With just six weeks remaining in 2020, states
are making final preparations for the defacto start of Electronic Visit
Verification, or EVV, in which providers of Medicaid personal care services
(PCS) and home health services log their visits. It’s been a slow, steady climb
to this point. Per the 21st Century Cures Act, which Congress passed in
December 2016, EVV was supposed to take effect for PCS on Jan. 1, 2020.

But with every state except for Tennessee
applying for and receiving a good faith exemption, EVV’s launch date was pushed
back a year to 2021 — meaning it’s now just around the corner.

The COVID-19 pandemic has dominated the
attention of home health care agency leaders in 2020, and rightly so. Yet the
pandemic also has implications on EVV, too. Here is a look at where EVV stands
now, advice to home health care providers as they make their final move toward
PCS compliance and what to expect next.

The state of the union on EVV

There’s a lot that home health agencies need
to know about EVV, but at this point in time, so close to the new year, there
is one major idea to keep in mind.

“The picture we want to paint for people is
that as soon as the January 1, 2021 deadline is upon us, it doesn’t mean EVV is
done,” says Courtney Martin, EVV expert of technology solutions provider CellTrak, which provides
home-based care solutions, including EVV, for more than 4,000 home care
agencies worldwide. “This is a gradual, iterative process — the states
are a work in progress and many providers are still progressing toward
compliance as well.”

The Centers for Medicare and Medicaid Services
(CMS) has given states the Jan. 1, 2021 deadline to be compliant. If the states
don’t meet it, they are penalized with their FMAP (Federal Medical Assistance
Percentage) funding, which the federal government gives to states for programs.
CMS will determine whether each state has met the EVV requirements necessary to
retain all funding in 2021.

The hard deadline, therefore, is that states
will begin to see these penalties in their federal funding if they have not
done enough with respect to EVV implementation. Many states are in turn passing
that urgency along to providers, even giving some criteria for providers to hit
prior to that date.

Yet in most cases, Martin notes, that criteria
does not include claims denial for providers. CMS does not penalize providers
for lack of compliance, but rather empowers states to determine how to comply
and to set EVV requirements for providers. In other words, CMS holds states
accountable and states hold providers accountable, meaning
that for most providers, Jan. 1, 2021, is the day where they begin EVV adoption
in earnest by sending visit data to the state.

Three pieces of EVV advice to

As EVV continues into 2021, Martin has three main pieces of advice for affected providers:

— Know your state dynamic
— Know your internal processes
— Know how to avoid claims denial

A provider knowing its state dynamic means
understanding what is required in each state where EVV-impacted services are
delivered, and knowing what that given state demands of providers. Some states
set a threshold for percentage of visits that have to be electronically
verified with no manual interventions or corrections. Others manage claims
denials per visit, requiring a review of EVV visit data before reimbursement.

“If I’m a multi-state provider, I might have a
January 1st claims denial deadline in one state that I work in, and I might
have another state that has not yet issued formal guidance,” Martin says. “So
providers are dependent on the terms of EVV implementation based on their
location. And all providers, regardless of the state they are in, should now be
collecting EVV data, even if it’s not yet specified how that EVV information
should be reported to the state.”

The second piece of advice — knowing internal
processes — means proactively managing both administrative workflow and caregiver training. There is a connection
between those two: If a caregiver makes a mistake, or has an exception for the
service they provide, the administrative staff must know how to manually
document any addendums to the record.

Lastly, providers must know how to avoid
claims denial by knowing each of their state’s criteria for claims
adjudication. That means knowing when a given state will begin claims denial,
and knowing a given state’s criteria for paying a claim versus denying one.

One crucial element that providers must know
is whether the states where they provide services will allow them to continue
billing the way they have before. Most states are not changing the billing
process, which is a better workflow for providers. However, there are some
states that plan to implement closed billing, which means that visits affected
by EVV must be billed through the system that the state or MCO mandates. Some of
these providers, therefore, will have a more complex workflow, and potentially
be forced to use two billing systems: one for EVV visits and one for non-EVV

“That’s pretty difficult for providers, so
they need to understand how that dynamic can affect their agency, and then have
direct dialogue with the state if they have concerns around implementation,”
Martin says.

What providers can expect in 2021

In the early portion of 2021, states will continue to evolve their implementation
and monitoring progress. That will increase accountability for providers,
beyond what they saw in 2020, as states may begin claims denial or threshold
monitoring. Approximately a third of states are beginning implementation
efforts in 2021, and providers working in those states will be “newly
accountable” in 2021, Martin says.

Meanwhile, the home
health mandate for January 1, 2023 is still coming. While some providers
implemented both Personal Care Services and Home Health Services together, many
implemented separately, which means that providers can expect EVV mandates for
home health services prior to January 1, 2023.

“Preparing for the home health mandate starts
now,” Martin says.

To learn
more about how CellTrak can help you navigate EVV in 2021,
visit CellTrak’s EVV state map to understand what is happening in your
state — and stay tuned for more on EVV at HHCN from CellTrak.

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