New Year’s Day brought a new era for Electronic Visit Verification (EVV), as the 21st Century Cures Act ushered in the mandate that all states must implement EVV for all Medicaid personal care services (PCS) that require in-home care visits. States that fail to do so are subject to incremental Federal Medical Assistance Percentage (FMAP) reductions, unless they submit a good faith effort exemption — which every state but Tennessee, along with Washington, D.C., and Guam, did in 2019.
As a result of those exemption submissions (with all approved but South Carolina and Guam, which are pending), CMS will not apply FMAP reductions on those states in calendar year 2020. That loosens the collar just a bit for home-based care providers that are determining how to ensure EVV compliance.
But regardless of the actual implementation date, the need for EVV compliance is coming. Here are the three questions agencies need to ask themselves to ensure their own EVV compliance.
1. Does my agency have an EVV solution?
There are five state models for EVV solution compliance, with three proving most popular thus far. There is the open model, where agencies can use any EVV solution; the closed model, where the state Medicaid program contracts with a single EVV vendor and mandates that all provider agencies use that vendor’s EVV system; and the hybrid model that combines the two, where the state provides a solution, but also provides agencies the option of selecting their own.
Examples of those three models include:
— Closed model: Connecticut and Texas
— Open model: Virginia
— Hybrid model: Florida and Ohio
Integration with an electronic medical record (EMR) system, such as ContinuLink from Complia Health, ensures that all EVV data is in sync with payroll and billing.
So the first question agency leaders need to answer is whether they have an EVV solution at all. It might seem like an obvious starting point, but for home-based care agencies still tracking visits via paper, it’s a starting point that is very real.
2. Does my state allow my EVV solution?
Of course, just having an EVV solution is not enough. It must be allowed in an agency’s given state. For open states, that’s a bit easier. For closed states, that challenge might require a full change of solution.
Compounding that challenge are the agencies with caregivers in multiple states. These agencies must have a solution that is compatible across state lines.
“There are a lot of questions that agencies have regarding EVV requirements,” says EVV expert Janelle Schroeder, senior vice president of development at Complia Health, and the leader of Complia’s EVV approvals. “You have to ask, ‘What does it mean in my state?’ In Florida, for instance, they have three different (EVV) models.”
ContinuLink, for example, is compatible in every state but Alaska, giving Complia customers great compatibility no matter their state of practice.
3. Is my EMR integrated with my EVV solution?
Interoperability is crucial for EVV — interoperability between an agency’s EMR system and the EVV solution, and between the EVV solution and the state system. So having an EMR that is integrated with the EVV solution is a major step in the compliance mission.
“This is important because your EMR is producing the claim that is going to go to the payer,” Schroeder says. The payer will verify that the data from the agency’s EVV solution matches the claim. The state will deny payment if the EVV data does not match.
“So if I am an agency, I don’t want to pick a solution that’s not integrated,” Schroeder says. “That means if I have a separate EVV solution outside of my EMR, I will have to enter schedules twice. I can see that being a nightmare. But if everything is integrated, you at least have consistency with the claim and the data that you are providing. Furthermore, you have a partner that is helping you troubleshoot.”
In the road to EVV compliance, some states are further along than others. Understanding what a state offers and where it is on its compliance timeline can give agency heads a glimpse into their own road ahead.
“If agencies do not have an EVV solution, they need to take action now,” Schroeder says. “It needs to happen right away. They have to start doing their due diligence to make sure that they select a partner that is going to meet the requirements of their state, and that will be integrated with their billing solution. I can’t emphasize that enough.”
Choosing an EVV solution is a vital, strategic decision that has never been more important. To learn more about what ContinuLink can do for your agency, visit CompliaHealth today.
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