By Preston Finkle, SETWorks
You’ve likely heard a lot about the electronic visit verification (EVV) requirement lately. The EVV requirement for personal care services went into effect in most states on January 1 2021, but you may not know that it was actually signed into law in 2016 as part of the 21st Century Cures Act.
What is EVV? Simply put, EVV is a way of verifying information about Medicaid provider visits for personal care or home health care services. The information that must be collected and verified includes the date, location and type of service; the individuals receiving and providing the service; and the time the service begins and ends. This is usually done by checking in with a GPS-enabled mobile app or calling a toll-free number from a landline in the home of the person receiving the service or support.
Originally, EVV was set to start on January 1, 2020. However, the Centers for Medicare & Medicaid Services (CMS) allowed states to request a “good faith” extension, giving them an extra year to prepare. Every state (with the exception of Tennessee) took advantage of this opportunity—meaning the rule came into force at the beginning of this year.
Since the January 1, 2021 deadline has passed, you may have already made some changes to the way you collect data and verify service delivery. Even so, there’s still a ton of confusion around what needs to be done. Let’s debunk some of the most common myths and misconceptions we’ve heard so far.
Myth 1: EVV lets the state watch your every move.
Some DSPs might worry that EVV means “Big Brother” is watching them all the time. While it’s true that EVV requires providers to verify their location and other information, the idea of EVV is not to spy on anybody. Rather, it’s to ensure that people get the services they’ve been promised and to cut down on fraudulent claims. By preventing Medicaid dollars from being wasted on fraudulent claims, this ensures that the money is available for individuals that need it. Ultimately that’s something any honest provider should welcome, not fear.
Providers should note that EVV systems should only record a person’s location when specified to do so within the tool—not in an ongoing manner. By giving DSPs control over when this information is collected, EVV systems can track the necessary information without making staff feel like someone is looking over their shoulder.
Myth 2: EVV only applies to nursing services.
When people think of EVV, they often jump to the conclusion that it only applies to nurses who provide in-home services. However, this is not the case at all.
EVV applies to any agency that provides Medicaid personal care services and home health services in a person’s home. That includes nursing and home health aide services, of course, as well as things like in-home support and personal assistance programs for individuals with disabilities.
If your agency provides services that fall under the EVV requirement, you must electronically verify the delivery of those services. And, you must submit this verification information before your claims can be processed for payment.
Myth 3: EVV requirements are the same across the country.
EVV is a federal mandate. The rule lays out the types of information that need to be verified. However, it’s up to individual states to decide how to implement the EVV requirement and gather data. Each state is different, which makes compliance confusing for a lot of providers.
Compliance deadlines can vary by state. Missouri, for example, started requiring EVV for certain programs back in 2016. Other states didn’t require EVV until January 1 of this year. Some states require it for personal care services now, but won’t require it for home health care services until 2023.
States must also decide how they will verify visit data, whether by using GPS, landlines or special devices in the homes of people receiving services—or a combination of these. In addition, each state must decide how they will collect and report EVV data.
Myth 4: Agencies must use their state’s EVV system.
Again, this depends on which state you’re in. Most states have selected a state-sponsored EVV system to verify visit data. This system transmits information electronically to the state’s data aggregator, which gathers data on the state’s behalf.
Some states require providers to use the state-sponsored EVV system. However, most states allow providers to choose their own EVV solution as long as it can integrate with their state’s aggregator.
This is a convenient option if you’re already using an I/DD software solution that includes EVV, such as SETWorks. Most agencies find it easier to have EVV integrated with their other responsibilities, such as timekeeping and service documentation, to simply track EVV behind the scenes.
Myth 5: Staff must check in for every activity, whether it’s at home or in the community.
The EVV rule only requires care staff to check in for the portion of services that are delivered in-home. However, some states may choose to require additional information if services are provided at home and in the community during the same visit.
For example, let’s say you provide a service that starts in the community but ends in the individual’s home. In that case, it’s up to states to decide how they will track this information. It can get pretty confusing, so it’s best to check with your state’s requirements to be sure you’re in compliance.
Myth 6: I use web-based timesheets, so that’ll be good enough.
According to the Centers for Medicare & Medicaid Services, web-based electronic timesheets (even those with dual verification) are not an acceptable form of EVV. That’s because they don’t provide the state with “auditable confirmation of the data entered by the provider and approved by the individual.” In other words, there’s no way for states to verify that the location information is true and accurate. Instead, providers must use GPS or landlines to verify the location of the services performed.
Myth 7: I can worry about it later.
Since the EVV requirement is fairly new, some people might understandably be tempted to put off dealing with EVV until they have absolutely no choice. But that would be a big mistake.
To understand why, let’s back up a step. In order to receive their full funding from Medicaid, states must comply with the EVV requirement. Those that don’t are subject to reductions in funding, so naturally most states are taking EVV pretty seriously.
Providers that don’t submit their data may be subject to denial or non-payment of claims, as well as fines, sanctions, and suspension or termination from their state’s Medicaid program. Ouch.
The best way to keep this from happening is to make sure that you have a system in place for collecting EVV data, and that your staff know how to use it.
Myth 8: EVV will take a ton of time.
While it’s true that any new requirement comes with a learning curve, a good software system that includes EVV will do a lot of the hard work for you.
SETWorks, for example, makes visit verification remarkably easy. When care staff get to the client’s home, they can use their mobile phone or tablet to check in. The system collects all the information needed for EVV, like the start time and location services where the service is being provided. The best part is that this doubles as a timesheet for payroll, and staff can do all their documentation in the same place.
Billing is easier, too, because all of this information has already been collected and included with your other service documentation. This means there are no additional steps needed or headaches for your staff.
Finally, we’re all sick of dealing with missing location data. A good EVV system will save you from this misery by automatically checking for missing data and giving you quick access to correct it.
Keep Learning
Now that you know the truth behind some of the most common myths about EVV, you’ll be in a much better position to comply with the requirement and keep your agency running along smoothly. Be sure to visit our EVV page to learn more about how we solve for EVV with our clients across the nation at SETWorks.
Preston Finkle is Client Operations Director at SETWorks. Preston uses his passion for working with others and utilizing the best technology in his role as the director of our client operations team at SETWorks. He has enjoyed getting to know the disability services industry and partnering with agencies all over the country to help make them the best they can be through SETWorks and EVV. When he’s not working, Preston is usually hanging out with his wife and son, playing golf or grilling in the back yard.