For many states, achieving Centers for Medicare & Medicaid Services (CMS) certification for their electronic visit verification (EVV) solution is a main goal, and a lofty one at that. The application process can be long, expensive, and difficult to navigate, but the benefits – more efficient processes, demonstrated compliance, and enhanced federal financial participation (FFP) – make the effort worthwhile.
In this blog post, we’ll share ways to streamline your path to CMS EVV certification. But before diving into those steps, let’s get clear on the basic requirements. CMS has simplified the certification process, structuring it around the following elements:
- Outcome statements. These describe the desired results once the system is implemented, such as availability and accessibility, and preventing fraud. CMS-provided outcomes are based on the Cures Act.
- Evaluation criteria and required evidence. These correspond to outcome statements and are used by the state seeking certification, and by CMS to evaluate the system’s functionality and its compliance with laws, regulations, and industry good practices.
- Key performance indicators (KPIs). These metrics support the outcome statements and are used to track the performance of the system over time. KPIs include the percentage of claims paid with supporting EVV data.
Now, let’s discuss how you can prepare to achieve CMS EVV certification.
Key #1: Communicate & Engage with Stakeholders Consistently
The certification process involves multiple parties and many moving parts, therefore regular communication is key. Be sure you are engaging with relevant individuals from the following groups early on and throughout the implementation process:
- Managed care organizations (MCOs), if applicable
- State homecare associations
- Homecare providers
- Technology vendors
- Member advocacy stakeholders
Consistent correspondence with these stakeholders will not only allow for improved transparency and effective collaboration but will also give all teams the confidence that the solution you’re implementing aligns with their needs. If you find the system falls short for any parties, addressing those issues sooner rather than later will save you from having to make more costly changes in the future.
Key #2: Set Policies on EVV Requirements
Under the Cures Act, the following elements must be electronically verified for all homecare visits: type of service performed; individual receiving the service; date of the service; location of the service delivery; individual providing the service; and the time the service begins and ends.
Because many states have additional requirements and validation rules regarding the data being collected, those specific items should be clearly outlined and communicated. To start, ensure you’re addressing the following:
- What makes a visit EVV compliant in your state?
- What are the data expectations?
- What rules are being applied to confirm that visit is compliant?
If your state has an Open (or Choice) Model, it is important to make sure that all providers are using an EVV solution that meets the state’s requirements.
Key #3: Establish Clear Measures & Gates to Drive Adoption
Because of the complexities involved in implementing EVV, it is unlikely that you will achieve 100% compliance right from the start. Therefore, it’s wise to set more reasonable expectations so that rather than overwhelming your teams with impossible timelines, you can keep them motivated, confident, and on-track.
We suggest focusing your initial go-live, or soft launch, strictly on the utilization of EVV tools. Many providers find this approach to be less abrasive, as it allows them time to get comfortable with the solution and understand how EVV will impact their daily operations. Then, as providers have a chance to adapt to the system, step up your compliance goals. Set a target percentage of claims to be confirmed electronically vs. manually. For some states, that goal may be 50% electronic confirmations; for others, it could be 85%.
It’s important to note that when evaluating your state’s EVV system for certification, CMS won’t frown upon a soft launch, as they understand it’s a necessary practice to engage stakeholders and equip all parties to reach full compliance. What CMS does want to ensure is that you have a solution in place that will enable you to collect the required data and only pay EVV-compliant claims.
Key #4: Organize & Prep for Final System Certification
In order to be eligible for a CMS certification review, you must first complete an Operational Readiness Review (ORR) with CMS, and your EVV solution needs to be operational for at least six months before final system certification.
As you prepare for your ORR and final certification presentation, be sure to consider the following items which CMS will expect you to address:
- How your state’s Medicaid program is organized
- Demos to prove that your solution meets all criteria for outcomes-based certification (OBC)
- Descriptions of the services EVV will impact and be applied to
- Your plans to collect and report KPIs
- How you will leverage the data collected to drive quality of care and ensure payment integrity
While the path to CMS EVV Certification is complex, consistent communication with all stakeholders, clear policies, and strong organizational practices will streamline your process and prevent unnecessary loss of time and resources.
HHAeXchange has a long history of supporting both payers and providers in achieving unparalleled communication, transparency, efficiency, and compliance. In addition to helping dozens of states and MCOs manage billions of dollars in Medicaid claims, HHAeXchange was recently granted CMS certification of its EVV system as the State of New Jersey’s EVV aggregator.
Learn more about how HHAeXchange can help you achieve CMS EVV certification.