On December 13, 2016, the 21st Century CURES Act (114 U.S.C 255) was signed into legislation. The CURES Act is designed to improve the quality of care provided to individuals through further research, enhance quality control, and strengthen mental health parity. A portion of the bill (Section 12006) requires EVV to be used for all Personal Care Services (PCS) and Home Health Care Services (HHCS) delivered under the Medicaid program.

EVV is a method of utilizing electronic technology to capture point of service information related to the delivery of in-home services. The EVV system must verify the following:

  • Type of service performed,
  • Individual receiving the service,
  • Date of the service,
  • Location of service delivery,
  • Individual providing the service, and
  • Time the service begins and ends.

This can be achieved in a variety of manners, including but not limited to, the use of mobile applications with Global Positioning System (GPS) capabilities, telephony, fixed devices, and biometric recognition.

What Services Require the Use of EVV?

The CURES Act requires use of an EVV system by all PCS providers by January 1, 2019 and all HHCS providers by January 1, 2023. This encompasses services delivered to a wide variety of populations.

The Department of Health and Senior Services (DHSS), Division of Senior and Disability Services (DSDS) promulgated a regulation  requiring use of telephony or other suitable EVV effective February, 2016. As a result, the majority of providers of PCS are currently utilizing electronic means of visit verification. Information regarding the EVV regulation is included on the DHSS website in PM/VM -16-17. Additionally, DSDS has made available a list of frequently asked questions (FAQs) related to EVV requirements.

Note: The requirements set forth by DSDS do not meet all needs of the CURES Act, and not all responses contained in the FAQs are consistent with the upcoming mandates. A new regulation to meet all requirements outlined in the CURES Act is being drafted at this time. Until the new regulation is in place, current DSDS regulation continues to be in effect.

In addition to the services authorized by DSDS, PCS authorized by the Bureau of Special Health Care Needs and the Bureau of HIV, STD and Hepatitis of DHSS and those authorized by the Department of Mental Health (DMH), Division of Developmental Disabilities (DD) must be verified through use of an electronic system in order to comply with the CURES Act. HHCS delivered under the Medicaid program will also require use of EVV. Providers delivering these services will be required to acquire an EVV vendor.

What is Missouri Doing?

There are multiple EVV designs that meet the requirements of the CURES Act:

  • Provider choice model allows providers to select the EVV vendor of their choice and self-fund implementation;
  • State mandated external vendor model in which the state contracts with one EVV vendor that all providers must use;
  • State mandated in house model in which the state creates and manages an EVV system that all providers must use; and
  • Open vendor model in which the state aggregates EVV data from third party vendors selected by providers.

In order to comply with the CURES Act, the Missouri Department of Social Services (DSS), MO HealthNet Division (MHD) has opted to pursue an open vendor model, allowing providers of PCS and HHCS to select the EVV vendor which best suits their needs, or to continue to utilize their existing system. The implementation of the EVV vendor will not be funded by MHD monies.

The state will establish technology requirements for all EVV systems and acquire a vendor neutral aggregator system to compile all data and present it in a standardized format for review and analysis. Use of the aggregator system will allow the state to maintain quality oversight while providing flexibility in vendor selection by PCS and HHCS providers.

All EVV systems utilized in the state by providers will be required to meet the technology requirements for the interface with the aggregator system. As soon as these requirements are defined, they will be available on this site. The cost of the interface is funded by the EVV vendor and is expected to be a one-time per vendor expense. If an EVV vendor is not able to meet the requirements, they will not be considered an acceptable EVV vendor and the provider will be required to select another EVV vendor to meet their needs and to be in compliance with the CURES Act. Any provider of Medicaid funded PCS who is determined to be out of compliance following implementation of the aggregator system will be at risk of losing their contract with Missouri Medicaid Audit and Compliance (MMAC).

The MO HealthNet Division is currently in the planning stages of the EVV Aggregator Solution project. Research is being conducted and information gathered to prepare a request and begin the process of identifying the most appropriate aggregator vendor. This website will be updated as more information becomes available.