Coming guidance from the Centers for Medicare & Medicaid Services (CMS) could settle some big questions regarding electronic visit verification (EVV) in home care, setting the stage for a lot of activity throughout 2018.
Under the federal 21st Century Cures Act, all Medicaid-reimbursed home care providers across the country must be utilizing EVV as of Jan. 1, 2019. EVV refers to technology a caregiver uses during a home visit, such as a mobile application or landline telephone system, that captures information including the time when service begins and ends. The government believes mandatory EVV will cut down on fraud and abuse.
The Cures Act directs CMS to issue guidance on how to comply with the EVV mandate. States and providers are now awaiting that guidance, which could be released “any day now,” Darby Anderson told Home Health Care News. Anderson is executive vice president and chief development officer at Dallas-based Addus HomeCare Inc. (Nasdaq: ADUS), a major provider of Medicaid-reimbursed home care. He also serves as first vice chair of the Partnership for Medicaid Home-Based Care Providers, an association that has been advocating on EVV.
The CMS guidance could address pressing questions about how states can go about implementing “open model” EVV frameworks, which the Partnership and other home care industry stakeholders strongly support.
In a “closed model,” a state implements a single EVV system and mandates that home care providers utilize it. In an “open model,” home care providers have the option to choose from a variety of EVV solutions that have been certified as meeting certain requirements.
“There’s little doubt that the ‘open’ approach is best for the industry, in terms of care provided, the effects on providers as businesses, and the likelihood of successful implementations by year-end,” Mark Battaglia, CEO and president of CellTrak, told HHCN. Chicago-based CellTrak offers care delivery management technology that includes EVV.
In terms of the business case, it is simply more efficient for a company to use a single EVV solution rather than multiple solutions across multiple states, Anderson said. And, companies that adopted EVV systems even before the Cures Act already have systems in place. Addus, for example, is utilizing at least four different EVV tools—one mandated by the state of New Mexico, two more in Tennessee, and the CellTrak product in other states that the company operates in, including Illinois and Texas.
Advocacy and challenges related to closed models have persuaded some states that initially went this route, such as Ohio, to move toward more open models. And Anderson and Battaglia are optimistic that additional states could follow suit this year.
However, the language of the Cures Act has created some uncertainty regarding open models.
The law is clear that a state will receive federal funds to develop and operate a single EVV system provided by a single vendor, Anderson said. It’s less clear on how the federal funds flow in an open model.
“I don’t think [the Cures Act] was trying to prohibit an open model, but it’s a little more technically complicated,” he said. “We’re hoping that in the guidance, CMS creates a pathway [and clarifies] how you apply for those federal matching funds in an open model.”
“If CMS would clarify how available federal funds could be use in an ‘open’ approach, that could make a difference because it would remove what some interpret as a financial incentive to go down the ‘closed’ path,” he said.
On that question of financial incentives, one issue is whether home care companies can get a cut of the government money supporting EVV, in an open model. Consider the situation in Ohio, where there is a state-run EVV system that home care companies can use at no cost. Or, they can pay out of pocket to work with a vendor from a list of certified EVV providers.
Margins are thin in Medicaid home-based care, but even so, there are reasons why a company like Addus would opt to partner with a vendor rather than use a free, state-run system, Anderson said.
If all the EVV data flows to the state and is not shared, the home care provider does not benefit from the information. Also, innovation and customization of a company’s EVV platform can happen when it is not working on a general, state-wide system, making it possible for a provider to differentiate itself in the marketplace with better service and lower costs, he said.
As Battaglia points out, companies like his can offer additional capabilities beyond EVV, as well.
A provider that opts out of the state-run platform should not have to pay 100% of the costs for its EVV system, Anderson believes.
“The easiest way to handle this is some sort of rate increase, specific to EVV, that will then go into your federal matching claim, and go to the provider to at least partially offset their costs for running an EVV system,” he said. “I don’t think the rate increase has to cover 100% [of EVV costs], which my competitors don’t like to hear me say, but to be fair, we shouldn’t expect the state to pay for the efficiencies that accrue to us through EVV.”
Whatever the guidance contains, expect states to finalize their EVV policies and systems once it is released. Then, the latter half of the year will be all about running implementations, as providers ensure that they are using compliant EVV systems across their whole enterprise, Anderson said.
“It’s going to be a busy year, there’s a lot to get done,” he said.
Written by Tim Mullaney