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 technology to capture point of service information related to the delivery of in-home services. EVV compliance 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 from a landline, fixed devices and biometric recognition.

In order to provide EVV services in the state of Missouri, all systems must verify the following:

  • Type of service performed (includes details specific to tasks for agency model and consumer directed services authorized by the Division of Senior and Disability Services (DSDS)),
  • Individual receiving the service,
  • Date of the service,
  • Location of service delivery when it begins and when it ends,
  • Individual providing the service, and
  • Time the service begins and ends.

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. Additionally, Missouri was approved for a Good Faith Effort Exemption, which allows additional time for implementation before withholding of federal funds occurs. The approval of the exemption does not postpone the State’s goal of implementation of EVV by all personal care service providers by January 1, 2020.

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.

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 services are not required to be verified electronically by DSDS regulation, but are included in the requirements of the CURES Act.

EVV is required to document delivery of the following services:

  • Advanced Personal Care
  • Chore
  • Consumer-Directed Personal Care
  • Homemaker
  • In-Home Respite authorized by the Division of Senior and Disability Services (DSDS)
  • Personal Care
  • Any of the above services reimbursed by a Managed Care Organization

EVV is NOT required for the following services:

  • PCS delivered in a facility where assistance is available 24 hours per day, such as a Residential Care Facility or an Assisted Living Facility
  • Respite services authorized by the Division of Developmental Disabilities

Additionally, in order to be in compliance, Home Health Care Service 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:

  • Improved health and welfare of individuals through validation of delivery of services according to their personal plan and increased ability to monitor service delivery;
  • 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; and
  • More robust data collection and analysis capabilities.

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 service 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 solution to compile all data and present it in a standardized format for review and analysis. Use of the aggregator solution 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 EVV vendor funds the cost of the interface. 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 will be at risk of losing their contract with Missouri Medicaid Audit and Compliance (MMAC).

The MO HealthNet Division is seeking enhanced federal funding for the EVV Aggregator Solution. The proposal is in the review process with an anticipated release date of January 2020. 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 their EVV system collects all information required by the CURES Act and meets the minimum standards as defined by the State;
  • 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.