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EVV Update: Deadline to Implement EVV for Personal Care Services Delayed until 2020
On July 30, 2018, legislation was passed to amend Section 1903(l) of the Social Security Act to delay the timeline for states to implement electronic visit verification (EVV) for personal care services by one year. The legislation does not affect timelines for home health care services. Previously, states were required to implement EVV for personal care services by January 1, 2019, or otherwise be subject to Federal Medical Assistance Percentage (FMAP) reductions as follows:
- 25 percentage points for calendar quarters in 2019,
- 25 percentage points for calendar quarters in 2020
- 5 percentage points for calendar quarters in 2021
- 75 percentage points for calendar quarters in 2022
- 1 percentage point for calendar quarters in 2023 and each year thereafter
Under the new timeline, states are required to implement EVV for personal care services by January 1, 2020, or otherwise be subject to FMAP reductions as follows:
- 25 percentage points for calendar quarters in 2020,
- 5 percentage points for calendar quarters in 2021
- 75 percentage points for calendar quarters in 2022,
- 1 percentage point for calendar quarters in 2023 and each year thereafter
States that have not implemented EVV by January 1, 2020 will be subject to FMAP reductions unless they have both made a “good faith effort” to comply and have encountered “unavoidable system delays.” States with good faith effort exemptions will not be subject to FMAP reductions in 2020, however will be subject to incremental FMAP reductions beginning with 0.5 percentage points for calendar quarters in 2021 if they have not implemented an EVV system by January 1, 2021. Please be advised that the provision on good faith effort exemptions does not provide CMS with authority to delay the FMAP reductions for more than one year.
CMS had previously indicated that it would accept requests for good faith efforts starting in July, 2018. However given the passage of this legislation, requests should be submitted to CMS in July, 2019. Please contact the CMS EVV mailbox at EVV@cms.hhs.gov for questions or concerns.
Please be advised that EVV resources published on Medicaid.gov prior to July 30, 2018 may reference dates that are impacted by this change.
Updated Social Security Administration Field Office Instructions Regarding Premium-Part A Enrollments for Individuals Who Wish to Apply for the Qualified Medicare Beneficiary Program
The Social Security Administration (SSA) has clarified its program instructions for field offices to process Medicare Part A enrollments for individuals who must pay a premium to enroll in Part A and who intend to apply for the Qualified Medicare Beneficiary (QMB) at the state Medicaid office. Additional information about the update can be found at the following link: http://policynet.ba.ssa.gov/poms.nsf/lnx/0600801140.
Background:
Although most Medicare beneficiaries qualify for “Premium-free Part A,” a minority lack the requisite work history and can only enroll in “Premium-Part A.” Many such individuals, however, cannot afford to pay the Medicare Part A premium (up to $422 each month in 2018) without assistance. Instead, states pay the Part A premium in addition to the Part B premium and Parts A and B cost-sharing for individuals who are enrolled in the Qualified Medicare Beneficiary Program (QMB). However, individuals must be enrolled in Part A in order to qualify for the QMB program. This creates an impossible predicament for low income individuals who are only eligible for Premium-Part A.
Currently, thirty-six states and D.C (Part A buy-in states) pay the Part A premium for QMBs under the terms of their Medicare buy-in agreements which can streamline processes and reduce costs for states and beneficiaries. The remaining 14 states (Group Payer states) use the group payer arrangement.
The Conditional Part A Enrollment Process in all States
The revised SSA instructions address inconsistencies and confusion among SSA field offices by clarifying existing SSA policy allowing individuals who lack Premium-free Part A and intend to apply for QMB, to “conditionally enroll” in Premium-Part A. The conditional enrollment process addresses the enrollment challenge for low income individuals without Premium-free Part A by allowing individuals to apply for Premium-Part A at SSA without paying the first month of premium on the condition that the state approves their QMB application and thus becomes liable for the Part A premium. With the conditional enrollment in Part A Medicare, individuals meet the eligibility criteria for the QMB program, enabling states to find them eligible for QMB and begin paying the Part A premiums. If the state denies the QMB application, the individual will not be enrolled in Premium-Part A.
The revised instructions specify that individuals who live in Part A buy-in states can enroll conditionally in Premium-Part A at any time while individuals who live in Group Payer states can only enroll in Medicare Premium Part A during a prescribed Medicare enrollment period.
When processing the conditional Part A enrollment, SSA will refer the individual to the appropriate state office to apply for the QMB program and may give the individual a screen shot of the application to bring to the state as proof of the conditional enrollment. The state can also query SSA’s State Verification & Exchange System (SVES) to verify the conditional Part A enrollment.
Additional Streamlined QMB Enrollment Procedures in Part A Buy-in States
In Part A buy-in states, the conditional Part A enrollment through SSA is applicable if individuals lack both Part A and Part B. If QMB applicants lack premium-free Part A, but are already enrolled in Part B (and otherwise eligible for QMB), the state must enroll them in QMB and refrain from referring him or her to SSA for conditional enrollment. Under the terms of the buy-in agreement, individuals enrolled in Part B should be treated as enrolled in Part A for the purposes of the QMB eligibility determination.
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