Fraud in home healthcare is a persistent problem. Recently, a federal grand jury indicted more than a dozen residents for billing Medicare and Medicaid $1.3 million for services that weren’t provided, according to the St. Louis Post-Dispatch. Earlier, in November, 12 home healthcare workers were indicted for defrauding the Pennsylvania Medicaid program out of $87 million over more than six years, Home Health Care News reports.
Those indictments are indicative of why, as part of the 2016 21st Century Cures Act, states were called upon to require the use of electronic visit verification (EVV). While an original deadline of 2019 for personal care services was pushed to 2020 (and stands at 2023 for home health services) that doesn’t change the fact that providers must figure out plans to implement such systems rather quickly, or face reductions to federal Medicaid assistance.
The provision, according to the Centers for Medicare & Medicaid Services, does not mandate the use of any particular kind of system, only that the system “be able to electronically verify, with respect to visits conducted as part of personal care services or home healthcare services”: the type of service performed; who received the service; who provided the service; and when and where the service took place, including start and end times. CMS, however, is considering implementing a survey to require states to report on their EVV progress, according to Home Health Line; public comment on the proposal closed in December.
So, what does this mean for industry stakeholders over the next couple of years?
How Providers Can Vet EVV Vendors
For starters, depending on which model a state chooses, providers may need to vet technology vendors to determine what features meet their needs. According to HomeCare, some appropriate questions for vetting vendors include:
- What is the experience of beneficiaries and providers using the system?
- Can the system reliably verify all of the necessary elements? How are these verified?
- Is the system interoperable with the state’s Medicaid enterprise systems?
Additionally, states or providers will need to determine which technology is the right fit to get the job done. According to a CMS presentation from December 2017, technology already in use includes:
- Smartphones and tablets, including GPS-enabled tablets
- A one-time password generator
- Biometrics, such as fingerprint scanners and voice-recognition tools, to verify caregiver check-ins
Privacy Concerns for EVV Systems Persist
The law raised privacy concerns for some industry stakeholders. In September, for instance, the Consortium for Citizens with Disabilities sent a letter to CMS Administrator Seema Verma praising the one-year delay, but lamenting the collection of data on caregivers while not on the job.
“States have collected data that tracks consumers’ and caregivers’ locations as they go about everyday activities such as shopping, running errands and engaging in recreational activities,” CCD wrote. “This has been a particular concern in consumer-directed programs.”
As of last spring, nearly three dozen states decided which EVV model they would implement, according to Partnership for Medicaid Home-Based Care, with a vast majority choosing the open model that allows providers to choose their technology. Moving forward, we’ll see which tools are deployed and how privacy concerns and other issues will be addressed by the government.