EVV Provision Leaves Home Health in Open Vs. Closed Dilemma

Home health care agencies were hit by another regulation last year, when President Obama signed the 21st Century Cures Act into law prior to leaving office. While the Act brought forth a number of developments for innovations and advancements in patient care, it also required home health agencies to comply with statewide electronic systems.

While progressive in nature, the technology provision within the Act has left some home health agencies scrambling to implement and invest in more than one patient documentation tool—and providers are under a deadline to sort it all out.

Section 12006 of the Act mandates that states require agencies to implement an electronic visit verification (EVV) system for Medicaid-funded personal care and home health services. EVV allows nurses and home health aides to check in electronically through software apps or smart devices and record details of their visit.


States, which are individually responsible for implementing the requirement, have until January 1, 2019, to put requirements into place for personal care services, and January 1, 2023, for home health services, or they risk losing Federal Medical Assistance Percentages (FMAP) funding.

Open vs. closed

While many providers may already be utilizing EVV software, states can choose to implement either an open or closed EVV model.


Under the provision, at the very minimum, the EVV must verify: date, type and location of the service; the individual receiving the service; the individual providing the service; and the time the service begins and ends.

In an open EVV model, states allow providers to use their existing EVV system, or allow them to choose one that best meets their individual needs.

On the flip side, in a closed EVV model, the state Medicaid program contracts with a single EVV vendor, and mandates all provider agencies to use that vendor’s EVV system.

While the closed model ensures technical and compliance standardization across all providers, it creates a financial burden on agencies that have already invested in an existing EVV program, according to Andy Kaboff, founder and chief business development officer at Schaumburg, Illinois-based CellTrak Technologies, Inc. Providers could also end up having to double up on software systems.

“[For] providers that are using other solutions that have their own EVV capabilities that would comply with the same data requirements as the Cures Act, it shifts and challenges them because now they have to use another solution,” Kaboff told Home Health Care News of the constraints of a closed model. “It actually moves them away from using the entire suite, and it now requires them to use two separate solutions.”

Kaboff, along with other EVV vendors and home health stakeholders, have coalesced to form the Partnership for Medicaid Home-Based Care (PMHC), a group advocating for state Medicaid programs to adopt an open EVV model.

Ultimately, the open model allows for agencies to streamline their overall processes, according to Darby Anderson, vice chairman of the PMHC and chief development officer at Addus HomeCare, Inc. (Nasdaq: ADUS).

“If we’re allowed to implement [an open model], we get a tremendous amount of synergy by the electronic data capture being used for the purposes of billing and for the purposes of payroll,” Anderson told HHCN. “The cost of actually implementing EVV is relatively small because you’re able to offset other costs [and] become more efficient.”

Driving innovation

Currently, Illinois, Louisiana, Missouri, New York, Ohio and Washington have already implemented an open EVV model, according to the PMHC.

Connecticut, Kansas, Louisiana, New Mexico, Oklahoma, South Carolina and Tennessee are utilizing a closed model.

While some states have an EVV program with no mandate in place, more than a dozen have not yet taken action.

As the deadline for compliance approaches, Anderson encouraged providers and state trade associations to actively advocate for an open model solution with their state Medicaid departments.

“[The open model] is really designed to be flexible for any-sized provider,” Anderson said. “A large provider in multiple states is going to want to choose a solution that they can use with their workforce across states.”

Kaboff agreed, stressing the role EVV can play in a patient’s overall care continuum.

“Managed Medicaid is going to look for more communication with the caregivers in the field,” Kaboff said. “Putting in a limited system … will stifle the improvement and quality of consumers in the long-term.”

Further, the open model will benefit the entire home health landscape by promoting innovation between providers, payers and the state, and allow them to “generate more value” from the EVV solution, according to Anderson.

Kaboff agreed, adding, “An open model [will] allow competition, which will drive prices down, it’ll drive innovation and that’s what will ultimately help manage the care and ensure that the fraud and abuse stops.”

Written by Carlo Calma

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