On April 23rd, NASUAD submitted a letter to CMS seeking further clarification on the 21st Century CURES Act requirements for state Medicaid agencies to implement Electronic Visit Verification (EVV) for certain services. NASUAD wishes to communicate the concerns of the states and territories regarding their ability to implement EVV for personal care services (PCS) by January 1, 2019. In this letter, NASUAD emphasizes the challenges that states face due to the lack of formal guidance regarding a number of issues relevant to EVV implementation, including the definition of PCS subject to the requirements as well as ambiguity around the nature of information that should be collected by the EVV system.
As a result of these concerns, NASUAD strongly encourages CMS to release guidance as expeditiously as possible with the following clarifications: (1) Provide clear definitions on the PCS included within the EVV mandate, and clarify that licensed residential settings such as assisted living and group homes are not subject to the requirements; and (2) Establish a liberal definition for the good faith exemption given that states do not yet have CMS guidance to use for their system development.
Click here to read the letter.