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What are the EVV compliance rules in your state?

Electronic visit verification (EVV) compliance is still a developing story in some states, but others have put a solution in place and require agencies to use it. Otherwise, their home healthcare visits might not be covered by Medicaid.

Only a handful of states met the federal EVV mandate deadline for personal care services on Jan. 1, 2020. Others received “good faith effort” exemptions, which provided an additional year to implement EVV and iron out any issues. Some of these efforts were hampered by COVID-19, but the Centers for Medicare & Medicaid Services (CMS) hasn’t reextended the deadline. So some states are still scrambling to implement a solution as soon as possible and avoid penalties.

What do personal care services (PCS) agencies need to know to ensure 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.

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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. For example, EVV isn’t required for home healthcare services (HHCS) until Jan. 1, 2023, but some states already require EVV for personal care services (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.

How to build a successful remote patient monitoring program

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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 (changing to open vendor model in January 2022)

Alabama implemented EVV in October 2017. In January 2022, the state will shift to an open vendor model using HHAeXchange as its vendor. Agencies will also be allowed to use other EVV providers that integrate with HHAeXchange’s data aggregator. Until then, agencies are required to use the AuthentiCare Electronic Visit Verification and Monitoring system 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.

Alaska

EVV model: Open vendor

Alaska selected Therap as its state-sponsored vendor and data aggregator. Therap is currently onboarding users, with plans to go live by July 31, 2021. Agencies that want to use another EVV vendor must have that vendor approved by Therap to ensure the third-party vendor’s technology can integrate with Therap’s data aggregator. Third-party vendors must be ready to submit data by the go-live date of July 31, 2021.

Arizona

EVV model: Open vendor

Arizona already requires EVV for both PCS and HHCS. Providers can use a mobile EVV solution from the state-sponsored vendor, Sandata Technologies, or choose an alternate vendor that integrates with Sandata’s data aggregator.

Arkansas

EVV model: Open vendor

Arkansas selected AuthentiCare as its state-sponsored vendor, but providers can also use a state-approved alternative vendor that integrates with the state data aggregator. Authenticare is currently enrolling users and testing third-party vendor integrations. Arkansas will start denying claims without EVV beginning Aug. 1, 2021.

California

EVV model: State-mandated in-house system (planning open vendor model)

California already has two systems to monitor agencies that provide Medicaid-funded PCS: the Electronic Services Portal (ESP) and the Telephone Timesheet System. However, these solutions don’t meet federal EVV guidelines. California plans to introduce an open vendor model but hasn’t yet announced a state vendor. The California Department of Social Services is currently conducting stakeholder meetings with agencies to determine the best solution.

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.

Delaware

EVV model: Open vendor

Delaware will implement EVV for PCS and HHCS simultaneously, using an open vendor model with a state-sponsored vendor and data aggregator. Delaware selected a vendor in 2020 and planned to go live by July 1, 2021, but the state recently discontinued that relationship and is looking for a new EVV provider. Agencies will be allowed to continue working with their existing vendors, if those vendors meet the requirements to submit data to the state-sponsored vendor’s aggregator.

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 agencies can now register for the solution and training sessions. 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. Hawaii already requires EVV for both PCS and HHCS. Providers can use a mobile EVV solution from the state-sponsored vendor, Sandata, or they can choose an alternate vendor that integrates with Sandata’s data aggregator.

Idaho

EVV model: Open vendor

Idaho has selected Sandata as its state-sponsored vendor, but agencies can also work with a third-party EVV vendor that meets data aggregation requirements. Sandata is currently onboarding agencies and testing third-party integrations. EVV will be required for all PCS claims beginning Sept. 1, 2021.

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 uses Sandata as the state-sponsored EVV vendor and required aggregator. Providers may use alternative vendors that meet the requirements for Sandata’s aggregator. As of Jan. 1, 2021, EVV is required for all PCS Medicaid claims.

Iowa

EVV model: MCO choice

Iowa worked with the state’s two MCOs to implement EVV for PCS, beginning Jan. 1, 2021. Both MCOs have chosen CareBridge EVV and are responsible for training agencies on how to use it. In-home care providers must 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 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 now requires 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.

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 and began requiring it for all PCS claims in 2020. To collect EVV data, agencies may use Sandata’s mobile app or IVR solution or work with an alternative state-approved vendor. 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 updated the system to meet Cures Act requirements and implemented the new solution in 2020.

Massachusetts

EVV model: Open vendor

Massachusetts selected 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. EVV is now required for all PCS Medicaid claims.

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. 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 has selected HHAeXchange as its state-sponsored vendor and data aggregator, but will allow alternative vendors that meet state requirements. Minnesota plans to implement EVV for PCS by Dec. 1, 2021.

Mississippi

EVV model: State-mandated in-house system

Mississippi implemented its own telephone-based EVV solution, MediKey, in 2017. Agencies cannot use alternative vendors. Mississippi is currently working with its vendor, FEI Systems, to upgrade from MediKey to a new CareVisit EVV platform, which will be implemented in 2021.

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 now require it under the federal mandate, so Missouri drafted a new EVV plan and selected Sandata as its state-sponsored vendor and data aggregator. Agencies can use the state vendor or continue using their existing solutions, if those solutions integrate with the state’s aggregator. As of Jan. 1, 2021, EVV is required for PCS Medicaid claims.

Montana

EVV model: Undecided

Montana has conducted stakeholder meetings to gather feedback but hasn’t announced its EVV compliance plans.

Nebraska

EVV model: Open vendor

Nebraska selected 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. Nebraska began requiring EVV for PCS on Jan. 3, 2021.

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Nevada

EVV model: State-mandated external vendor

Nevada requires every PCS claim to be verified using the AuthentiCare mobile app or IVR solution. The system 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. According to the state’s EVV timeline, New Hampshire will choose a vendor by fall 2021 and will fully implement the solution by July 2022.

New Jersey

EVV model: State-mandated in-house system

New Jersey selected HHAeXchange as its statewide vendor and began requiring EVV for PCS claims on Jan. 1, 2021. The following services are 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 have implemented the state’s new AuthentiCare EVV system. New Mexico began requiring EVV for PCS claims on Jan. 1, 2021.

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 selected Sandata as its state-sponsored vendor and aggregator but will allow agencies to use alternative EVV solutions that meet state requirements. North Carolina began requiring EVV for PCS claims on Jan. 1, 2021.

North Dakota

EVV model: Open vendor

North Dakota chose 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. North Dakota began requiring EVV for all PCS claims on Jan. 1, 2021.

Ohio

EVV model: Open vendor

Ohio 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.

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.

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. Pennsylvania began requiring EVV for PCS claims in July 2020.

Rhode Island

EVV model: Open vendor

Rhode Island chose Sandata as its state-funded EVV vendor and data aggregator, but agencies and MCOs may use alternative vendors that integrate with the state system. Rhode Island began requiring EVV for PCS claims on 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 plans to launch the new solution by January 2022.

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. The state launched EVV for both PCS and HHCS on Oct. 1, 2020.

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.

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. Vermont began requiring EVV for all PCS claims on 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. Washington began requiring EVV for all PCS claims on Jan. 1, 2021.

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., began requiring EVV for PCS on Jan. 1, 2021.

West Virginia

EVV model: Open vendor

West Virginia recently selected a state-sponsored vendor, HHAeXchange, but will also allow agencies to use alternative EVV solutions. The state hasn’t yet established an implementation timeline.

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. The state began a soft launch on Nov. 2, 2020, for both PCS and HHCS, but hasn’t set a date for the hard launch, when claims without EVV will be denied.

Wyoming

EVV model: State-mandated external vendor (possibly open vendor)

Wyoming has selected CareBridge as its state-sponsored vendor and is currently surveying providers. Implementation details and deadlines will be announced soon.

For more details on everything you need to know about EVV — and how it can boost your agency’s efficiency and profitability — consult Samsung’s free comprehensive guide. And discover additional technology solutions for healthcare from home, a highly accessible new norm that’s sure to stick around.

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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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