Understanding your state’s EVV system model
In my last post, I examined the new federal and state-specific electronic visit verification (EVV) requirements for all Medicaid-funded services requiring an in-home visit. This mandated the use of an EVV for personal care services (PCS) by Jan. 1, 2020 and for home health care services (HHCS) by Jan. 1, 2023 to avoid reductions in Federal Medical Assistance Percentage (FMAP) matching of expenditures over the first five years. This post will highlight the five EVV systems models, and the pros and cons of each.
A breakdown of the five EVV models
There are five major EVV system models states can implement. All five provide similar solutions but vary with respect to state involvement in vendor selection and EVV management. Additionally, states can choose more than one model. It is important to note that section 12006 of the Cures Act requires that states have flexibility in the type of EVV model they implement, as long as the model or approach selected meets statutory requirements, including compliance with HIPAA privacy and security standards. CMS does not endorse any model.
Differences between the models
In choosing from these models, states face tradeoffs between the ease of information sharing, among other factors. For example, while provider and managed care plan choice models provide more flexibility for providers and MCOs, those models require data across different systems to be aggregated into a common format. States wishing to avoid aggregating data across multiple systems might opt for a state-mandated in-house system, but developing an in-house system may impose a greater administrative burden on the state.
1. The Provider choice model
In this model, providers select their EVV vendor and self-fund EVV implementation. States set requirements and standards for EVV vendors, including specific data collection requirements. States using this model may or may not provide an approved list of EVV vendors. Single or small provider agencies may find this model technologically or financially burdensome. States may mitigate providers’ financial burden by incorporating costs associated with the purchase of EVV devices and/or equipment in the method used to develop the rate paid to the provider for rendering services.
In the provider choice model, other than setting standards for EVV systems generally, the state might have little or no involvement in the selection of the provider’s EVV vendor, which may complicate a state’s access to EVV data and its ability to report and link EVV data to claims, care plan authorizations, and the Medicaid Management Information System (MMIS).
2. The Managed Care Organization (MCO) choice model
This is like the provider choice model, except that MCOs, rather than providers, select and reimburse their EVV vendor solution. Because the state would mandate the MCO to contract with an EVV vendor, the state must include expected expenditures. These expenditures must relate to contracting with the vendor within the capitation rates paid to the MCOs so the rates are actuarially sound. The minimum standards outlined by the state need to be included in the contract with the MCO for EVV vendor selection, as well as details about specific data collection from the MCO(s).
Providers may feel the most burden in this model, especially if states have multiple MCOs, since providers may have to train on and use more than one EVV system, adopt multiple forms of technology, and navigate several vendor helplines. Further, complications may arise for providers integrating multiple EVV systems with their payroll and scheduling systems. These factors may increase administrative costs to providers.
3. The state-mandated external vendor model
This model states contract with a single EVV vendor to implement a single EVV solution. The state requires that all MCOs (if applicable), providers, individuals, and their families use that system to document services. This model guarantees standardization and access to all data for the state since it uses one vendor. The state has direct involvement in the management and oversight of the EVV program, which should promote compliance with EVV requirements. In addition, this may be less costly for the state than building an EVV system. There is an administrative burden for states in choosing and contracting with an EVV vendor as well as costs associated with managing the system. The state and/or its EVV vendor and/or any outsourced contractor are also responsible for providing all education and training on EVV operations, including technical training on the use of the system, to individuals, their families, and providers.
4. The states-mandated in-house system model
In this model, the state develops, operates, and manages its own EVV system. This model allows standardization and access to data for the state without a need to aggregate data from diverse external EVV systems. The administrative burden on the state is greater compared to other models since the state develops, implements, and manages its own EVV system. In addition, even if the state outsources training, the state is responsible for ensuring the development and dissemination of training, including technical training on the use of the system, to state staff, providers, individuals, and their families.
5. Open vendor model
This is a hybrid model where the state contracts with at least one EVV vendor. Or, they can operate their own EVV system while allowing providers and MCOs with existing EVV systems to continue to use those systems. This means providers and MCOs have the option of using the state’s system or continuing to use their own system. States are responsible for the development and implementation of policies and procedures regarding the EVV program and maintaining oversight. The open vendor model allows providers and MCOs with existing EVV technology the flexibility to use their current systems. However, to comply the state will require some level of integration between EVV solutions.
Some states using the open vendor model have a list of preferred EVV vendors. States can implement an “open model” in which a system aggregates EVV data from both the state-contracted vendor and third-party vendors. Similar to the provider- and MCO-based models, the states need to develop a data aggregation solution and specify the data to be collected from providers and MCOs. Each EVV system would then report standardized data to the state and each system would have the flexibility to be implemented according to the basic set of requirements identified in section 1903(l) and any other additional requirements established by the state.
Most states operate open models, which offers flexibility for providers, but requires a strong technology partner. There are many considerations when searching for the right fit for your organization. MatrixCare offers a comprehensive solution to meet EVV compliance changes, now and in the future.
Whichever technology you use, make sure the system can support your model, and ensure compliance. So, you can stay focused on providing care.
- gov EVV Website
- EVV Requirements in the 21st Century Cures Act: NASAUD Conference Workshop; CMS, August 2018
- 2018 Electronic Visit Verification Implications for States, Providers and Medicaid Participants, NASAUD
- FAQs: Cures Act for Electronic Visit Verification, Issued 5/16/18
- Electronic Visit Verification for Personal Care Services: Status of State Implementation; MACPAC The 21st Century Cures Act
This content is for informational purposes only and is provided as-is. Information and views expressed herein may change without notice. As such, we encourage you to seek, as appropriate, regulatory, and legal advice.