Big changes are coming for the home healthcare industry.
In 2016, then-President Barack Obama signed the 21st Century Cures Act into legislation. The law requires Medicare-reimbursed home healthcare providers to implement electronic visit verification (EVV) technology. It stated that the law would come into effect for personal care attendants on January 1, 2019, and home healthcare service providers on January 1, 2023.
President Donald Trump granted a one-year delay to the personal care attendant deadline (from January 2019 to January 2020) after different groups cited concerns about being ready in time for compliance with privacy, implementation, and other underlying issues.
Although it’s possible that the deadline may be extended again, it’s not a safe bet to count on it. Savvy organizations should start mapping out their game plan now so they can take advantage of benefits of this change and manage its challenges.
Electronic Visit Verification: Opportunities and Challenges
Electronic visit verification (EVV) is designed to help reduce Medicare fraud and abuse, which was recently estimated to cost the federal government $60 million annually. While the new requirements may stem from a place of challenge, they offer individual home care providers an opportunity to increase efficiency, improve customer satisfaction, reduce inaccuracies, and eliminate cumbersome paper timesheets and manual billing.
The 21st Century Cures Act mandates regarding EVV is not without challenges, though. Providers and states are facing several hurdles to enact this policy. Changing understanding of the policies is resulting in inconsistent policies among states. The changing deadlines provide more time to address these challenges, and more uncertainty.
This still leaves the big question everyone is trying to answer: How do I prepare for the new EVV requirements?
Preparing for the New EVV Requirements
Despite a multitude of questions and few concrete answers, EVV requirements will be enforced soon, and home healthcare organizations can’t afford to wait until the last minute to prepare.
EVV requires healthcare providers to record six data points:
- Type of service rendered
- Name of the person providing the service
- Name of the person receiving the service
- Date of the service
- Time the service begins and ends
- Location where the service is provided
Despite some states including it in their EVV models, GPS is not a requirement.
Providers also cannot rely on their patients to supply any form of technology, including internet service, a cell phone, or a landline. The onus is solely on the provider and home healthcare organization to implement an EVV system and comply with state and federal regulations.
When thinking about their mobile healthcare technology, providers must ensure their systems can collect the six data points mentioned above using only their own technology. Depending on the state where service is delivered, providers should also keep an eye on state requirements for GPS or other related technologies.
EVV Data Management Systems: Open, Closed, or In Between?
Although federal regulations will require Medicare-reimbursed providers to implement EVV systems, it is up to individual states to choose how they do it. There are generally three models of systems the states will chose: closed, open, and hybrid approaches.
In a closed model, the state chooses a single EVV system that each provider is required to use. The thought process behind this is that it allows for more consistency. However, there is a financial motive as well, since the federal government provides 90% of the initial costs for development and design, and 75% of ongoing costs related to maintenance and operation.
In an open model, providers are free to use an EVV system of their choice, as long as it meets federal requirements.
Other models include:
- Provider’s Choice: Guidelines are set by the state, and providers are free to choose any EVV system that meets those guidelines.
- MCP Choice: Managed Care Plans select a vendor that the providers in their network must use.
- Open Vendor Model: The state contracts with an EVV vendor and allows providers to access the system if they choose, but providers with existing compliant EVV systems are free to continue using those instead.
Before you can implement an EVV system, it’s important to determine which model your specific state has chosen. A provider in a closed model state, for instance, has to use the state’s system, even if their existing system is far superior. Meanwhile, an organization in a provider’s choice state will need to closely examine not only the federal guidelines, but also the state guidelines in order to remain compliant.
Choosing an EVV System That Works for You
Once you know your state’s requirements, you can move from the challenge of compliance to the opportunity of evaluating how you collect data from your mobile caregivers, where that information flows into your business, and how it’s used.
The purpose of an EVV system is to provide visibility and accountability into what happens onsite with patients. How could your business benefit from increased visibility aside from meeting regulatory requirements?
When managers and coordinators can see in an instant where their caregivers are, which patients they have seen, and who they are going to visit next, it creates a unique opportunity to find new efficiencies–even at scale–in your organization.
For managers and compliance experts tasked with implementing EVV into their agency, there are several important questions to ask when choosing a system:
- Does this system meet the requirements of my state?
- Will this system make it easier or harder for mobile caregivers to do their jobs?
- How will caregivers collect this data? Can they do it on their own devices?
- Will caregivers need an internet connection to collect this data?
- Who in the business needs access to the data collected by EVV?
- What other data should we collect while completing EVV requirements?
Integrating and Implementing EVV Systems
Choosing an EVV system is only half the battle. You’ll also need to make it integrate smoothly to your existing IT systems to prevent redundancies and duplicate data, which is one of the biggest obstacles to trustworthy business data.
While EVV only requires the who, what, when, and where of home healthcare, you likely need to collect a lot more information for your own use: birthdates, provider identifiers, state license and certification numbers, etc. Gathering trustworthy data from different sources, while still remaining compliant, can be difficult when best practices for integration and interoperability aren’t followed.
With a good EVV system, implementation woes should be minimal, provided you (or your service vendor) offers training and proper change management techniques. For many providers, it’s helpful to train those who will use the system the most at the beginning, then empower them to help train others.
Electronic Visit Verification Is the Wave of the Future
The 21st Century Cures Act is, deliberately or not, serving as a push for home healthcare and hospice providers to re-evaluate how they collect information from their mobile caregivers. While there are challenges and details regarding the new policy that need to be sorted out, EVV for home health services promises many benefits. Perhaps the biggest challenge right now for providers is how to communicate with state regulators that they want more from an EVV system than another set of boxes to check.
Skedulo’s healthcare scheduling platform, although not an EVV system, is a simple healthcare scheduling solution that can help home health organizations prepare for coming changes. Take a tour today and see how Skedulo can help your home health organization!