Why Eliminating GPS from EVV Could Cost Millions, Force ‘Massive’ Step Backward

The electronic visit verification (EVV) implementation process could hit a significant roadblock this summer if a Congressional bill that eliminates the use of GPS is passed by federal lawmakers.

The next iteration of the landmark 21st Century Cures Act would not allow EVV systems to use GPS in order to protect privacy. If the bill passes as written, millions of dollars already invested by home health providers and state governments are at risk of being wasted.

Industry insiders told Home Health Care News this week that although the majority of Cures 2.0 is solid – and improves much of what the original Cures Act intended – there is one line in the bill that many have taken issue with.


The bill includes a provision that “prohibits the use of geographic tracking features and biometrics within EVV systems.” Co-sponsored and lead by Rep. Diana DeGette (D-Colo.), the bill has opposition from associations such as National Association of Medicaid Directors, the National Association of State Directors of Developmental Disabilities Services and the Partnership for Medicaid Home-Based Care.

Broadly, EVV applies to Medicaid-reimbursed home care providers. It requires them to electronically verify the services they deliver. The caregivers and clinicians are responsible for recording data points like the date, time, location and type of services being provided.

Advocates in the disability community are arguing that mandating the use of GPS in EVV is against the privacy rights of people with disabilities, an insider told HHCN.


ADvancing States, a national organization that provides leadership and guidance to state aging and disability agencies, also opposes the bill’s anti-GPS provision.

It all comes down to privacy, Damon Terzaghi, the senior director of long-term services and supports policy for ADvancing States, told HHCN.

“We as a culture have made some value-based judgments that we’re willing to sacrifice some of our privacy for the convenience of our cell phone telling us what products or services that we like are nearby,” Terzaghi said. “We have the option to turn off GPS or not use our phones if we so decide. The argument they would make — which I don’t necessarily disagree with — is by virtue of having a disability, they’re being told that you don’t have this option, that you must accept to be tracked in order to receive services that, in many cases, are necessary for them to live.”

EVV implementation did not get off to a great start once Cures was passed. Larger providers and some states were able to hit the ground running, but most states and smaller providers followed slowly behind. The COVID-19 pandemic didn’t help the situation, but by now, providers all across the country have started to invest and make the transition to implement EVV.

The U.S. Centers for Medicare & Medicaid Services (CMS) played a large part in GPS being a part of EVV.

“[The guidance] essentially made states use GPS in their systems,” Terzaghi said. “States that tried to devise other ways to address the location issue without GPS were essentially told that that’s not verification of location, and so every single state that has implemented EVV has GPS as part of its system.”

Financial fallout

One of EVV’s primary goals is to stop fraud, waste and abuse in home-based care. Following the Cures Act, EVV is now necessary for states to unlock their full share of federal funding.

Under the Cures Act, states are required to use EVV for all Medicaid-funded home health services by Jan. 1, 2023. Those who don’t may not get their full federal match.

If GPS is cut from EVV as a whole, providers will likely feel like a rug was pulled out from underneath them.

Andrew Kaboff, chief revenue officer for the EVV technology company CellTrak, detailed a hypothetical.

“Let’s just say right now 50 states have enacted some type of technology, and those states have signed contracts with organizations to provide services,” Kaboff said. “Let’s say those contracts represent at least $5 million in value each. That’s a quarter of a billion dollars that the federal government has now, in essence, committed to pay for. That doesn’t take into consideration all the organizations or home care agencies that have put technology in place to manage a decentralized workforce with GPS, who have spent tens – if not hundreds – of million dollars [to get ready for this EVV implementation].”

Kaboff said this change would be a massive step backward. It would be the federal government reversing course and taking away a state’s ability to make the decision on how to implement EVV.

“We have multiple layers of expenses,” Terzaghi said. “We have expenses at the state level to redesign the systems, and then we have expenses at the provider level because a number of providers decided to use their own systems, so they would then have to change all of their verification methods to be compliant with this. We’re talking millions and billions of dollars across the country, right?”

What happens next

Like many in the industry, Terzaghi and his colleagues are fighting for the status quo as opposed to the anti-GPS provision.

But a solution other than striking the ant-GPS provision is hard to come by, industry experts told HHCN.

Cures 2.0 has not received a CBO grade in Washington as of Wednesday afternoon. It could be weeks before it’s voted on, but states and home health providers should keep their eye on it as it moves through Congress.

“At a macro level, it’s extremely concerning,” Terzaghi said. “I would say that the banning of GPS would eliminate any savings that may have been realized by the original EVV policy by essentially forcing states to completely scrap their systems and rebuild them from scratch.”

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