What is Electronic Visit Verification (EVV)?
Electronic Visit Verification (EVV) is a federally mandated requirement all state Medicaid programs must implement to verify home health and personal care services were delivered to beneficiaries. EVV is a mandate under the 21st Century CURES Act which was signed into law at the end of 2016 to decrease Medicaid fraud, waste, and abuse. The law mandates states must have a state-wide EVV system operating by January 1, 2019*, for Medicaid-funded home health services and January 1, 2021, for Medicaid-funded personal care services. Each state is given flexibility in designing their EVV system and can implement EVV before the mandated dates. States who do not comply with the EVV requirement or who can not show a good faith effort in implementing EVV by the deadlines will see their Federal Medicaid Assistance Percentage (FMAP) rates reduced each year the state is out of compliance after the above dates.
The Ohio Department of Medicaid (ODM) is contracting with Sandata to design and run Ohio’s EVV system. The selected system utilizes mobile devices with GPS capability that are supplied to each Medicaid beneficiary receiving home health or personal care services. While the devices are assigned to a specific beneficiary, EVV is the responsibility of the agency providing a service, not the beneficiary receiving a service. Direct Support Professionals (DSP) can also use a Sandata EVV application that can be installed on any mobile device that can be used instead of the supplied device. ODM and Sandata also have developed two backup options (telephony and manual entry) if the device or application is unavailable at any time. Each agency using the ODM system will have access to Sandata’s online portal where they can monitor and update their agency’s use of EVV. If an agency does not want to use the state-provided system they may use an alternate EVV system, but the alternate system must be approved by ODM. Visits logged with EVV that do not match with billing claims sent to ODM will eventually be denied.
EVV Implementation Scenarios
At the beginning and end of each visit to a beneficiary, direct support professionals (DSP) must document their service delivery and who they delivered the service to with the ODM supplied device, an ODM backup system, or their agency’s system.
Using the ODM Supplied System
– A DSP enters the required visit information using the ODM supplied device or mobile application at the beginning and end of the visit.
– A DSP enters the required visit information using the ODM telephony option. DSPs call a designated phone number through the individual receiving services’ landline telephone and enters the required visit information at the beginning and end of the visit into an automated prompt. Using the telephony option will create an exception for the beginning and end of the visit that needs to be “cleared” in the Sandata online EVV portal.
– A DSP manually records the required visit information at the beginning andend of the visit and the information is later uploaded through the agency’s online portal. Manual entry will create an exception for both the beginning and end of the visit that needs to be “cleared” in the agency’s online EVV portal.
– A DSP begins or ends a visit using the device or application, but then the device or application is unavailable for the other clocking in/out time. A DSP may begin or end the visit using the telephony or manual entry option. This will create an exception for the part of the visit that did use the ODM supplied device or application and must be “cleared” in the Sandata online EVV portal.
Exceptions may also be created if a DSP forgets to begin or end a visit with any of the above options or a DSP enters incorrect visit information. All exceptions will need to be cleared before an agency’s billings will be processed for provided services.
If an individual receiving services does not feel comfortable having the device or application used during their service delivery, an agency can forgo the use of the device. This should be documented in some part of an individual’s official record. An exception will be created for all required visit documentation for each visit and must be cleared in the agency’s online portal.
Using an Alternative System
Agencies are allowed to use an alternative EVV system they may already have in place or are looking to put into place. How alternate systems operate will depend on the specific EVV product and vendor. To use an EVV system already in place at an agency, the agency must apply through ODM and have their alternative EVV system approved. The alternate system must meet ODM’s Technical Specifications and Business Requirements.
EVV Implementation Timelines
Ohio’s EVV system is being implemented in three phases. Phase One began January 8th, 2018 and included state plan home health aide, state plan home health RN, LPN, and private duty nursing (PDN), Ohio Home Care Waiver RN and LPN nursing, Ohio Home Care waiver personal care aide, Ohio Home Care waiver home care attendant, and State Plan RN assessment. Phase Two will encompass all other Medicaid home health and personal care services, including some services provided by the Ohio Department of Developmental Disabilities. Phase Two is still being developed and is estimated to be implemented within the first half of 2019**. Phase Three will be implemented in May of 2020.
OPRA Advocacy Efforts
OPRA and our national partners at ANCOR been working closely with members of the US House of Representatives and US Senate to introduce legislation to delay the January 1, 2019 implementation date of EVV to January 1, 2020. House Resolution 6042 was passed out of the US House of Representatives on June 20, 2018, and is being discussed in the US Senate.
OPRA staff have been attending monthly stakeholder meetings regarding phase two implementation and is joining with the Ohio Council for Home Health and Hospice for an additional EVV workgroup. As Phase Two plans are publicized, OPRA will hold various trainings, webinars, committee meetings, conference sessions, and will update this page as needed.
June 25, 2018 Update
Services administered by the Ohio Department of Developmental Disabilities (DODD) subject to Phase Two EVV implementation include nursing, delegated nursing, and 15-minute unit-based homemaker/personal care services. This does NOT include homemaker/personal care billed under the daily rate. Services offered through the Self-Empowered Life Funding (SELF) waiver will have EVV introduced in May 2020 as part of Phase Three. For phase two, training on the EVV and access to ODM’s EVV system will begin January/February 2019, the system will “go live” May 6, 2019**. However, claims will begin to be denied if electronic visits and billing documentation does not match in the summer/fall of 2019. ODM is committed to this timeline even if the federal legislation to push back the EVV implementation deadline by one year.
July 18, 2018 Update
House Resolution 6042 passed out of the United States Senate. The bill waits on the signature of President Trump. Once signed, the official implementation date will be moved back to January 1, 2020**. The Centers for Medicare and Medicaid Services (CMS) has also begun taking ‘Good Faith Efforts’ applications from states to delay reductions in reimbursement by an additional year.
July 26, 2018 Update
The Ohio Department of Medicaid emailed Phase Two providers this introductory letter regarding the rollout of EVV.
*July 30, 2018 Update
President Trump signed H.R. 6042 into law. States now have until January 1, 2020 to come into compliance with the 21st Century Cures Act. Read the White House’s Press Release.
August 31, 2018 Update
The Ohio Department of Medicaid released this letter in response to the passage of H.R. 6042. At this time, the Ohio Department of Medicaid is not planning on pushing back their stated timeline for Phase Two implementation. Training will be available at the beginning of 2019 and system “go live” will be on May 6th, 2019. Medicaid will begin to deny claims that do not have appropriate EVV visits in fall of 2019.
September 11, 2018 Update
The ODM emailed Phase Two provider emails listed in MITS this Provider Readiness Checklist.
September 19, 2018 Update
The ODM and the Ohio Department of Developmental Disabilities held a joint stakeholder meeting to discuss how EVV will look in unit-based homemaker/personal care and nursing services. The stakeholder group focused on how to operate EVV when a DSP is supporting multiple individuals. View the presentation here.
September 26th, 2018 Update
**October 4th, 2018 Update
ODM announced via this memo that Phase 2 of EVV implementation will be delayed to no later than August 5th, 2019. Claims denial will also be delayed.
October 17th, 2018 Update
ODM announced training for Phase 2 providers will being on May 6th, 2019. Agencies will be able to sign up for training beginning in April 2019. Providers of Phase 2 services will need to start using EVV in August but claims will not be denied until a later date.
November 7th, 2018 Update
The Centers for Medicare and Medicaid Services (CMS) hosted a nation-wide conference call on EVV. A download of the MP3 file and transcript can be found here.
December 10th, 2018 Update
Registration for training for Phase 2 providers will open April 1st, 2019. Providers of only Phase 2 services will have the option to register for in-person, webinar, or an online, self-paced training. Providers who offer Phase 1 services and received training in Phase 1 will need to register for a refresher training course. Once training is complete, providers can begin to access the Ohio Department of Medicaid Sandata system for Phase 2 services.
January 7th, 2019 Update
Providers of Phase 2-eligible services can begin working with Sandata to get their alternate EVV vendor approved. Alternate vendors must be approved by Sandata in order for agencies to be approved alternate vendors. Learn more here.
January 31st, 2019 Update
Starting on February 12, 2019, claims for Phase 1 services without an electronically-verified visit were scheduled to begin to be denied. This date has been postponed by the Ohio Department of Medicaid. At this time it is unknown when the claims will be re-scheduled for denial. It is unclear how this postponement will impact the implementation timeline for Phase 2 services. Details will be shared at the February 11th stakeholder meeting.
February 11, 2019 Update
The Ohio Department of Medicaid confirmed the timeline for implementation of EVV in Phase 2 services will not change due to the delay of claims denials in Phase 1 services. Training is still scheduled to begin May 2019.