Providers of Medicaid personal care services (PCS) and home health services have a little more than three months left to prepare themselves for Electronic Visit Verification, or EVV — and to address any obstacles that might stand in their way.
The passage of the 21st Century Cures Act in 2016 put providers on the path to compliance beginning Jan. 1, 2020. But this year, every state except for Tennessee applied for and was granted a good faith exemption, ostensibly making the launch date for EVV Jan. 1, 2021.
In order to be ready, providers must be aware of three significant challenges — and know how to prepare for them. EVV expert Courtney Martin of technology solutions provider CellTrak — which provides home-based care solutions, including EVV, for more than 4,000 home care agencies worldwide — advocates that providers proactively avoid three speedbumps that could arise.
Compressed timelines for providers
The problem: For a provider to be compliant with EVV, it needs to implement a technology platform that will log and verify all home-based care visits. Most states operate within the “open model” for implementation, where providers can choose the technology solution they use, albeit within a set of state-mandated guidelines.
Yet for a range of reasons, some states have taken longer than expected to provide detailed specifics to providers about implementation. As such, providers are advised to take a parallel path with the state — to take action sooner than later, rather than waiting for 100% detailed implementation guidelines.
“Many providers are waiting for the state to get to the next level of implementation detail before they try to find a solution that fits their operation,” Martin says. “However, with deadlines looming, that approach could leave agencies faced with a time crunch.”
The solution: Choose a solution that works regardless of the state aggregator. That way, as long as you begin collecting data early, you can relay later when the state provides final details.
To benefit from that solution, Martin has two best practices she is advising for providers.
The first is that they get started as soon as possible on EVV implementation, even in the absence of 100% clarity on state guidance. Doing so will help providers identify their technology needs and might even get them ahead of the game on data collection.
“And when the state does issue its final guidelines and timelines, the providers that started early will be better prepared than those that waited,” she says.
The second best practice is to take advantage of a state’s soft launch period, where states still expect correct, compliant data in a timely manner, but also offer providers a grace period for claims denial. CellTrak recommends that states offer a six-month grace period at minimum prior to any claims denials, and hence that providers learn the practices of the states where they provide these services. Providers should take advantage of any soft launch periods their state is offering.
“If providers can start doing that research and thinking about their workflow, then by the time the state chooses a vendor or is requiring a specific type of data, it’s a lot easier for the agency to react rather than waiting to start,” Martin says.
Unrelated yet required process changes
The problem: Some states are requiring agencies to satisfy EVV in ways that are not required by the Cures Act, such as changing their billing process. These adjustments are complicated for agencies, because they are potentially billing one way now, and would have to change their back-office to bill the new way.
This creates a more difficult change management process for the agency, including staff preparation, and more worry about platform integration.
The solution: As agencies learn more about what their states are doing around EVV, they should advocate for as simple an implementation process as possible, in which at the outset, the state simply meets the minimum requirements of the Cures Act.
CellTrak, for instance, is an advocate nationwide for open billing, which allows providers to continue to bill their claims the same way they always have, as opposed to changing to a closed billing system.
“It’s just less disruption to their workflow and agency operations,” Martin says.
If agencies are running into repeated implementation challenges, Martin recommends that they reach out to state associations and work with their aggregators. That will eliminate any surprises once the claims denial period is here.
“The more you know about how this is affecting your operation, the better an advocate you can be within your state, and the more time you have to work through and adjust to the issues that you are facing as a result of the implementation model you’re dealing with,” she says.
Too much state-driven change
The problem: The Cures Act was put into place for services to be verified against six basic data elements for the purpose of overseeing service delivery.
“But some states have gone pretty far beyond that,” Martin says.
Some states are requiring more data elements, even up to 20 — vastly more than what the Cures Act requires. That leaves providers scrambling to figure out how to collect more data than they have previously, or trying to bring together multiple systems in order to comply with requirements.
“States don’t have to make sweeping changes, and in fact, the best ones are simply working toward incremental progress,” Martin says.
The solution: Agencies should step back and think about how they are operating today, and how EVV can benefit moving forward, thus improving the care they provide and helping caregivers feel better supported.
Once they have a sense of that, they can choose a flexible solution that, while being compliant, also more broadly helps them operate in this new world of more data required complexity.
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.