Open vs closed EVV models, and why it decides your options

Before you compare a single EVV product, you need to know whether your state permits you to choose one. Agencies routinely get this backwards. They evaluate software for weeks and then discover their state mandates a specific system, or conversely they resign themselves to a state portal that does not fit how they work, without realizing they were free to run something alongside it.

Federal law required states to implement EVV. It did not tell them how to structure it, so states made different choices. Those choices are usually described as models, and the labels are not perfectly consistent between states, which does not help.

In a closed model, sometimes called a state mandated model, the state selects one EVV system and every affected provider uses it. There is no alternative and no integration path for a system of your own.

What is good about it. There is no decision to make and no procurement to run. The system is provided, usually free, usually with training. Everyone in your state is using the same thing, so peers can help you and the state can support one product properly.

What is hard about it. If the system fits your operation badly, you have no recourse. If it lacks something you need, such as workable scheduling or usable offline capture, your options are to work around it or to run a second system alongside it for your own operational purposes while still submitting through the mandated one.

That second option is more common than vendors admit. Plenty of agencies in closed states keep a separate scheduling and hours system because the mandated EVV portal handles compliance but does not run their day.

In an open vendor model the state contracts an EVV system and offers it to providers at no cost, and providers may instead use a third-party system of their choosing, provided that system integrates with the state's and sends visit data through.

Two things about this are frequently misunderstood.

The free system is genuinely free. In an open vendor state, the state-provided system typically costs providers nothing and satisfies the requirement on its own. You are not obliged to spend money to comply. Any vendor implying otherwise is misrepresenting your position.

Choosing a third party does not release you from the state system. In most open vendor states you still need an account in the state's system, because that is where your data has to arrive. You are choosing where visits are captured, not whether they reach the state.

Integration is not automatic either. It normally involves registering your intent with the state or its vendor, a technical interface built to a published specification, and a testing period before you go live. Ask any prospective vendor whether they are already integrated in your state, and how long it takes, before you sign anything.

Real states are messier than a two-way split, and a few patterns come up repeatedly.

Different models for different programs. A state may run one arrangement for fee-for-service Medicaid and leave managed care plans to set their own. This is common and it catches agencies out, because the answer they find on the state website may describe a program they do not bill under.

Managed care plans choosing separately. Where care is delivered through managed care organizations, each plan may have its own EVV arrangement. An agency contracted with three plans can face three sets of expectations even in a state that looks settled from the outside.

Model changes over time. States re-procure. A state that mandated one vendor in 2020 may have moved to an open model since, or changed which vendor holds the contract. Guidance you read a few years ago may be describing an arrangement that no longer exists.

Four questions, in this order, will get you a reliable answer.

1. Which programs do you actually bill? Fee-for-service Medicaid, managed care, a waiver program, private pay, or a mix. The answer to everything else depends on this.
2. For each one, who sets the EVV requirement? The state Medicaid agency for fee-for-service, and the individual plan for managed care.
3. Does that payer provide a system at no cost? If yes, you have a compliant option that costs nothing, whatever else you decide.
4. Does that payer permit a third-party system, and what does integration require? If yes, you have a real choice. If no, you know where you stand.

Get these answers from the payer, in writing where you can. Our state guides cover what we have been able to verify from official sources, and we say plainly where we could not verify something. They are a starting point, not a substitute for asking.

Having a choice does not mean you should exercise it. The honest decision rule is narrower than most vendors would like.

Stay with the free state system if nearly all your visits are billed to the payer that provides it, your caregivers are managing fine with it, and your scheduling and payroll are not painful. Adding a second system to an operation that is working is a cost with no return.

Consider adding something alongside it if you run private pay visits the state system never sees, your schedule changes constantly, your caregivers struggle with the state app in homes with poor signal, or reconciling hours for payroll is eating hours of someone's week. Those are operational problems, and a compliance portal is not built to solve them.

Switch entirely to a third party only if it is genuinely integrated in your state, you have confirmed that with the state or plan rather than only with the vendor, and you have thought about what happens if that integration breaks.

The one thing not to do is buy software because a salesperson implied you were out of compliance without it. In an open vendor state with a free portal, that claim is not true.