosen Sandata as its state-sponsored vendor and aggregator but will allow agencies to use alternative EVV solutions that meet state requirements. North Carolina received a good faith effort exemption and plans to launch its new EVV program by the new deadline of Jan. 1, 2021.

North Dakota

EVV model: Open vendor

North Dakota has chosen Therap as its state-sponsored EVV vendor. Agencies may use the Therap mobile app or an alternative EVV solution that meets the requirements of the state’s data aggregator. The data aggregator vendor hasn’t been announced. The state received a good faith effort exemption and plans to implement EVV by the new deadline of Jan. 1, 2021.

Ohio

EVV model: Open vendor

Ohio already requires EVV for its fee-for-service Medicaid program, including both PCS and HHCS. 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 isn’t a mobile option. Ohio received a good faith effort exemption, but the state plans to meet the federal mandate by Jan. 1, 2021.

Oklahoma

EVV model: State-mandated external vendor

Oklahoma requires agencies to use the AuthentiCare EVV solution and data aggregator. Agencies may use the mobile app or IVR but cannot use alternative EVV vendors. Oklahoma hasn’t announced an official timeline for full 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 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, and they can also 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 worked 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. All providers began using the system in January 2020, and claims without EVV will be denied beginning Jan. 1, 2021.

Rhode Island

EVV model: Open vendor

Rhode Island chose 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 is currently conducting a state-wide soft launch. Providers will be required to use the system beginning Jan. 1, 2021.

South Carolina

EVV model: State-mandated in-house system

South Carolina is currently transitioning to a Replacement Medicaid Management Information System, which includes an EVV module along with tools for accounting, finance and other administrative tasks. The EVV solution will include a mobile app and an IVR option. South Carolina received a good faith effort exemption, but it’s unclear whether the state will meet the new federal deadline on Jan. 1, 2021.

South Dakota

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

South Dakota chose 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 that caregivers should use the web or mobile application whenever possible. South Dakota will also use Therap to replace other forms of paper-based billing. South Dakota has applied for a good faith effort exemption to delay implementation until January 2021. The state plans to simultaneously implement EVV for both PCS and HHCS.

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 aren’t managed by MCOs and haven’t 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 vendors

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) can choose from the state EVV vendor pool managed by the Texas Medicaid and Healthcare Partnership. These solutions are available at no cost to providers. Agencies and MCOs may also choose to develop their own proprietary EVV systems but must first receive approval from the state. EVV is already a statewide requirement in Texas for both PCS and HHCS.

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 received a good faith effort exemption to delay the federal compliance deadline.

Vermont

EVV model: Open vendor

Vermont 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 granted Vermont a good faith effort exemption, but the state will expect agencies to be onboarded, trained and using the solution by the new deadline of Jan. 1, 2021.

Virginia

EVV model: Provider choice

In Virginia, agencies that provide Agency Directed services may choose their own EVV vendors but they needed to have a solution in place by Oct. 1, 2019, for PCS and respite and companion services. MCOs are 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 began denying EVV-less claims on Jan. 1, 2020.

Washington

EVV model: Provider choice

Washington requires EVV for home care agencies that provide Medicaid services, including PACE-contracted home care agencies. Providers choose their own EVV vendors and are 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 ensure compliance before becoming subject to penalty.

Washington, D.C.

EVV model: Open vendor

Washington, D.C., lets providers choose between the state-sponsored vendor — Sandata — or alternative third-party vendors that meet Sandata’s data aggregation requirements. Mobile apps are preferred for data collection, but the state also allows other verification methods. Washington, D.C., is currently onboarding and training providers, with plans to “go live” on Jan. 1, 2021.

West Virginia

EVV model: Open vendor

West Virginia will have a state-sponsored vendor, but will 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 selected Sandata as its state-sponsored vendor and data aggregator, but agencies can use third-party EVV vendors that integrate with the system. Wisconsin permits 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 began a soft launch on Nov. 2, 2020, for both PCS and HHCS, but hasn’t set a date for the official launch.

Wyoming

EVV model: Undecided

Wyoming hasn’t selected an EVV model or announced much about its implementation plan. According to a high-level timeline, the state has set EVV deadlines of March 1, 2021, for PCS and Feb. 1, 2023.

Understand everything you need to know about the EVV mandate — and how EVV can boost your agency’s efficiency and profitability — with our free white paper. Then discover how Tellus is simplifying EVV compliance.

Posts By

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

View more posts by Taylor Mallory Holland