What is electronic visit verification?

Strip away the acronym and EVV is a simple idea. When a caregiver visits someone at home and Medicaid pays for that visit, there has to be an electronic record proving it happened. Not a timesheet filled in on Friday from memory. A record created at the time, by the person who was there.

The requirement comes from federal law, specifically section 12006 of the 21st Century Cures Act, which was signed in December 2016. The reasoning behind it was straightforward: Medicaid was paying for a large volume of home visits with almost no way to confirm they took place, and paper records are difficult to audit and easy to fabricate.

What the law does not do is tell you which software to buy, or even require you to buy any. It sets out what has to be captured and leaves each state to decide how. That distinction matters a great deal, and we come back to it below.

Federal law names six data elements. Every compliant visit record captures all six, in every state, regardless of which system you use:

1. The type of service performed. What was actually delivered, matched to the service the client is authorized for.
2. The individual receiving the service. Which client the visit was for.
3. The date of the service. The day it happened.
4. The location of service delivery. Where the visit took place. This is the element that leads most systems to use GPS, though the law does not specifically require GPS.
5. The individual providing the service. Which caregiver delivered it.
6. The time the service begins and ends. Both, which is what makes the duration verifiable.

That is the whole federal list. Individual states add their own requirements on top, and some are considerably more demanding, but these six are the floor everywhere.

Notice what is not on the list. There is no requirement for biometrics, no requirement for the client to sign anything on a screen, and no requirement to record what was said or done during the visit. Some systems add those things. The law does not ask for them.

EVV applies to Medicaid-funded personal care services and home health services that require an in-home visit. In practice that covers most non-medical home care and home health agencies billing Medicaid, including services delivered through consumer-directed and self-directed programs.

The requirement follows the funding, not the agency. This is the part that confuses people most, so it is worth stating clearly:

• Medicaid-funded visits: EVV applies.
• Private pay visits: the federal EVV requirement does not apply. A client paying you directly is not a Medicaid visit.
• A mixed caseload: your Medicaid visits need EVV and your private pay visits do not, which is why many agencies end up tracking two sets of hours in two different places.

Long-term care insurance, VA programs and other payers each set their own rules. Some require electronic verification, some do not, and none of them are governed by the Cures Act requirement.

Whether a particular program in your state counts is a question for your state Medicaid agency or your managed care plan. Our state guides cover what we have been able to verify state by state.

Three methods are in common use, and most states permit more than one.

A mobile app

The caregiver checks in and out on a phone. Location comes from the device, times are recorded as they happen. This is the most common approach and the least intrusive for the client, since nothing has to happen in their home beyond the caregiver tapping a screen.

The obvious weakness is connectivity. A phone with no signal cannot reach a server, which is why the question of what an app does when it is offline is worth asking any vendor before you buy.

Telephony

The caregiver calls a toll-free number from the client's landline at the start and end of the visit. Location is inferred from the phone number being called from. It works without a smartphone and without data, which is why it persists.

It also depends on the client having a landline, which fewer and fewer do.

A fixed device in the home

A small device stays in the client's home and generates a code the caregiver records. Useful where there is no cell signal and no landline. It is more equipment to manage, and it only helps for clients who have one.

"I have to buy EVV software to comply"

Often untrue. Many states provide an EVV system to providers at no cost. Whether yours does, and what it covers, is the single most useful thing to establish before you spend anything. Any vendor telling you that compliance requires buying their product is selling, not informing.

"EVV means being tracked all day"

The law requires the location of service delivery, which means where the visit happened. It does not require continuous tracking, and a well-built system captures location at check-in and check-out only. Caregivers ask about this constantly and deserve a straight answer.

"A signed timesheet is fine as a backup"

A paper timesheet is not an electronic visit verification record. If your system fails and you fall back to paper, you have a gap, and your state will have a specified process for handling it. Find out what that process is before you need it.

"EVV proves the care was good"

It proves someone was at the right place at the right time for the right duration. What happened during the visit is a supervision and care planning question. EVV is an attendance record, not a quality measure, and treating it as one leads agencies to over-trust it.

If EVV is new to you, work through it in this order:

1. Find out what your state provides. Read the guide for your state, then confirm it with your state Medicaid agency, because we may be wrong and they cannot be.
2. Find out whether your state lets you choose a system or requires a specific one. That is the open versus closed model question, and it determines whether you have a decision to make at all.
3. If you are in managed care, ask each plan you contract with. Plans frequently have their own arrangements that differ from the state's.
4. Only then consider whether you need anything beyond what you have been given.

Doing it in that order stops you buying something to solve a problem your state may have already solved for you.