Under Congress’s Jan 1st, 2023 implementation deadline, state-supported Medicaid programs offering Home Healthcare Services or Skilled Nursing Care must now fully operate under an EVV system, ensuring the correct billing of all home visits and that adequate support was granted for a beneficiary’s needs. As EVV mandates now cover a wide net of home and community-based services, our experts have highlighted important health updates that state providers and beneficiaries should know going forward.
What is EVV?
EVV are computer or phone-centric systems used to electronically record time and attendance to facilitate accurate claims, purchasable from various nationwide vendors, each offering different forms of EVV such as GPS Smart Phone, Telephony, or Fixed Visit Device-based systems. Its purpose is to grant visibility by electronically verifying that caregivers truly performed home visits while attempting to reduce fraud by improving the accuracy of home health claims reports through observable metrics. Federal regulations imposed under the Cures Act now require each state to partner with an EVV software vendor whose systems can be implemented for capturing six data elements. These required data points include:
- The member receiving the services
- Caregiver providing the service
- Type of Service
- Location of the service delivery
- Date of the service
- Time the service begins and ends
Why are States Mandating EVV for Medicaid Services?
In 2016, congress approved a new federal law, the 21st Century Cures Act, requiring State Medicaid programs to begin implementing EVV systems for home care and community-based services. Congress passed this legislation for two reasons. First, Medicaid fraud and abuse have plagued federal spending for decades, with improper payments from unverified home health claims contributing to an estimated $36 billion in Fiscal Year (FY) 2016 alone. When fraudulent claims escalate within a state’s home health system, those states lose the ability to support their Medicaid beneficiaries effectively.
These ethical violations prompted Congress’s second reason for mandating EVV for a revitalized Medicaid claims system, advocating better resource management and vigilance when preventing fraud. Committed to ensuring accurate payments, CMS required all state Medicaid programs to implement EVV for primary care services (PCS) by Jan 1, 2019. Due to delays brought on by states filing GFE requests, the new PCS deadline became Jan 1, 2021, and the Home Health Services deadline was pushed back to Jan 1, 2023.
Provided states proved they made good faith efforts to implement EVV in a timely manner, CMS may honor GFE exemption requests within time to receive a one year extension to their deadline, and defer any reductions incurred to state funding.
How Will EVV Affect Home Health Costs?
This mandate expands existing requirements for PCS and consumer-directed services to account for Home Healthcare Services (HHCS), or skilled services across all state Medicaid providers. As seen during the previous PCS implementations, adding EVV into broader HHCS will require assigning new duties involved in maintaining EVV systems while retraining staff to perform those sophisticated roles efficiently.
In most states, providers must choose to implement either a state-contracted vendor for their EVV or install systems following their state’s guidelines. For those states choosing to contract with a vendor, Medicaid will cover vendor costs, including EVV system implementation, provider agency EVV training, and ongoing recurring EVV fees. A few states have mandated the use of only their contracted vendor without permitting the choice to use others that meet the data collection requirements and integrate with their aggregator.
Benefits of EVV Systems
Depending on their software vendor, EVV-compliant agencies can efficiently reduce costs while changing how they update payrolls, review claim submissions, render services on schedule, and promptly provide backup caregivers when a field staff member doesn’t report for home visits as scheduled. By verifying visits using EVV, providers can reduce fraud by flagging claims that don’t align with previous patient reports. If a state has given providers the option of using state-contracted vendor services or finding an alternative EVV vendor, only those providers implementing an alternative EVV system will incur charges due to purchase, outsourced implementation, and continued support of those systems.
There are EMR systems that are only charging a minimal fee for their proprietary EVV when used as a state mandated alternative EVV. There are some significant efficiencies that can be realized by utilizing an EVV that is already an integral part of the organization’s agency management system rather than operating from 2 or more systems to achieve compliance. Several states for example have chosen to implement multiple EVV contracted vendors either based on individual MCO choices or different state Medicaid departments. This then often requires the organization to train multiple, disparate EVV systems and processes. Utilization of a proprietary EVV within the existing agency management system, as in the case of KanTime, allows the organization to standardize on one EVV system that then is integrated with all the state mandated aggregators. This then eliminates the complexities of multiple EVV systems and associated human error of having to remember how to operate within them.
Redefining The Patient-Caregiver Relationship with EVV
As stated, the GFE deadline for implementing EVV into all remaining Home Health Services applicable to State Medicaid closes Jan 1st, 2023. Past this final date, beneficiaries and caregivers must adhere to different EVV processes to verify the quality of care and accuracy of all reported claims. Although some states chose to implement both non-clinical PCS and skilled services early, CMS only initially required non-clinical services to be implemented to make service claims transparent and measurable for payrolls. Now a similar process will require patients receiving in-home assistance through a PCA or other skilled nursing disciplines to use EVV during each care visit as well.
While it is preferred that beneficiaries utilize smartphone-based options for EVV, CMS will not mandate their use nor require patients to purchase phones for their caregivers while other forms are available. Additionally, in areas with limited or no connectivity, where smartphone-based options are not always functional, other options such as Telephony and fixed devices are made available. For state providers offering support through PCAs or skilled nursing services to continue being reimbursed by Medicaid and Medicaid associated MCO’s, they will need to process claims through EVV which match the required data points. Failure to comply with these regulations will see the denial of all claims for services requiring EVV. Any state system that fails to implement EVV will see CMS reducing that state’s Medicaid funding by 2%.
Conclusion
As the home health industry moves into 2023, EVV systems will continue to become a topic of focus. Medicaid fraud and abuse is still a prevalent issue affecting millions of home health patients annually, which CMS hopes to address through EVV implementation. Balancing the scales back towards patients’ needs and quality of life will continue to require compliance with EVV to ensure limited funds are spent to their best efficacy.
Down the line, this means reducing fraud rates, streamlining time-consuming tasks for caregivers with automation, and putting the best resource possible toward verified patient care.
