The 21st Century Cures Act introduced an important requirement for state Medicaid programs covering personal care and home health care services: electronic visit verification (EVV). Although EVV itself wasn’t new, this broad adoption represented a renewed focus on accountability where public dollars were concerned. As government spending comes under increased scrutiny, EVV has taken on even greater importance. For compliance with the Cures Act, both home- and community-based service providers and caregivers must embrace sound EVV practices to protect not only their livelihood, but also the people they serve.
Broad Mandate, Uneven Adoption
The Cures Act recognized that growing populations of aging people and people with disabilities would result in an increasing demand for Medicaid home- and community-based services. EVV was identified as one method of assuring that services were delivered to beneficiaries as intended. In essence, EVV would keep track of provider visits and help prevent fraud, waste and abuse by storing and reporting data on six core components:
- Services provided
- Individual receiving services
- Date
- Location
- Individual providing services
- Times when services begin and end
One look at Medicaid’s EVV compliance status trackers for personal care and home health indicates the uneven adoption across states so far. While most states report full or at least partial compliance, outliers remain—but they don’t tell the whole story. States were given considerable latitude in their EVV approach, meaning there is a patchwork of EVV models nationwide. Beyond variations in the model selected by a state, there are also variations in EVV platforms. EVV may rely on telephone timekeeping (telephony), which is often tied to a participant’s landline; web-based Global Positioning System (GPS) verification, which is typically baked into a mobile app; a one-time password generated by a fixed object, in a participant’s home; or biometric identification captured through voice, fingerprint, face or iris scans. As a result, providers and caregivers are managing a patchwork of EVV systems in their day-to-day work.
A Growth Mindset Supports Adoption
Deadlines for EVV implementation in personal care and home health services have come and gone, and as some states continue to work toward full compliance, agencies and caregivers are bracing for the change. EVV is accompanied by a learning curve, as many caregivers and their participants need time to adjust to new tools and methods of tracking services. Provider agencies and financial management services (FMS) vendors can support them throughout the learning process—and the first step is often in setting realistic expectations around EVV.
Oklahoma offers a lesson in flexibility. The state was an early adopter of EVV, piloting a system in 2009 before requiring it in 2010. During the first decade, the EVV vendor changed several times, prompting stakeholders to adjust to the idiosyncrasies of various platforms in a short period. Even if a vendor doesn’t change, their platform will likely be refined with use, feedback and technological advancements, and home health agencies, caregivers and participants will need to adapt.
It’s important to position EVV as not only an immediate requirement, but an ongoing opportunity to learn and grow in ways to protect critical funding for people who rely on long-term services and supports (LTSS). At the same time, EVV solutions should be rooted in person-centered practices, ensuring that technology enhances, rather than disrupts, the individual’s ability to exercise choice and control over their care and daily lives. To that end, providers and caregivers, especially, must have access to flexible and accessible technology to ensure that EVV is not a barrier to services and is easy to use to ensure data integrity.
Advocating for Caregivers & Participants
States that have found success with EVV implementation invest considerable time and effort in understanding the many stakeholders involved. Providers and caregivers can voice their knowledge about impacted populations and encourage states to meet them where they are in terms of training, from providing in-person sessions to technical webinars and podcasts. Additionally, ongoing support should be an area of advocacy to ensure that caregivers and participants have reliable resources to turn to whenever issues arise in the field, whether that resource is a hotline, a website or a built-in feature in an EVV app, like a video tutorial.
Providers and caregivers may also have misgivings about EVV technology that should be recognized and addressed. People in rural areas may have concerns about internet accessibility. Others may raise privacy questions over GPS-enabled EVV tools. Some, particularly those who self-direct, may worry that they could lose flexibility in scheduling or reliable payment for their workers. People may also have language barriers and limitations when using or obtaining devices.
EVV systems that align with person-centered practices can help address these challenges. When tools are designed with the participant and caregiver in mind—supporting autonomy, privacy and ease of use—they become enablers rather than obstacles. Caregivers and their participants should have access to simple, user-friendly tools that may work with multiple devices and systems, such as an app that can be loaded onto tablets and smartphones and that works with any operating system.
As key stakeholders in the LTSS ecosystem, providers can push for answers to caregivers’ and participants’ concerns and prompt states and their agencies to consider solutions that simplify EVV. For example, many FMS providers collect much of the same information as required by EVV, as they integrate with reporting mechanisms so that self-directing participants, case managers, agencies and managed care organizations have real-time data to help with budgeting and scheduling decisions. An FMS may be able to fold EVV into their service offerings for self-directing participants, reducing the number of systems to manage and providing valuable training and support to the caregivers using their EVV tool.
Embracing EVV Protects
LTSS EVV is here to stay, and implementing effective EVV systems will be more important than ever as government spending is scrutinized. By proactively embracing EVV processes, advocating for person-centered approaches and pushing for resources and flexibility to ensure ongoing compliance, providers and caregivers can help ensure that participants and their support systems will remain accessible and sufficient for their needs.