Electronic Visit Verification Requirements on the Horizon

A lesser-known component of the 21st Century Cures Act is the electronic visit verification (EVV) requirement that goes into effect January 1, 2020, for personal care services (PCS), and January 1, 2023, for home health care services (HHCS). So, what is EVV and how can your organization prepare to comply with this requirement?

One of the greatest impacts will be to PCS providers who offer opportunities to Medicaid beneficiaries to receive services such as activities of daily living (ADL) in their own homes versus an institutional setting.

For example: providers in the intellectual development and disability (I/DD) service area assist with things like movement, bathing, dressing, toileting, transferring and personal hygiene. EVV allows providers to validate that the care was delivered at the time and location documented, which reduces the potential for fraud or patient neglect.

According to the Medicaid Fraud Control Units Fiscal Year 2017 Annual Report, the organization recovered $1.8 billion last year. This number includes 1,157 convictions of fraud and 371 convictions of patient abuse or neglect. The EVV requirement aims to curtail fraud and abuse in healthcare by arming caregivers with approved mobile applications and other methods to prove that the appropriate care was delivered on time and in the care setting documented.

The EVV is intended to verify what kind of services were performed, the right individual received the services, date of service, location of service delivery (verified by GPS and telephone lines), the individual providing the service and the time the service began and ended. This information can help to ensure the visits that are being reported to the Centers for Medicare and Medicaid (CMS) are actually taking place and that Medicaid is being accurately billed for those services.

One of the challenges with the EVV requirement is that design and implementation quality control measures have been left to the states to determine, bringing great variability to the policies in how each state will monitor compliance. Both the Senate and the House passed measures to delay the initial start date by one year to give states more flexibility to get the systems up and running. President Trump signed the bill in July 2018.

Looking beyond all of the regulatory components, there are some great benefits of EVV to both providers and consumers. One of the drivers of the EVV requirement is access to care. Its intent is to provide services where individuals are, particularly those that do not have easy access to transportation to and from appointments. The Cures Act projects a 26 percent growth in personal care service providers from 2014 – 2024 due to demographic growth of populations that needs these services, but more importantly that those individuals much prefer to receive services in their own homes.

So, how can you prepare for the EVV requirement? Make sure to have an integrated solution within your electronic health record (EHR) system has the capability to automate time and track miles for your staff providing services out in the community. Studies have shown that this automation improves provider satisfaction through activities like expedited payroll processing and claims management and reduces mileages costs by up to 20 percent over self-reported mileage. In addition, your solution should have real-time alerts to escalate potential late or missed visits.

While regulations are always cumbersome to comply with, they are an important part of improving our healthcare delivery system while protecting patients and providers.