Connections - 07.18.19

Countdown to Electronic Visit Verification

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By Stephen Flanigan, Therap Services

CMS’ Electronic Visit Verification (EVV) requirement of the 21st Century Cures Act for all reimbursed Personal Care Services (PCS) is set to take effect in January 2020. Home Health Care Services (HHCS) are the next scheduled EVV mandate, in January 2023. States encountering unavoidable delays despite good faith efforts to comply in implementing EVV for these HCBS waiver programs will have the next few months to request up to a one year extension before reductions in the federal matching rates take effect.

While a handful of states have an EVV presently in place for select PCS services and a few others expect to roll out this year, the vast majority are still in the scoping and planning phases, and only a couple have extended EVV to Home Health. For the majority of states and providers, they’ll need a solution now to decide on oversight and data aggregation, fund and train providers, engage and educate families and stakeholders as the federal deadline looms.

The impetus for Electronic Visit Verification adoption is clear. The reduction of fraud, waste and abuse (FWA) is cited as a driving factor, with services rendered tied to verification independent of service provider or recipient, and accurate units billed per the individual’s care plan. The overall reduction of paperwork reduces administrative and audit costs with accessible and retrievable data, along with any provider savings in schedule flexibility. Additionally the effectiveness of quality assurance is improved by ensuring services and care are at minimum documented. 

CMS has issued specific requirements in what it will accept as an EVV. In addition to required service information (date, time, location, service provider, type, individual), state solutions need to be flexible in scheduling, accommodate recipient-initiated schedule adjustments and self-directed services, and allow multiple locations for service delivery, including locations with limited or unreliable internet.  That flexibility extends to allow states to implement their preferred EVV model, with provider and stakeholder involvement. These include options to plan and mandate an in-house system, an external vendor, leave providers and/or Managed Care Organizations (MCOs) to independently choose their own systems based on minimal state requirements, create an open house environment where providers and the state select from EVV vendors or in-house options (with the potential aggregation of third-party data), or some combination of these models.

As states submit planning documents and weigh options, Therap providers and states using Therap have a proven system in place, now. Providers are verifying billable service hours and create or adjust staff and service recipient schedules. These schedules denote services delivered and potential missed entries, while field staff using Therap mobile apps check-in/out to verify services with GPS-location stamping the site, time, and date of service. When GPS doesn’t pinpoint the anticipated service location, staff add location and comments to supplement the generated geo-location

 Care providers in communities with limited or unreliable internet utilize Therap’s Interactive Voice Response, a call-in service verifying service times, issuing a pin linked to check-in/out, along with access to the offline schedule. Features like Therap’s secure, direct-to-server photo uploads (storing no data on the device), digital signature options for the individual or family, and electronic signature stamps linked to each step of the data submission and review process give providers additional safeguards to ensure accountability, verify services rendered, and reducing fraud, waste and abuse.

As the deadline approaches, Therap is ready to provide states and providers with an EVV solution. Visit us at to learn more.

Stephen Flanigan is the Assistant Director of Strategic Initiatives at Therap Services. He can be reached at [email protected].