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 originally required use of an EVV system by all PCS providers by January 1, 2019. In July, 2018 a Congressional bill was signed to extend the deadline for PCS providers to January 1, 2020. EVV is NOT required for PCS delivered in a facility where assistance is available 24 hours per day, such as a Residential Care Facility or Assisted Living Facility.

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 for all providers delivering DSDS services. 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. These providers were not required to use EVV by DSDS regulation, but are included in the requirements of the CURES Act.

Additionally, in order to be in compliance, HHCS providers are required to implement EVV by January 1, 2023 for services delivered under the Medicaid program. Providers delivering these services will be required to acquire and utilize an EVV vendor by the deadline.

What Are the Benefits of EVV?

There are numerous benefits of EVV utilization, including but limited to:

  • Reduction in the potential for fraud, waste and abuse by ensuring appropriate payment based on actual service delivery and by identification of duplicated or authorized services;
  • Elimination of paper documents to verify services;
  • Enhanced efficiency and transparency of services provided to individuals with increased accountability of provider agencies and direct care workers;
  • Improved health and welfare of individuals through validation of delivery of services according to their personal plan and increased ability to monitor service delivery; and
  • Allow for more robust data collection and analysis.

What is Missouri Doing?

There are multiple EVV designs that meet the requirements of the CURES Act. States are allowed to select the design which best meets the current needs of the state, the providers and the service recipients.

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. Following full implementation of the aggregator solution, state staff as well as designated staff from the PCS and HHCS provider agencies will have access to specific information related to service delivery from the aggregator system.

All EVV systems utilized in the state will be required to meet the technology requirements for the interface with the aggregator system. Upon selection of an aggregator solution and definition of interface requirements, details will be distributed as well as 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 of data collection or exchange with the aggregator, they will not be considered an acceptable EVV vendor and the provider will be required to select another EVV vendor to be in compliance with the CURES Act. Any provider of Medicaid funded PCS who is determined to be out of compliance with EVV requirements 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 with decisions being made regarding the identification of the most appropriate aggregator vendor. This website will be updated as more information becomes available.

How Can PCS Providers Prepare for Implementation of EVV?

Providers who have an existing agreement with an EVV vendor should:

  • Ensure the EVV system collects all information required by the CURES Act;
  • Monitor PCS aides/attendants to verify consistent use of EVV for all PCS recipients; and
  • Encourage all recipients of Medicaid funded PCS to use EVV, explaining the risk of losing service eligibility if EVV is refused.

Providers with no current EVV vendor agreement should identify and contract with an EVV vendor as soon as possible, ensuring the vendor of choice collects all required information.