CMS Moves Step Closer to Required EVV Survey

Federal health care policymakers have taken another step toward rolling out a required nationwide electronic visit verification (EVV) survey.

The 21st Century Cures Act originally required home care providers and state agencies to begin adopting EVV systems by Jan. 1, 2019. EVV requirements are meant to reduce instances of fraud and abuse in the delivery of home-based care through the use of approved mobile applications that verify whether services were delivered on time, in full and in an appropriate fashion.

Bipartisan legislation signed by President Donald Trump in July pushed that deadline back to the start of 2020, however.


The deadline for Medicaid-funded home health care services is Jan. 1, 2023.

The Centers for Medicare & Medicaid Services (CMS) notified at-home care stakeholders on Thursday it has taken into account industry feedback and refined its proposed EVV survey planned for November of this year. CMS first hinted at a required EVV survey in October.

The electronic, web-based survey is for states to self-report their progress in implementing EVV for personal care and home health care services, according to CMS officials. Moving forward, CMS plans to use the survey data to assess EVV compliance and levy Federal Medical Assistance Percentage (FMAP) reductions when necessary.


A state is subject to incremental FMAP reductions up to 1% unless it has both made a “good faith effort” to comply with EVV requirements and has encountered “unavoidable delays.”

“There is often a serious lack of broadband and internet in rural areas,” an independent living specialist in Montana wrote to CMS during a comment period after the EVV survey was first proposed. “I have concerns about the fact CMS is asking states to implement EVV at a time when many states have waiting lists or have cut home- and community-based services.”

CMS will stop the possible survey — distributed to all 51 state Medicaid agencies plus Washington, D.C., and Medicaid agencies in five U.S. territories — when all states have fully implemented EVV systems. The survey will take live form, meaning states will be able to update their compliance status on a continuous basis. As FMAP reductions are assigned, states that are not in compliance will be asked to review their survey information on a quarterly basis to ensure it is up-to-date and modify their survey responses as needed.

The Consortium for Citizens with Disabilities — a Washington, D.C.-based advocacy organization focused on public policy related to adults and children with disabilities — is arguing that CMS’s proposed EVV survey does not do enough in terms of gauging progress in its current form.

“The [EVV survey], as proposed, does not accurately measure compliance with these important requirements,” representatives from the advocacy organization commented to CMS. “Instead, the proposed survey only asks states to certify general compliance and to include a description of their program.”

To ensure that EVV is “minimally burdensome,” protects privacy and does not inhibit community integration, more specific questions should be included in the compliance survey, the representatives noted.

The current public comment window for the proposed EVV survey closes on March 18.

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