Electronic Visit Verification Mandates: The Impact of Open vs. Closed Systems

Jul 13, 2017 9:30:00 AM

The 21st Century Cures Act has established January 1, 2019, as the deadline for states to establish Electronic Visit Verification (EVV) standards for Medicaid-funded personal care services. As this date draws closer, state Medicaid directors must soon decide on the type of EVV system they’ll require.

Electronic Visit Verification Mandates: The Impact of Open vs. Closed SystemsSpecifically, states will need to decide whether to mandate an open or closed EVV system. These two options are very different from each other, with different implications for home care agencies.

Before states enact these sweeping changes for their constituent agencies, states must understand these differences, so they can endorse the best solution for their agencies’ — and their own — needs.

Understanding Open and Closed Electronic Visit Verification Systems

State Medicaid directors face two solutions for meeting the EVV mandate:

  • A closed system, which lets a state stipulate the EVV vendor and requires agency providers to implement only that specific system, resulting in a significant burden on the state, providers, and caregivers.

  • An open system, which is a hybrid approach that lets a state set minimum EVV requirements and empowers agency providers to choose the EVV system that best meets their needs. The state then implements a vendor-agnostic aggregator system to collect data from across EVV systems and apply standard business rules. This ensures that EVV standards are met and lets the aggregator oversee the entire program.

Each system has its own impact on compliance, cost, and productivity for agencies. These impacts are significant, and agencies shouldn’t be relegated to a passive role in this decision process. In fact, they should be vocal advocates for the type of system that will best serve them, their clients, and their states.

How Open Electronic Visit Verification Systems Can Benefit Agencies

While some states adopt closed EVV systems for simplified implementation and to ensure compliance across agencies, it’s not always the best choice for either agencies or the state. Open systems, in contrast, offer participants four distinct advantages:

1. Functionality and Cost

Agencies in states considering closed EVV systems are faced with two choices, neither of which is ideal.

  • Replace their existing system with the state-selected one. For agencies that have already invested in an EVV solution, a closed system frequently means these agencies have wasted considerable time, money, and effort in a now irrelevant EVV product.

  • Maintain multiple separate systems. What happens if the state-selected system ends up being less robust than the agency’s system? These agencies may need to either give up the workflow efficiencies they’ve gained with their own system, or supplement their own system with paper documentation to make up for the state system’s shortfalls – which can result in billing and reporting errors.

The situation gets worse for agencies that operate in multiple states. In these cases, the agency may be required to use multiple state-mandated EVV systems — creating an extensive administrative burden for the agency and hindering the agency’s ability to easily monitor and analyze visit data across the organization.

However, when agencies are allowed to select their own EVV solutions, both agencies and states gain efficiencies. For states, this may include cost benefits, since the state will not be responsible for procurement and implementation, and efficiency benefits, because the state can now focus its resources on data evaluation instead of data capture and technology maintenance.

2. Flexibility

A closed system locks an agency into a fixed solution that might not provide all the options they need. But an open system lets agencies tailor functionality to their requirements and implement the solution that works best for them. If they need extra services — like sophisticated point-of-care documentation or GPS-based location services — they can add them in. If basic functionality is all they require, that’s all they implement.

Additionally, the ability of an EVV vendor to support a closed system mandate must be considered. Imagine the difficulty a single vendor faces as it rolls its solution out to all home care agencies of varying sizes within a state. But with an open system, agencies aren’t dependent on one vendor rolling out one solution at one time, and that vendor isn’t trying to address an entire state’s questions and issues simultaneously.

3. Agency Backing

For any state-wide EVV mandate to be successful, the state needs the support of the agencies who will be using the EVV solution. That support is automatic in an open system where agencies have chosen the most fitting solution to fulfill their needs.

With a closed system in which one solution is forced upon users, that same buy-in can’t always be expected. When Connecticut rolled out its closed EVV system, home care agencies quickly and loudly pointed out the system’s myriad problems, including billing issues, payment delays, and the need for agencies to hire extra staff to manage the software. As a result of the overwhelmingly negative feedback, the state acknowledged the problems and delayed implementation by four months to resolve the issues.

4. Open-Market Competition

One of the biggest benefits of an open system is that it fosters innovation. When vendors are competing for market share, there’s increased incentive to develop cutting-edge solutions. Not only can these solutions increase efficiency, but they can also help agencies and caregivers deliver additional value to their client interactions.

Advocating the Best Solution for Your Home Care Agency

As states look toward finalizing their EVV solutions, it’s clear that an open system offers the best of both worlds: States gain the verification data they want, while agencies are able to choose the EVV solution that best meets their needs.

Given everything at stake, agencies should consider joining the public discourse about EVV. Above all, agencies should ensure that any EVV system safeguards their access to the real-time care delivery information they need. The right EVV solution will not only improve compliance with the latest mandates, it will help agencies meet delivery management objectives across all the care and services they deliver.

CellTrak’s Care Delivery Management solution interfaces with the leading EMRs as well as mandated EVV vendors. This means every agency can supply verification data in the format their state or payer requires while also benefitting from CellTrak’s advanced functionality. Contact us today to learn why home health and community care leaders rely on our solution to achieve objectives; optimize workflows; and improve results in terms of compliance, cost, care, and communication.

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Topics: Electronic Visit Verification, Compliance, EVV