Electronic Visit Verification (EVV) will be required in most states by Jan. 1, 2021, some requiring home health care in addition to personal care. The deadline is right around the corner, so agencies need to prepare now.
Agencies have two responsibilities when it comes to EVV compliance:
- Collect the required EVV data for every visit affected by the mandate
- Relay that data in the right format, often in near real time to the state or MCO that mandates it
“The agencies that will be most successful will focus on the opportunity that EVV offers for them to provide better care in the field,” says CellTrak EVV expert Courtney Martin.
So, how can agencies set themselves up for success? Here are three considerations that are foundational to developing a good implementation plan:
- Determine whether the mandate applies to you by reviewing the services you deliver against the EVV-mandated services list in your state.
- Consider the complexity of your compliance environment, such as how many states you operate in, and how many payers you submit claims to.
- Start early to allow time for caregiver training and system testing. Be prepared to meet state deadlines which often differ from each other and may be sooner than the federal mandate.
Determine if you are subject to the mandate
The Federal 21st Century Cures Act requires EVV for Medicaid-funded Personal Care Services (PCS) first, with Home Health Care Services (HHC) by January 1, 2023. However, some states have chosen to mandate EVV for services in both categories in 2020.
In order to comply with state implementation requirements, agencies must understand which of their services are subject to the EVV mandate. There are two criteria to consider. The first is which services are billed to Medicaid. The second is whether the services you deliver – PCS, HHC, or others – are mandated by the state where you deliver them.
To determine that, individual state websites or state communications departments will provide a list of procedure codes and services that are subject to EVV. “If an agency delivers any of those services, then EVV applies,” says Martin. “If they only deliver services that are not included on the list of covered services, then they are not affected.”
Here are examples of what you might find as you explore state sites:
Consider your Compliance Environment
Once an agency knows its state model and whether its services are subject to EVV, they must then consider the complexity of their compliance environment, Martin says. One aspect of compliance is the number of states an agency operates in. Agencies must comply with the unique EVV mandate for each state where they deliver services, which means that multi-state agencies must comply with multiple sets of requirements.
Another aspect is the number of payors who mandate EVV. Some states have multiple Medicaid payers – for example, the state Medicaid office or several managed care organizations (MCOs). “The agency needs to take inventory of the payers that are affected and realize that there might be a different requirement for data that the state requires versus data that the MCO requires,” she says. “Many agencies are billing to multiple payers in the states where they do business, all of which could have unique requirements.”
The most important bit of advice – start early. EVV preparation and compliance is a changemaking exercise. Allow time to make a strategic decision around how your agency will comply with the mandate and use EVV to provide better care. Recognize the technology systems that will be affected and plan for a testing period. And finally, agencies must identify the segment of their workforce that will be affected and allow plenty of time for training.
State EVV deadlines can be different state-to-state, even among neighboring states. Agencies must align to those deadlines when they design their compliance plan, and even consider different technology requirements.
“The short term challenges and complexities to get over the hurdle of implementation will be far outweighed by the benefits to agencies in terms of streamlining operations, supporting caregivers and providing better care for patients,” Martin says.
To learn more about how CellTrak can help you navigate EVV in 2020 and beyond, visit CellTrak’s EVV state map to understand what is happening in your state — and stay tuned for more on EVV at HHCN from CellTrak.