NH Medicaid is unlikely to meet the Electronic Visit Verification (EVV) timeline established by the 20th Century Cures Act. The Act requires that states implement an EVV for Medicaid personal care services and home health services. The Act originally required states to launch EVV in 2019 for PCS and 2022 for home health. Last year, Congress delayed EVV to 2020 and 2023, respectively.
Based on information in documents related to a Request for Proposal (RFP) for an EVV consultant, NH will likely need to submit “good faith waiver” to CMS to delay implementation. The RFP, which was issued on March 12, seeks a consultant to analyze business and technical systems, conduct interviews, research EVV technology and define the requirements for the actual EVV system RFP. The deadline to submit a proposal was May 2, with the consultant to begin in July. However, a contract has yet to be submitted to Governor and Council for approval. DHHS now expects the consultant to begin in September and complete the EVV Plan in December. March 2020 is the target date to issue an RFP for an EVV developer. These are ambitious targets. A good faith waiver from CMS will allow NH Medicaid to delay EVV system launch for personal care services to January 2021. However, CMS has no authority to waive penalties beyond one year. If NH isn’t ready by 2021, NH’s federal Medicaid matching funds (FMAP) will be reduced incrementally by .25% each quarter in the first year, and more in subsequent years.