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The state-by-state nationwide rollout of Electronic Visit Verification (EVV) – mandated by the Cures Act – hasn’t been straightforward.
Time and money has been invested into EVV in the home-based care world, and yet, in 2023, persistent confusion remains.
“For personal care providers at this point in time, the deadline has passed,” HHAeXchange President Stephen Vaccaro told Home Health Care News. “States need to be in compliance with the requirements of the Cures Act around personal care services. The majority of the states have fully implemented their EVV programs, but not every state has yet.”
HHAeXchange is a New York City-based home care technology platform and an aggregator of EVV data for payers and providers.
The main idea behind EVV is putting a stop to fraud, waste and abuse in the home-based care sector. It mandates that providers have to electronically verify their services. As such, caregivers and clinicians have to track and record data points, such as time, date, location and service type.
States such as Massachusetts and Michigan have yet to implement EVV. There are also other states that have opted to do a partial roll out.
Many of the states that have implemented EVV have also gone through the Centers for Medicare & Medicaid Services (CMS) certification process, and are receiving an enhanced Federal Medical Assistance Percentage (FMAP).
On the home health side, the deadline for EVV has passed, but CMS offered states the opportunity to file for good faith exemption. Most states submitted for this reprieve and have until Jan 1. 2024 to become compliant.
“I know, just from the work that we do in the marketplace, a number of states have already begun rolling out their home health compliance solution,” Vaccaro said. “We’re doing this in a number of states, such as New Jersey.”
Indeed, HHAeXchange was certified by CMS to be New Jersey’s state aggregator of EVV services.
When the time finally comes for providers – which have been given a reprieve – to implement EVV, it will be critical for them to weigh their options, and plan for the future carefully, according to Vaccaro.
“They need to think about what their EVV solution is going to be,” he said. “Are they going to use an in-house solution that they bring in? Are they going to use the free solution that’s offered by the state? Depending on which direction they go, how is that going to change their operational workflow? How will they need to modify their operational workflow and train their teams accordingly?”
It will also be important for providers to have a firm understanding of their state Medicaid programs.
“Each state Medicaid program has nuances and differences — no two are the same,” Vaccaro said. “It’s important for them to stay on top of any communications coming directly from the state. Normally, as we do a state rollout, we do informational sessions for the various provider stakeholders. I really encourage them to make sure they’re attending those sessions, whether it’s an HHAeXchange state, or another vendor is operating in that state.”
Other states watch and learn
As one of the last states to implement EVV, Michigan has been able to act as a sort of observer.
“I think we’re fortunate here in [Michigan] that we were not one of the first ones to act,” Barry S. Cargill, president and CEO of the Michigan HomeCare & Hospice Association, told HHCN. “We’ll be able to benefit, I think, from the experience that other states had in implementing. I know the state has specifically acknowledged that this is their intent. They want to learn from what the other states are doing.”
The Michigan HomeCare & Hospice Association is a state trade association for home-based care providers that represents 240 member organizations.
Last week, Cargill attended a meeting with the Michigan Department of Health and Human Services, where the organization announced that they had selected an EVV vendor for the state. Now, providers are waiting for the organization to announce next steps.
In the meantime, Cargill believes that providers should be forming relationships with vendors.
“You always want to start with your current vendors,” he said. “If you are working with any companies that have the ability to provide EVV, you want to have that conversation with them. Find out what they have. Work with those who share information widely, have experience and are willing to share that, so you have a smooth transition in implementing EVV.”
One of the challenges providers may run into while preparing for EVV implementation are the associated costs, as well as limited internet and cellular access in the more rural parts of certain states.
Cargill is also watching for how the state will respond to providers that aren’t able to get EVV compliant in time.
“That’s one of the stakeholder issues that we need to resolve with our Michigan Department of Health and Human Services,” he said. “What will they do to offer grace periods? Will they offer the opportunity of good faith effort, or are they going to simply have hard line enforcement?”
Michigan is less than a year away from EVV implementation.
“We’re encouraging our Department of Health and Human Services to hold those stakeholder meetings — to do it fairly soon, this spring would be an ideal time,” Cargill said. “This is so organizations have plenty of time to establish those vendor relationships and become comfortable with utilizing electronic visit verification in their everyday activities.”
Ultimately, Cargill warns providers not to get complacent during the wait time for implementation.
“We’re actively working with our membership to make them fully aware of this regulation that is coming, that there are some expenses they need to anticipate and some training time that will be necessary,” he said.
