What is Electronic Visit Verification (EVV)?
Electronic Visit Verification (EVV) is a federally mandated requirement all state Medicaid programs must implement to verify service delivery by home health and personal care services. It 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. 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.
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 is 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 recieving a service. Eventually, an EVV application that can be installed on any mobile device will be released to agencies and agencies can use the application instead of the supplied device. ODM and Sandata also have developed two backup options (telephony and manual entry) if the device is unavailable at any time. Each agency using the ODM system will have access to an 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 another EVV system, but it must be approved by ODM. Electronic visits that do not match with billing documentation 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 device application at the beginning and end of the visit.
– A DSP enters the required visit information using the ODM telephony option. This requires a DSP to 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 both the beginning and end of the visit that needs to be “cleared” in the agency’s online EVV portal.
– A DSP manually records the required visit information at the beginning and end 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 a visit using the device or application, but then the device or application is unavailable. A DSP may end the visit using the telephony or manual entry option. This will create an exception for the end of the visit documentation and must be “cleared” in the agency’s online EVV portal.
Exceptions may also be created if a DSP forgets to begin or end a visit with any of the above options, the DSP begins or ends the visit at a GPS coordinate that is not recognized in the EVV system, the GPS function is not working, or a DSP enters incorrect visit information. All exceptions will need to be cleared before an agency can bill 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 the individual service plan (ISP). 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 system must meet ODM’s 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 unless it is delayed. 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. 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 was passed out of the United States Senate. The bill is waiting on a signature from 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.