The nationwide rollout of electronic visit verification (EVV) has been nothing short of a mess for many, plagued by moving deadlines, poor planning and bad execution. But while the mandate has admittedly made life difficult for many providers, as a whole, requirements like EVV are a good thing for providers and the individuals they serve.
On the surface, the EVV rule is designed to prevent fraud by requiring providers of personal care or home health care services to electronically verify the delivery of these services. The U.S. Government Accountability Office conservatively estimates that fraudulent billing costs Medicare and Medicaid $95 billion a year — about 10% of total health spending.
One of the biggest culprits of fraud is billing for services that were never rendered. With limited funds to go around, it’s honest providers who end up paying the price.
“We’re competing with other agencies for hours. If they bill before us, they’re using up the hours before we have a chance to submit and get them claimed,” says Shoshanah Adams, an associate program director at The Arc Lane County.
In order to comply with EVV requirements, providers must collect and validate the date, location, and type of service; the individuals receiving and providing the service; and the time the service begins and ends.
One positive side effect of EVV compliance, as some providers have noted, is that it has forced them to take a hard look at their service tracking and documentation processes.
Think about it: How many times have you lost track of billable hours simply because someone forgot to fill out their timesheet until the end of the week? EVV solves this issue by requiring caregivers to clock in and out at the time services are delivered, which means an hour worked is always an hour paid.
“It’s easy to mess up paper timesheets. Now my staff push a button, they’re clocked in; they push a button, they’re clocked out. Shifts are reported with better accuracy, because they don’t have to try and remember when they started,” says Adams.
Billability aside, there’s a much larger reason EVV holds value — the individuals who rely on others for safe and dependable care. EVV was developed to ensure individuals receive the services they were promised, and cut down on the potential for neglect.
Instances of neglect are alarmingly common among individuals with disabilities and the elderly. Neglect occurs when caregivers fail to meet an individual’s basic needs — or worse, don’t show up at all. Approximately 30% of individuals who need assistance with daily care, health and safety, and accessing the community have experienced some form of abuse or neglect.
What’s more, much of this neglect happens in community settings — one target of the EVV regulation. Between 2012 and 2016, the US Department of Health and Human Services (HHS) investigated over 200 cases involving fraud and patient harm or neglect in the personal care services program nationwide. EVV aims to prevent situations like these by ensuring that home care visits are actually taking place and that individuals are getting the care they need. At its core, EVV is a modern way of ensuring that neglect becomes a thing of the past, and that the most vulnerable are protected.
Of course, EVV is far from perfect. As Disability Rights California (DRC) points out, rules like EVV have the potential to infringe on the rights of individuals with disabilities.
“DRC believes that people with disabilities have the right to receive services in the most integrated setting possible, in a manner that maximizes their personal autonomy and independence,” their website states.
Arguably one of the biggest concerns is the collection of GPS-based location data. Not only could this be intrusive, it might also discourage providers from delivering services away from the home. For instance, some workers have reported that they are not allowed to be clocked in during travel times or while accompanying individuals to medical appointments.
However, a closer look reveals that the EVV law itself does not require caregivers to supply GPS location data. Individual states have the power to prohibit GPS tracking, if they choose. And even in states where a GPS location is required for services, EVV systems do not have to continuously track this information. Instead, they can record location data only at the start and end of the visit.
Caregivers have also raised concerns around the use of location tracking. But the idea of requiring employees to electronically verify their whereabouts, along with other service information, is not exactly unusual.
For example, Amazon requires its drivers to provide photographic proof of delivery location when they leave a package on a customer’s porch. Likewise, hospitals, airlines, and trucking companies commonly use apps like Paylocity with location-based restrictions that dictate where users can clock in and clock out. Similar to EVV systems, these apps use GPS tracking information to make sure that the employees are clocking in and out from authorized locations.
The compliance burden of EVV is real, and it’s not going away anytime soon. Still, it is important to remember what EVV is tackling: protecting individuals recieving care, reducing fraud, and improving service tracking. That’s a victory for everyone.
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