Mandated under the 21st Century Cures Act, Electronic Visit Verification (EVV) is finally coming to fruition for many organizations starting January 1, 2021. With the effective date rapidly approaching, many agencies are still asking questions.
“States and providers are still in the thick of EVV implementation,” 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. “The challenge for providers is how they can be forward thinking with respect to EVV compliance as they prepare for 2021.”
Here’s where agencies need to be in terms of preparing for EVV.
Does the requirement impact my agency?
It might. The answer depends on the types of services your agency provides.
Although the Cures Act sets the federal guidelines for EVV adoption, states are responsible for implementation and manage all aspects of their EVV rollout such as timelines, policy and technology selection.
Since the mandate is administered at the state level, the location of your agency makes a difference. For organizations that operate in multiple states, the rules may vary state to state. Some states, such as Ohio, will implement EVV for both personal care services and home health at the same time, while other states will roll out EVV for personal care services first and follow with home health later.
It’s critical for agencies delivering in-home care services to be familiar with the requirements in each state they operate in. There are two criteria for agencies to use when determining whether they are affected by the mandate:
- Is the service Medicaid-funded?
- Are any of the procedure codes the agency delivers included in the state list of EVV required services?
“Each state issues a list of Medicaid-funded services which are covered under the EVV mandate,” Martin says. “Agencies must understand which services are affected by reviewing at the procedure code level.”
What do agencies need to do now?
Providers in open states can choose the EVV solution that works best for them, opting to implement either the state-procured solution or a commercially available EVV solution. For providers operating in multiple states, using a state system can be more complicated because it would necessitate the agency to operate multiple EVV solutions to comply.
“For agencies with offices in multiple states, using the state system means that agencies must train their workforce on different mobile applications, with different IT implications,” Martin says.
Providers need to develop their compliance approach now, especially in cases where there are complexities such as complying in multiple states, managing more than one back-end system, or delivering multiple lines of service. Waiting until claims denial deadlines loom will mean that providers have fewer choices for how to comply, and less time to build a smooth implementation plan.
“Providers have a responsibility to collect data and relay that information,” Martin says. “Even in states where full guidance has not been provided, agencies can begin collecting EVV data now, essentially creating a longer runway to investigate solutions, train caregivers and adapt operationally.”
Where can agencies learn more?
The EVV requirements will continue to evolve based on state progress. Therefore, it’s critical for agencies to continue to monitor updates for their individual states.
“Agencies need to understand state timelines and participate in state calls, as well as research and understand the technology that is available,” Martin says.
While implementation continues to evolve at the state and provider level, this engagement will be important for agencies in January and well beyond.
“EVV implementation won’t be complete everywhere on January 1,” Martin says. “Think of it as an evolving process. Be proactive now, and don’t wait until your state starts denying claims. Collect the data, evolve your workflow and make adjustments before you’re at risk for any claims penalty.”
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.