With the public health emergency top of mind, it may be easy to forget that new federal technology requirements — electronic visit verification (EVV), in particular — are right around the corner.
Starting on Jan. 1 of next year, Medicaid-reimbursed home care providers are required to electronically verify the services that they deliver in the field. Caregivers must record data points, including date, time, location, type of service and other information.
Medicare-certified home health providers won’t have to do so until Jan. 1, 2023.
EVV originally became law in 2016 under the 21st Century Cures Act, with the goal of curbing fraud and abuse in the delivery of home-based care. The law sets the federal guidelines for EVV, but the mandate is administered at the state level.
States that aren’t compliant with EVV guidelines by the Jan. 1 deadline will be subject to a reduction in Federal Medical Assistance Percentage funding, which in turn impacts resources for state programs.
In some ways, it makes sense that the implementation of EVV has been placed on the backburner for some providers.
Originally, EVV adoption was supposed to take effect on Jan. 1 of 2020 — this year. Instead, most states — New York, for example — applied for and received exemptions, which pushed implementation back a year.
“New York state had several requests to postpone the implementation, given the difficulties in rolling this out in the personal care industry,” Emina Poricanin, managing attorney of New York-based Poricanin Law, told Home Health Care News. “Those were granted. New York state didn’t have the ability to just unilaterally postpone it.”
Now, roughly two weeks before providers are meant to be in compliance with the law, some providers feel less than prepared, according to Poricanin.
“There are way too many providers out there who are still calling to this day, asking what is EVV and what do I have to do about it,” she said. “Those are very late questions to be asking at this point in the game.”
States also have a hand in overall preparedness industry-wide, Courtney Martin, EVV expert of technology solutions provider CellTrak, told HHCN.
“That very much depends on the local state implementation plan. … Some states have been early with their implementation and are already to the point where they’ve given a lot of guidance to their providers around expectations and how they’ll be measured against them,” Martin said. “About half the states have done that. Then there are some states that are taking a little bit longer to implement.”
CellTrak is a Schaumburg, Illinois-based provider of home-based care solutions, including EVV, for more than 4,000 home care agencies internationally.
Providers have two responsibilities when it comes to the mandate. They have to collect correct, compliant EVV information in the field, at the point of care. Additionally, providers have to relay that information to the state or to the managed care organization that requires this data for compliance.
This means that whatever technology solutions a provider has in place must help them accomplish this, according to Martin.
To this end, providers have the option of implementing either a state-procured EVV solution or a commercially available solution.
“Those decisions are obviously very unique to the providers,” Martin said. “Generally speaking, the state system will include a very straightforward check the box compliance. Some providers that are trying to meet the minimum requirement, may choose to adopt the free solution.”
However, for providers that operate on a multi-state level, this may create challenges, according to Martin.
“The downside to a free solution is that if you are operating in multiple states, and those states all have different free solutions, this can be complicated for an agency,” she said. “Now, the agency is trying to support training and monitoring their caregivers on these different state solutions.”
When it comes to deciding on a technology solution, providers should consider their company’s operational workflow, as well as state compliance requirements.
As the EVV implementation date inches closer, Martin stressed the importance of providers beginning the data collection and documentation process as soon as possible.
“We encourage providers to do that, rather than waiting for state guidance,” she said. “The reason being that it’s time for their caregivers to get used to the technology solution. It gives them time to think through how their workflow, internal to the agency, is after their EVV processes are in place. It also gives them time to be prepared for when that state guidance comes.”
Providers should also follow state stakeholder meetings in order to stay up to date with the new information.
The state of New York, for example, has held weekly calls over the past several months. The aim of the calls was to help providers get prepared and address some of the technical issues associated with EVV, according to Poricanin.
As providers continue to operate amid the public health emergency, Martin believes that EVV adoption will help improve care delivery.
“You’re going to have way more information about that patient — and about the care that they need,” she said. “This can help you do a better job in the visit and also alert you to any specific circumstances that you need to know, including that patient’s potential sensitivity to being exposed to COVID-19.”
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