PA Asks Feds for Exemption to Delay Electronic Visit Verification Implementation

The 21st Century Cures Act (CURES) came into law in December 2016. A section of that law (12006), requires an Electronic Visit Verification (EVV) system to be used for Personal Assistance Services and Home Health Aide in Medicaid. EVV allows the individual providing service to record electronically the exact date, real start and end time, and location of a visit.

The law requires EVV to be in place by January 1, 2020 for Personal Assistance Services and 2023 for Home Health Services. Personal Assistance Services are provided through various PA Home and Community Based Waiver program. These services assist individuals with health conditions or disabilities with activities of daily living such as bathing, dressing, toileting and mobility.

Federal law allows states to have some discretion about the way EVV is implemented. PA Department of Human Services has held frequent public meetings this year to educate providers and consumers on how our state will implement EVV and the allowable options for providers/employers. In October, the state began a “soft launch” of the use of EVV for providers to gain familiarity with the process and allow the state and providers to work through kinks in the system so there was no disruption of payment for Personal Assistance Services in January. These services can be provided through a Home Health Care Agency or individuals can hire their own staff directly through a consumer driven model. In either case, the state wants to ensure timely payments to agencies and individuals without any delays.

Agencies had some discretion over what EVV system they used, and some were already using EVV. DHS contracted with Sandata and providers using alternate EVV systems must be able to interface with Sandata. Providers using alternate systems reported to DHS that the certification process with Sandata was taking longer than expected. As such, Pennsylvania has requested an extension from the Centers for Medicare and Medicaid Services (CMS) to allow additional time for these systems to go through the necessary testing with Sandata and become integrated to feed EVV data to the DHS aggregator.

If approved by CMS, the extension will allow DHS to extend the soft launch period and implement a tiered compliance structure before the denial of payments. Since the exemption has not yet been approved, providers are still required to begin using EVV by January 1, 2020. DHS expects a denial or approval from CMS by the end of this year.  DHS will update stakeholders on the Good Faith Effort Exemption request response from CMS once it is received.

All questions about EVV should be directed to the state’s resource account at