Earlier today, the Centers for Medicare and Medicaid Services (CMS) released further guidance on the implementation of electronic visit verification (EVV) for States. This federal guidance document is in addition to the guidance released May 2018.
In an attempt to answer commonly asked questions, the very short and direct guidance offers clarity to: live-in caregivers; the delivery of medical supplies, equipment or appliances; EVV use within the community; and web-based timesheets.
This guidance is a win-some, lose-some situation for the community. Here’s the breakdown of what the federal government has said to States:
- Caregivers who reside with the consumer are not federally mandated to use EVV. States are permitted, at their own discretion, to use EVV for live-in caregivers “to curb fraud, waste and abuse … particularly when using discrete units of reimbursement, such as on an hourly basis.”
- Delivery, set-up and instruction of use on medical equipment, supplies or appliances are not subject to EVV use.
- Assistance received in the community is not subject to EVV use. States are permitted, at their own discretion, to capture services rendered in the community.
- Where services are provided both in the community and at home, only the minutes of service provided at home are required to use EVV.
- Use of “home” or “community” to capture location is acceptable.
- Web-based timesheets are not an acceptable form of EVV.
This new guidance creates additional challenges for States and consumers, in particular where services are provided in both the home and the community. While EVV use in the community is not required, recording the hours for purposes of submitting payroll is essential. Should consumers maintain paper timesheets for their activities in the community and an EVV recording system for services in the home, States will need to manage the additional administrative burden this will place on payroll services. There is also significant opportunity for errors to pay.
Stop EVV is disappointed to learn CMS does not agree that a web-based timesheet is an acceptable EVV solution. States such as California, where a web-based timesheet has been in play for many years, will need to re-design their entire payroll structure before the January 1, 2020 implementation deadline approaches.
“The web-based EVV model is the current standard for consumer-directed services,” says Kendra Scalia, Director of Policy at Stop EVV. “It is the only model developed by consumers, for consumers. This loss as an acceptable solution will inevitably deteriorate consumer-directed programs nationwide, rolling back civil right advancements gained through the independent living movement.”
Notably not addressed in the August 2019 guidance document are outstanding questions surrounding the need for EVV systems to capture services in real-time.
Stop EVV is committed to continue its work with national and local groups to find solutions that satisfy the 21st Century Cures Act and maintains the full intent of consumer-directed services.