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,
  • 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 Home Health Care Service providers by January 1, 2023. 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 home health care service providers by October 31, 2023.

EVV is required to document delivery of the following home health care services:

  • Nursing (RN/LPN/etc.)
  • Occupational Therapy
  • Physical Therapy
  • Personal Care Aide
  • Speech Therapy
  • Any of the above services reimbursed by a Managed Care Organization

What Are the Benefits of EVV?

There are numerous benefits of EVV utilization, including but not 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 has established technology requirements for all EVV systems and acquired 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 allows 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. 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 or HHCS 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).

How Can HHCS 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 staff to verify consistent use of EVV for all HHCS recipients; and
  • Encourage all recipients of Medicaid funded HHCS 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.