With just six weeks remaining in 2020, states are making final preparations for the defacto start of Electronic Visit Verification, or EVV, in which providers of Medicaid personal care services (PCS) and home health services log their visits. It’s been a slow, steady climb to this point. Per the 21st Century Cures Act, which Congress passed in December 2016, EVV was supposed to take effect for PCS on Jan. 1, 2020.
But with every state except for Tennessee applying for and receiving a good faith exemption, EVV’s launch date was pushed back a year to 2021 — meaning it’s now just around the corner.
The COVID-19 pandemic has dominated the attention of home health care agency leaders in 2020, and rightly so. Yet the pandemic also has implications on EVV, too. Here is a look at where EVV stands now, advice to home health care providers as they make their final move toward PCS compliance and what to expect next.
The state of the union on EVV
There’s a lot that home health agencies need to know about EVV, but at this point in time, so close to the new year, there is one major idea to keep in mind.
“The picture we want to paint for people is that as soon as the January 1, 2021 deadline is upon us, it doesn’t mean EVV is done,” says Courtney Martin, EVV expert of technology solutions provider CellTrak, which provides home-based care solutions, including EVV, for more than 4,000 home care agencies worldwide. “This is a gradual, iterative process — the states are a work in progress and many providers are still progressing toward compliance as well.”
The Centers for Medicare and Medicaid Services (CMS) has given states the Jan. 1, 2021 deadline to be compliant. If the states don’t meet it, they are penalized with their FMAP (Federal Medical Assistance Percentage) funding, which the federal government gives to states for programs. CMS will determine whether each state has met the EVV requirements necessary to retain all funding in 2021.
The hard deadline, therefore, is that states will begin to see these penalties in their federal funding if they have not done enough with respect to EVV implementation. Many states are in turn passing that urgency along to providers, even giving some criteria for providers to hit prior to that date.
Yet in most cases, Martin notes, that criteria does not include claims denial for providers. CMS does not penalize providers for lack of compliance, but rather empowers states to determine how to comply and to set EVV requirements for providers. In other words, CMS holds states accountable and states hold providers accountable, meaning that for most providers, Jan. 1, 2021, is the day where they begin EVV adoption in earnest by sending visit data to the state.
Three pieces of EVV advice to providers
As EVV continues into 2021, Martin has three main pieces of advice for affected providers:
— Know your state dynamic
— Know your internal processes
— Know how to avoid claims denial
A provider knowing its state dynamic means understanding what is required in each state where EVV-impacted services are delivered, and knowing what that given state demands of providers. Some states set a threshold for percentage of visits that have to be electronically verified with no manual interventions or corrections. Others manage claims denials per visit, requiring a review of EVV visit data before reimbursement.
“If I’m a multi-state provider, I might have a January 1st claims denial deadline in one state that I work in, and I might have another state that has not yet issued formal guidance,” Martin says. “So providers are dependent on the terms of EVV implementation based on their location. And all providers, regardless of the state they are in, should now be collecting EVV data, even if it’s not yet specified how that EVV information should be reported to the state.”
The second piece of advice — knowing internal processes — means proactively managing both administrative workflow and caregiver training. There is a connection between those two: If a caregiver makes a mistake, or has an exception for the service they provide, the administrative staff must know how to manually document any addendums to the record.
Lastly, providers must know how to avoid claims denial by knowing each of their state’s criteria for claims adjudication. That means knowing when a given state will begin claims denial, and knowing a given state’s criteria for paying a claim versus denying one.
One crucial element that providers must know is whether the states where they provide services will allow them to continue billing the way they have before. Most states are not changing the billing process, which is a better workflow for providers. However, there are some states that plan to implement closed billing, which means that visits affected by EVV must be billed through the system that the state or MCO mandates. Some of these providers, therefore, will have a more complex workflow, and potentially be forced to use two billing systems: one for EVV visits and one for non-EVV visits.
“That’s pretty difficult for providers, so they need to understand how that dynamic can affect their agency, and then have direct dialogue with the state if they have concerns around implementation,” Martin says.
What providers can expect in 2021
In the early portion of 2021, states will continue to evolve their implementation and monitoring progress. That will increase accountability for providers, beyond what they saw in 2020, as states may begin claims denial or threshold monitoring. Approximately a third of states are beginning implementation efforts in 2021, and providers working in those states will be “newly accountable” in 2021, Martin says.
Meanwhile, the home health mandate for January 1, 2023 is still coming. While some providers implemented both Personal Care Services and Home Health Services together, many implemented separately, which means that providers can expect EVV mandates for home health services prior to January 1, 2023.
“Preparing for the home health mandate starts now,” Martin says.
To learn more about how CellTrak can help you navigate EVV in 2021, 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.