The Department of Health has significantly amended and updated the Electronic Visit Verification (EVV) Program Guidelines and Requirements (the “Guideline”). Critically, the Guideline now includes minimum training requirements that provider agencies and fiscal intermediaries must adhere to when training their EVV system staff and caregivers. Providers must meet the requirements by August 1, 2021. Here, we outline the EVV training requirements.
First, the Guideline confirms that all covered providers and fiscal intermediaries must provide training to their caregivers, agency staff and EVV system users that are submitting EVV data to the State Department of Health. Training may be delivered in any format, including instructor-led, webinars and self-service online training.
All providers and fiscal intermediaries must maintain documentation of the training, including a list of caregivers and staff users of the system, and
- training that caregivers and staff users of the system have received,
- training materials and content,
- the date(s) the individual attended training,
- the format of the training (e.g., in person, online, etc.) and
- the date training was successfully completed.
All providers and fiscal intermediaries must ensure to document in the member’s service plan that the Medicaid member has seen and understands the Department’s Fact Sheet What You Should Know About Electronic Visit Verification (EVV).
All providers and fiscal intermediaries who are required to submit EVV data must have an EVV Attestation, which includes attesting to having provided training, on file with the Department.
All providers and fiscal intermediaries, data submitters, and caregivers must be familiar with NYS EVV Website, including where to send questions regarding EVV: EVVHelp@Health.NY.Gov The Guideline states that all providers and fiscal intermediaries, data submitters, and caregivers should read and be knowledgeable with the policies in the Program Guidelines and Requirements document.
All EVV trainings must include the EVV stipulations of the 21st Cures Act, including where these “stipulations” can be found on the Department’s EVV Website:
- What is EVV
- What Data Fields are required to submit complete EVV data
- Start date for EVV for PCS services
- Services that require EVV data collection
The Guideline states that providers’ EVV System Training Requirements for Caregivers should include:
- Provider’s System Overview and Workflows (non-technical)
- How to electronically collect EVV data using the Providers system and device(s)
- How to and when to collect EVV data manually and what to document
- How to document Live-in caregiver information
- How to electronically collect EVV data when there are multiple caregivers
- How to electronically collect EVV data when there are multiple beneficiaries
- How to send data to Provider’s System
- What information to share with Medicaid beneficiaries and their families about EVV
As a reminder, EVV is mandatory. Providers who are still using only timesheets to track and record personal care services run the risk of significant penalties and recoupment action, including being required to pay back all their collected billings that are not EVV-supported to OMIG and/or their MLTCs. Contrary to common misconception, EVV applies to LHCSAs and fiscal intermediaries. There are some exceptions to the EVV requirements, but they are few. Thus, responsible providers should make sure to understand their EVV obligations.
Please reach out to us if you have any questions regarding EVV requirements.