CMS Auditing Electronic Visit Verification Systems
October 1, 2023
EXECUTIVE SUMMARY
CMS will audit the electronic visit verification for home services. Failure to properly enter the required data could result in unpaid claims.
- Each state implemented its own electronic system.
- Data must verify the patient’s care plan was executed properly.
- Employees should be retrained periodically on the requirements.
The Office of Inspector General (OIG) announced it will audit electronic visit verification (EVV) systems for personal care services (PCS) and home healthcare services (HHCS), creating an obligation to ensure compliance.1
The source of the EVV requirements is a section of the 21st Century Cures Act, says E. Bahati Mutisya, JD, an attorney with Baker Donelson in Raleigh, NC. The goal of the Cures Act was to bring innovation and advancement to the provision of healthcare to make it more efficient. One of the sections required all states to implement the EVV system for two types of services provided in a patient’s home — PCS and HHCS.
State EVV Systems
The Cures Act requires a state EVV system to record who is the beneficiary receiving the service and individual providing the service, what type of service is provided, when the service was provided and time the service begins and ends, and the location of service delivery. Because the state must report that information to CMS, it will require the same information from healthcare organizations, Mutisya says. Healthcare organizations will be held accountable for the information when reviewing claims.
“The guidance has indicated that the government wants to make sure that when a beneficiary is signed up for the services, and they have been authorized, that they’re actually receiving them,” Mutisya explains. “It’s not in an institutional setting surrounded by other employees, so they want to be able to monitor that the services are actually being provided when they say they are. The electronic system that all states have been required to roll out allows these providers to input data that verifies ‘Here’s when I came in, here’s what I did, and here’s when I left.’”
Each beneficiary receives a care plan and a schedule that provides the dates and times the aide or staff person will be in the home to provide services. Because it is laid out in a plan that must be approved and authorized, the EVV is a way to track the execution and make sure the providers are complying with that plan.
“If you have a schedule that says this person is scheduled for two hours of service or an hour visit here, you want to make sure that the employees are inputting the beginning and the end time that captures that full hour so that it translates to units that will be billed,” Mutisya says. “If the data do not add up and match what has been authorized or approved, then that’s when the provider has problems with getting paid.”
Different Electronic Options
Some states use a single EVV system, and some use an open system that allows participants to use different methods to report the data, Mutisya says. The ideal option is one that includes a smartphone app, which encourages the entrance of prompt and accurate data. However, some employees may not have smartphones, or struggle working with an app.
Other options include a phone system in which the employee calls a data receptionist to report the information. Some states allow a fixed verification system in which a small device at the patient’s home is used to enter data that will be collected regularly.
Whatever method is used, it is important for healthcare organizations to ensure employees are diligently reporting the information. “What this means for organizations is that if the OIG is conducting this audit, they’re going to be looking very closely at the claims that are submitted and whether there is EVV data to support the claims that have been submitted for payment,” Mutisya says. “We’ve seen with some providers who are subject to the EVV requirements that there’s been a bit of a transition period. In some cases, it’s been a little difficult for staff members to get on board, maybe because they’re just used to doing things the old way. But what’s important to know is that there really isn’t an alternative, there isn’t an option, there’s no opt out.”
Mutisya recommends these best practices:
- Confirm required information has been properly submitted into the EVV system and that it is consistent with the claims billed.
- Submit prior authorization information along with EVV data to demonstrate the data are based on authorized services.
- Establish written policies and procedures that address EVV for employees to follow, such as what devices they are using and how they should be used.
- Conduct routine training on the use of EVV.
- Seek out consultants or vendors who can advise on how to ensure neither employees nor beneficiaries have tampered with the technology used to record EVV data.
- Establish a monitoring system that verifies the EVV information entered is accurate.
Periodic retraining is important, particularly with the staff shortages across the healthcare field and staff turnover.
“It’s important to make sure you have a clear understanding of what they need, have it written down, and that you have given your employees not just access to training, but access to these written policies and procedures for them to review to make sure that they are complying properly,” Mutisya says. “If there are too many mistakes made along the way that are not addressed by your organization, it could end up hurting you. If you end up with a post-payment review or another type of audit and the government catches these mistakes, then you’re stuck in a situation where you may not get paid for services that were actually rendered.”
REFERENCE
- Baker Donelson. Electronic visit verification: What personal care services and home health care services providers need to know. June 28, 2023.
SOURCE
- E. Bahati Mutisya, JD, Baker Donelson, Raleigh, NC. Phone: (984) 844-7916. Email: [email protected].
The Office of Inspector General announced it will audit electronic visit verification systems for personal care services and home healthcare services, creating an obligation to ensure compliance.
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