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 15-minute unit-based homemaker/personal care and nursing services. Phase Two training for providers using the state-provided Sandata system will begin in May of 2019. Providers of Phase 2 services are expected to be using EVV, either through an alternate vendor or the state-provided Sandata system, in August of 2019. While providers are expected to be in compliance in August of 2019. Claims for payment for relevant services provided without corresponding electronic visits will not be automatically denied. The date for denial of claims without corresponding electronic visit verification has not been set by the Ohio Department of Medicaid. 

Phase Three will be implemented in May of 2020.

Resources:

Ohio Department of Medicaid EVV webpage

Ohio Department of Developmental Disabilities EVV Fact Sheet

Centers for Medicare and Medicaid Services (CMS) EVV Frequently Asked Questions

Centers for Medicare and Medicaid Services (CMS) EVV Informational Bulletin 

American Network of Community Options and Resources (ANCOR) EVV Advocacy Centers

 

Have questions about EVV? Email OPRA Vice President Anita Allen or OPRA Policy Analyst Christine Touvelle.