EVV Frequently Asked Questions

What services should be tracked by the EVV system? If the service falls under the definition of hands-on direct care in the member's plan of service, then it is covered.
Does documenting on paper count as capturing services rendered? Recording information on paper is not an acceptable form of visit documentation under the CURES Act.
Would an attestion by the provider stating where the services are provided be sufficient? CMS categorizes this as replacing an EVV system. As there is no substitute for an EVV system, an attestation is not acceptable.
How, when and what process will CMS use to waive the CURES Act? CMS does not have the authority to waive a Congressional Act.
What level of EVV monitoring is expected, sample or 100% monitoring? All services that are hands-on direct care related should be monitored and the six elements should be reviewed for all rendered hands-on direct care services. The six elements that should be reviewed are as follows:
Type of service performed
Individual receiving the service
Date of the service
Location of service delivery
Individual providing the service
Time the service begins and ends
Does CMS have any recommendations to address global positionial system (GPS) tracking issues? The CURES Act does not require ongoing tracking during the transportaiton portion of the visit. The expectation is that there should be check-ins at different locations, if possible, as long as services provided are in the line with the service plan.
Has CMS heard of any security concerns from any states that have already implemented an EVV system? One state mentioned that individual and family members that received services had expressed concern and confusion around privacy and confidentiality with having the device in their home. Through training, it can be explained that the EVV systems must be Health Insurance Portability and Accountability Act (HIPAA) compliant, have role-based access, password protection, ability to wipe data remotely, etc.
Is EVV required for services if hands-on direct care is only a small part of a larger service? Private Duty Nursing is not included at this time. Anything that includes ADL, IADL, trasportation, etc., would be included. There is nothing that says the State cannot expand beyond hands-on direct care.