Electronic Visit Verification
Electronic Visit Verification, or EVV, is a requirement under the 21st Century Cures Act, a federal law passed in December of 2016. Under the 21st Century Cures Act, states must implement an electronic system to verify certain home and community based services were delivered in order to continue receiving federal financial support toward the costs of those services.
Federal law, Subsection l of Section 1903 of the Social Security Act (42 U.S.C. 1396b), requires all states to implement EVV for Medicaid-funded personal care services by January 2020 and home health care services by January 2023. States can select and implement their own EVV design. However, the EVV system must verify: type of service performed; individual receiving the service; date of the service; location of service delivery; individual providing the services and time the service begins and ends.
NH EVV Implementation
New Hampshire worked with our stakeholder community in the first half of 2020 to identify New Hampshire specific EVV design and program requirements. Those requirements were utilized to competitively procure the information system components needed to implement EVV.
NH has contracted with First Data Government Solutions LP to provide the EVV system and data aggregator. Implementation will begin in early 2023 and the EVV implementation timeline will be updated when available.
NH is planning to implement an Open Vendor EVV Design Model. This model gives flexibility to the State to contract with a single EVV vendor, but allows providers and MCOs to use other vendors. The State EVV system could be used by providers that do not have their own EVV solution and will aggregate EVV data from multiple sources for use prior to claims payment.
NH sought a CMS good faith effort exemption for personal care services to request to delay implementation until January 1, 2021, which was approved on November 21, 2019. New Hampshire contracted with Mercer Health & Benefits LLC to assist with stakeholder engagement and identifying EVV business and systems requirements that were used as the foundation for the Request for Proposal (RFP) to procure EVV technology and services. This process took place in 2020.
In October 2022, NH submitted a CMS good faith effort exemption for Home Health Care Services that was approved by CMS on December 1, 2022.
- EVV Implementation Timeline
- List of Medicaid Services That Will Require EVV
- EVV Market Analysis Report
- Family Friendly Documents (Thanks to NH Family Voices)
New Hampshire is committed to the full involvement of recipients, family caregivers, providers and other stakeholders in the planning and implementation of EVV. Stakeholder meetings and surveys were held in 2020 to obtain feedback from the stakeholder community, identify best practices, and identify needs/requirements to implement EVV. Stakeholders will be reengaged once the EVV system implementation project begins. Read the overview of the EVV stakeholder engagement activities.
EVV Distribution List
If you would like to be included in the EVV distribution list, please send this information to EVV@dhhs.nh.gov:
- Identify your role in EVV (e.g., service recipient, service provider, advocacy group)
- Organization/Company you represent (if applicable)
- Email address
Is the State still planning to have an open system and will MCOs be allowed to have their own EVV vendor to interface with the State system?
Yes, the State is proposing an open EVV system. Under this model, if an MCO has an existing EVV system, they may continue to use that system as long as it complies with The CURES Act requirements. MCOs will be required to send their EVV data to the State's data aggregator.
Are there any integration specifications/requirements for alternative EVV systems for State or aggregator submission?
Integration specifications/requirements will be made available once an EVV vendor is selected and onboarded.
Who will pay for the EVV fees? Will the State provide a system to use?
The State is proposing an open model EVV system. This allows providers with an existing system to continue to use their own and providers without an existing system to use the one procured by the State. The State procured system will be made available to providers without an existing system free of charge.
Will the EVV system replace the need for providers to submit monthly paperwork?
DHHS is still reviewing how the use of the EVV system will impact provider documentation requirements.
Will Choices for Independence (CFI) waiver Case Managers themselves also be required to use the EVV system?
At this time, there are no plans for CFI waiver case management visits to be validated via the EVV system.
Will the state require EVV for individuals who live with a caregiver, but receive hourly/episodic/intermittent personal care services?
Yes. Personal care services provided (and billed) on a unit or hourly basis are subject to EVV even when the individual lives with the caregiver.
How would services be entered when a child is cared for in the home, then at school, and then back at home again? Would sign in and out need to occur during the school time that might be covered under a separate entity versus the at home care?
Only services that are provided in the home require verification via EVV.
Are the services provided by Adult Day Programs one of the services being proposed for EVV?
No, adult day program services are not subject to EVV.
Are Supported Employment Services subject to EVV?
No, supported employment services are not subject to EVV.
Is EVV required for Participant Directed and Managed Services/Self-Directed Services?
If a service requires electronic visit validation, staff/providers providing the service must validate the service through an EVV system even if that service is self-directed through PDMS.
Are ABA (Applied Behavioral Analysis) services subject to EVV?
No, ABA services are not subject to EVV.
Will providers be subject to a penalty if the State does not implement EVV on time?
No, penalties will be applied at the State level.
When a Direct Support Professional (DSP) is visiting multiple different places at different times and providing services in different areas, will a log in with the required information need to be entered for each and every location in real time?
The Cures Act requires that the visits are validated at the beginning and at the end of each discrete visit.
What is the impact on the individual’s self-directed budget if the DSP incorrectly validates a visit? Will the individual’s budget be penalized?
The EVV system allows for services validated in error to be corrected. There would be no impact on the individual’s budget.
How will individuals or family members with visual impairments verify service delivery? Can visit verification be done via voice activation or TTY?
Information and requirements for individuals/family member validation of services delivered will be shared when the EVV system is implemented. EVV systems are required to be accessible to all users.
Will data collection begin on the EVV system implementation date or will a request for data for visits conducted in the past be made?
Data collection for visit validation will begin when the EVV system is implemented. Providers are encouraged to maintain appropriate backup documentation for billing purposes.
Will EVV devices track the whereabouts of the DSP and/or the individual using GPS?
A GPS enabled EVV device notes the location of service at the start of the visit and at the end of the visit only.
Who supplies the EVV device: the provider, the DSP, or the individual? What if the DSP doesn’t have an iPhone? Who pays for the device?
The State is considering various options for the provision of EVV devices.
Is there a backup plan for visit validation if there is no cell service or if a phone/tablet/computer doesn’t work?
Yes, the EVV system will include backup options for validating the visit.
Will training be provided on how to use the EVV system? How will the training be provided? Will there be a booklet or a pamphlet?
Yes. Training will be provided for providers, DSPs, individuals, and families. Training will be available online and via other modalities. Written materials will be provided as well.
EVV is guided by the following principles:
- New Hampshire’s approach to EVV will be consistent with federal law.
- EVV will be developed through a collaborative stakeholder process.
- EVV will be developed in a manner that respects recipients and providers, does not alter their Olmstead protections and is minimally burdensome.
- EVV will not change the number of service hours, nor how or where services are delivered.
- Existing information systems will be leveraged for EVV.
- Providers, recipients and other stakeholders will be trained on the use of the EVV system.
Which programs will be impacted by EVV in New Hampshire?
EVV will impact all personal care services and home health care services provided under the state plan and four Home and Community-Based Service (HCBS) waivers.
State plan personal care services and home health care services are predominately managed by the three NH Medicaid Care Management organizations. A small number of recipients still receive services under Medicaid Fee-for-Service, which are paid through the Medicaid Management Information System. Those stakeholders include:
- AmeriHealth Caritas New Hampshire
- New Hampshire Healthy Families
- Well Sense Health Plan
- Medicaid Management Information System – Conduent
The NH Division of Long Term Services and Supports administers personal care services and home health care services provided under Medicaid Home and Community-Based Service (HCBS) programs. Impacted HCBS programs include:
- Acquired Brain Disorder (ABD) Waiver
- Choices for Independence (CFI) Waiver
- Developmental Disabilities (DD) Waiver
- In Home Support (IHS) Waiver for Children with Developmental Disabilities
The NH Bureau of Improvement and Integrity – Program Integrity Unit is charged with monitoring financial claims for NH's Medicaid plan. The Program Integrity Unit will be responsible for monitoring EVV compliance.