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Section 12006(a) of the 21st Century Cures Act mandates that State Medicaid agencies implement an Electronic Visit Verification (EVV) system for select Home and Community Based Services (HCBS) and State Plan services that require an in-home visit by a provider. States that do not implement EVV will incur a reduction of Federal funding.
EVV is a system which electronically verifies that home or community-based service visits occur by documenting six points of data:
An EVV solution may include multiple point-of-care visit verification technologies, such as mobile phone application, telephonic, and web-portal.
The Department has received a Good Faith Effort Exemption from the Centers for Medicare and Medicaid Services (CMS), allowing the implementation of EVV for all Colorado required services to be delayed as late as January 1, 2021. The Department intends to mandate the use of EVV for all affected providers by late summer 2020.
The 21st Century Cures Act mandates that states implement EVV for Personal Care and Home Health services. Colorado implementation will require EVV for required services and additional services that are similar in nature and service delivery. Services types that require EVV include:
A detailed list of services, including procedure and revenue codes, that require EVV in Colorado can be found on our EVV Website under Resources, listed as "EVV Types of Service - Service Code Inclusions."
Technical guidance provided by the Centers for Medicare and Medicaid Services (CMS) clarified that the Cures Act requires EVV for services outside of Personal Care and Home Health. When service provision is permitted to be in a member’s home, CMS indicated that services covered under the Home Health authority, except DME, and HCBS services which include an element of Personal Care are also mandated. The Department has also included services that are similar in nature and service delivery to mandated services. This ensures services are delivered to our members and streamlines requirements for providers.
Colorado’s EVV system went live October 1, 2019 and providers could begin using the State EVV Solution or a Provider Choice system at that time. Use of EVV is currently voluntary and may be used at provider agency discretion. The Department intends to mandate the use of EVV in last summer 2020. Until is mandated, implementation is in a Soft-Launch period. The Department strongly encourages providers and caregivers to participate in EVV at this time. The Soft-Launch is an opportunity to become familiar with EVV prior to claims integration, test and interface Provider Choice systems, inform policy and system changes, and help the Department identify and develop supplemental training materials. During the Soft-Launch, the Department will outreach providers for technical assistance needs. Once EVV is mandated by Colorado Code of Regulations, the use of EVV will be required and claims without corresponding EVV are subject to denial or recoupment.
Combining implementation streamlines service delivery for members, mitigates confusion among providers who deliver multiple services requiring EVV, alleviates duplicative training requirements, reduces systems costs for providers who employ their own EVV solution, and effectively utilizes Department resources.
The Department intends to mandate the use of EVV in late summer 2020. Claims will be impacted by EVV no earlier than when the mandate is in effect and no later than January 1, 2021. This timeline has been extended from January 1, 2020 to allow for an extended Soft-Launch, so stakeholders are comfortable using EVV prior to claims integration. Prior to claims integration, the Department will provide outreach to agencies who are not using EVV correctly and risk denied claims in the future.
Yes, Home Health agencies must submit EVV if providing any of the services listed on our EVV Website under Resources, listed as "EVV Types of Service - Service Code Inclusions."
Yes, both Consumer Directed Attendant Support Services (CDASS) and In-Home Services and Supports (IHSS) are required to comply with the EVV mandate.
Provider-owned residential services, such as Assisted Living Facilities, Alternative Care Facilities, Host Homes, and Nursing Facilities, do not require EVV. Please note that Hospice services will require EVV in all locations, including Nursing Facilities, that utilize the Type of Bill range 811-815.
EVV appropriate services provided via Telemedicine must collect EVV unless provided in a setting that is exempt from EVV services. For example: Behavioral Consultation in an office (Place of Service 11).
To ensure a minimally burdensome EVV implementation, the Department released communication in July 2019 that Durable Medical Equipment (DME) providers will have a delayed launch. DME providers will be able to register for EVV training by no later than April 1, 2020 and will be required to use EVV for mandated services upon the passage of the Colorado Code of Regulations EVV Rule. With this delay, DME providers will still have the opportunity for a "Soft-Launch" where claims will not be impacted. The decision to delay the EVV requirement for DME is due to programmatic challenges and breadth of program size. EVV will only be required for services listed in the EVV Website under Resources, listed as "EVV Types of Service - Service Code Inclusions."
Respite services require the use of EVV when listed in the “EVV Types of Service – Service Code Inclusions,” found on the EVV Website in the Resources section.
Behavioral Therapies require the use of EVV when listed in the “EVV Types of Service – Service Code Inclusions,” found on the EVV Website in the Resources section. Services not specifically listed in this inclusion list are covered through the Regional Accountable Entities (RAEs) and are not subject to EVV.
The Department does not require that live-in caregivers use EVV. An informational bulletin released by CMS permits states to exempt live-in caregivers from EVV, if the state chooses. The Department is delaying the implementation of EVV for the purpose of operationalizing an exemption for live-in caregivers. Individual providers are permitted to require EVV for live-in caregivers employed by the agency, if they choose.
Federal guidance permits states to exempt live-in caregivers from EVV. Colorado will not require that live-in caregivers complete EVV. This exemption may or may not apply to the parent of the member, depending on living arrangement. If a parent is not a live-in caregiver for the member receiving care, they will need to complete EVV entries for the member.
Yes. The Department requires EVV for all mandated services, regardless if the service occurs in the home or in the community. Most services that require EVV in Colorado, may be provided in the home or community. Billing procedure and revenue codes processed through the State’s MMIS system (DXC interChange), do not differentiate location of service delivery. Requiring EVV for services provided in the home and the community encourages fluid service delivery and avoids significant changes in service design. The Department is also committed to assuring that services may be delivered without pre-determined locations, preventing barriers to service delivery.
The purpose of the State EVV Solution is to meet the EVV mandate as outlined by the 21st Century Cures Act and is not intended to fulfill CDPHE certification or survey requirements. The Department recommends providers continue current practice for fulfilling CDPHE requirements. The Department does not prohibit providers from using a Provider Choice EVV Solution that incorporates electronic recording of survey or compliance requirements while also collecting and submitting EVV data.
The State EVV Solution will utilize two primary technologies for capturing visit information at the service location:
The state will also employ web-based functionality for use by provider agencies.
No. EVV implementation in Colorado will not require a microphone, photographic, or video recording, nor does the Department authorize individual agencies to require the use of such devices.
Services will be verified through the State EVV System by using an application on a mobile phone or tablet, telephone call, or Sandata web-portal. The direct care worker should bring required technology into the member’s home for verification and take it with them when they leave. Provider Choice system may use different technology than the State EVV Solution. Members are encouraged to contact their agency for details.
iPhone users: the application is best viewed on an iPhone 6 and higher, running Minimum iOS version 9.0.
Android users: the application is best viewed on an Android device using Android OS 7.0 (Nougat) or higher, with a minimum OS of Android 5.0 (Lollipop).
For MVV in the State EVV Solution, each clock-in and clock-out uses roughly the same amount of data as a text message.
Visits will merge automatically if the same direct care worker enters both ends of the service.
No, EVV does not require members to obtain a home landline or cell phone. Verification of service through EVV is the responsibility of the provider agency. Technology necessary for EVV should be supplied by the provider or direct care worker. A member may approve of the caregiver using their personal landline or cell phone for EVV, but it is not required. If a provider encountering a field within the State EVV Solution that requires a member phone number and no member number is available, providers may enter (999) 999-9999.
Technical specifications for Provider Choice systems can be found on the EVV Provider Choice Systems Website. The Department will maintain a list of vendor software versions already integrated with the State EVV Solution for reference. The Department will not certify any specific EVV vendor beyond operability and successful data transmission.
Data submitted through the State EVV Solution will be stored in the Sandata system and transmitted to both the State’s MMIS (DXC interChange) and Business Intelligence Data Management (BIDM) system. This is the industry standard and complies with federal privacy and security practices.
GPS is not required. In the State EVV Solution, the mobile application uses GPS but the telephone option does not. The location formats the EVV State Solution will accept are street addresses, GPS coordinates, or a uniquely identifiable public landmark.
The State EVV Solution will accept GPS coordinates, street address, or uniquely identifiable landmark.
The Cures Act does not require states to capture continuous location as a member moves throughout the community; the Colorado EVV program will collect location at the time of clock-in and time of clock-out for each service delivered. For the State EVV Solution, location will be captured via GPS when MVV is used and through Automatic Number Identification (ANI) technology for TVV.
The Address Confidentiality Program (ACP) provides a confidential address and telephone number that may be used instead of actual locations for the provision of services in Colorado. Participation in ACP does not exempt providers from using EVV; guidance for accommodating ACP during the Soft-Launch may be found on the EVV Website under Resources. Further guidance will be issued at a later date.
EVV data is stored on secure servers that are managed and maintained by Sandata, DXC, and IBM. The Department’s contracted vendors are responsible for ensuring the data meets state cyber security and Health Insurance Portability and Accountability Act (HIPAA) requirements.
The Department has opted to not verify a service location against a member’s home or other pre-determined location.
The State EVV Solution is designed to work across the state. The MVV application will work without cellular service and can upload information when service is restored or connected to Wi-Fi when re-opening the application. The TVV option is also available in rural areas when a cell phone or landline is available. In situations where MVV and TVV are both unavailable, a provider may complete EVV requirements through the Sandata provider portal. Please note that manual entries are subject to increased scrutiny by the Department.
Within the State EVV Solution, the client phone number will be entered in the EVV provider portal by the agency provider. The system will be able to cross reference which member is associated with which phone number.
No. The EVV State Solution does not require or have the capability for photo submission for service verification. The Department does not permit or condone the use of photos for service verification in Provider Choice systems and will not accept any photos.
With the implementation of EVV, billing practices within the DXC provider portal will remain the same. Once EVV is mandated, EVV required services billed to the Department will require corresponding EVV data. An EVV record does not bill the Department. Administrative staff will be able to review EVV data, if necessary, before submitting billing claims.
CMS guidance indicates that states must implement thresholds for manually entered and edited EVV. The Department has not yet established these thresholds or how claims may be impacted if exceeded. Additional information will be released prior to the EVV mandate.
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The direct care worker is still responsible for reporting the visit. Visit activity already recorded will be saved for when the phone regains power. If the visit is still in progress when the phone regains power, it is possible that EVV can be recorded correctly. If the visit is unable to be accurately recorded, the agency administrator may fix visit data within the Sandata provider portal. Please note, manually entered visits are subject to Department audit.
Services will not be impacted by a direct care worker’s lost device. The provider agency will be able to complete manual entry through the web portal and any EVV data remaining on the device is encrypted. Within the State EVV Solution, direct care workers must log into the Sandata application each time it is used for EVV, preventing unauthorized access to sensitive member data.
Compliance with EVV requirements is the responsibility of the provider agency. To prepare for EVV implementation, providers should learn about EVV requirements, decide whether they will utilize the State EVV Solution or a provider choice EVV system, and complete mandatory training.
In addition, the Department recommends that provider agencies:
In most situations, compliance with EVV requirements is the responsibility of the provider agency. The impact to most members will be minimal and no preparation is needed. However, if a member utilizes CDASS, preparation will be necessary. CDASS members/authorized representatives employ the direct care worker, and as an employer will need to learn about EVV requirements and complete training offered by their selected Financial Management Services (FMS) vendor. Additional details for CDASS members will be communicated by FMS vendors.
As a condition of the Provider Agreement, providers must comply with all state and federal ADA laws. The State EVV Solution is WCAG 2.0 certified.
Yes. The implementation of EVV does not change the format or location of service delivery. Individuals will continue to receive services in accordance with their service plan and existing program rules.
The member’s emergency care comes first. A visit can be manually entered or edited by the agency administrator in the provider portal if EVV was not able to be captured at time of visit.
The caregiver is responsible for reporting EVV appropriate care when delivered. An unscheduled visit can be captured through State EVV Solution mobile or telephone visit verification.
If there are two clients in the same home, the attendant will choose which client they are providing services to. If the service pertains to both, the attendant will be able to clock in separately for each individual or provide a group service, if appropriate.
The Department EVV vendor, Sandata, provides a one-time bulk upload option of members and direct care workers for provider agencies that have more than 80 members. The upload of member and direct care worker information into the State EVV Solution and the Scheduling Module does not require dual entry and may be completed in one step. Members and direct care workers that are uploaded outside of this one-time bulk upload will be entered by the provider agency.
Please call or email the Sandata support center for this upload.
Within the State EVV Solution, an agency administrator may complete visit maintenance within the Sandata Provider Portal. The administrator will enter the missing data and select a reason code on why a manual entry was done. Manual entry may be entered on a case by case basis. Please note, that these entries are subject to increased scrutiny by the Department.
Clocking-in and clocking-out will require less than one-minute for MVV or TVV within the State EVV Solution. Users have reported the MVV solution is slightly quicker.
No. EVV service groupings were created for caregiver ease of use when clocking-in and clocking-out for EVV. The Department maintains a crosswalk of all individual billing codes to the EVV service groupings, assuring that a grouped service codes are matched with an individual service submitted on a claim.
Yes. This allows for information sent to the interChange from the Data Aggregator to be the same across any system a provider may choose.
The Department does not intend for the implementation of EVV to impact current billing rules. Providers that span bill or bill for more than one service per day should continue with current practices.
The State EVV Solution can record multiple visits to a member per day. Each direct care worker has their own unique identifier and EVV records created by that identifier are direct care worker specific. The State EVV Solution does not limit the number of services a member can receive in one day.
The Department has dedicated User Acceptance Testing (UAT) professionals to test scenarios ensuring the State EVV Solution functions based on business requirements.
The Department also developed opportunities for stakeholders to participate in the UAT process and provide feedback on specific scenarios that they would like to see tested. The UAT process for the State EVV Solution concluded in October 2019.
Yes. The Department will allow all providers the opportunity to work within the State EVV Solution or connect a Provider Choice system to the State Solution before EVV is required for claims processing. The Department refers to the time between when the system is available to providers and when EVV is required for claims processing as the Soft-Launch. The Soft-Launch ensures that providers and direct care workers understand how to correctly use EVV and that providers who use their own EVV solutions have time to configure their systems to be fully operational EVV is mandated. The Department strongly recommends that all providers participate in the Soft-Launch. Technical assistance will be available to providers during the Soft-Launch.
Colorado is implementing EVV through a hybrid approach. The Department will implement and maintain a State EVV Solution that providers may utilize at no cost. A provider may instead choose to implement and utilize the EVV system of their choice. A provider choice EVV system must meet Cures Act requirements and successfully integrate with the State EVV Solution for data transfer.
While providers may utilize the State EVV Solution free of charge, costs associated with purchasing and maintaining a provider choice system are the responsibility of the provider. There will be no fee to providers for connecting or transmitting data to the State EVV Solution.
Colorado is implementing EVV through a hybrid approach, meaning that agencies may use the State EVV Solution or different EVV solution of their choice. If an agency chooses to use a Provider Choice system, the solution must meet Cures Act requirements and successfully integrate with the State EVV Solution for data transfer. It is possible that an existing EHR may meet these requirements. The Department recommends agencies contact their vendor for details and work with the Sandata support center to assure the EHR will interface correctly.
Sandata Support Center:
The Department understands that providers require information on the State EVV Solution to make an informed decision regarding which EVV system to utilize. The Department recommends that agencies evaluate their business needs against capabilities of the State EVV Solution, taking into consideration fiscal impacts of Provider Choice systems. For details of the State EVV Solution functionality, review the EVV Agency Provider Participant Training Guide and the EVV Traning Supplemental Materials Guide located on the State EVV Solution Provider Information page on the EVV website. For details of technical requirements for Provider Choice systems, visit the Provider Choice Systems Information page on the EVV website.
A current list of the Provider Choice systems who have been interfaced with Sandata can be found on the EVV website. Utilizing a vendor from this list may reduce interface time. The Department does not endorse any specific vendor.
The hybrid approach to EVV implementation permits flexibility when choosing which system to utilize. Providers may choose to utilize the State EVV Solution at any time. Since training and systems requirements for the State EVV Solution may differ from that of provider choice systems, the Department recommends that providers plan timelines accordingly to ensure seamless transition.
Financial Management Service (FMS) vendors for the CDASS program may use the State EVV Solution or a Provider Choice system. However, requirements within the FMS contracts establish guidelines for when a vendor may choose to utilize the State EVV Solution. FMS vendors should refer to their contract for details.
Please review two technical specification documents posted on our EVV Resources webpage with your EVV vendor:
The provider agency and EVV vendor need to successfully complete interface testing. The length of this process varies and may take two to six months depending on the provider choice system. Please refer to the EVV Provider Choice Systems Information webpage for further information.
Providers should contact Sandata at (855) 871-8780 or CO-HCPF-EVVProviderHelpdesk@etraconline.net to begin the process of connecting to a Provider Choice system. Technical specifications for Provider Choice systems wishing to connect to the Aggregator can be found on the EVV website.
Provider Choice system users are also required to attend training prior to receiving log-in credentials to the Data Aggregator. A link to register for this training is available on the EVV website. Upon completing training and successful interface testing, Provider Choice systems will be able to successfully connect to the Data Aggregator.
Provider Choice systems are required to meet Cures Act requirements and interface with the State EVV Solution through the Data Aggregator. If a Provider Choice system is unable to interface with the Data Aggregator, no EVV information will be transmitted to the Department. The Department’s EVV vendor will work with providers on a case by case basis when Provider Choice systems are unable to interface with the Data Aggregator. In instances where interfaces are not possible, providers can choose to utilize the State EVV Solution or a different Provider Choice system.
Yes. Providers may choose what works best for their agency, caregivers, and members.
The scheduling module is an optional feature within the State EVV Solution. This allows an administrator to enter scheduled visits for their direct care workers and members. It also allows for provider agency staff to receive alerts if direct care workers are missing scheduled services and if there is a need to send an additional direct care worker out to a member, ensuring service delivery.
No, the scheduling module is an optional feature for provider agencies. It is not required for State EVV Solution users or Provider Choice systems to have this feature active. If utilized, scheduling information contained in the module is for provider use only and will not transmit to the Department.
Training is mandatory for providers who utilize either the State EVV System or a Provider Choice system. Successful training completion results in administrative log-in credentials, which are used to access the agency’s State EVV Solution or Data Aggregator. The self-paced eLearning is the training modality currently available and will remain available throughout the life of the EVV program. This training format is available for multiple staff members within the agency. Please note, that the first staff member to complete training will initiate the release of log-in credentials.
Prior to the launch of the EVV system in October 2019, in-person classroom and instructor-led webinar trainings were hosted by the Department and our EVV vendor. Additional instructor-led webinar trainings may be offered prior to the EVV mandate.
Training for State EVV Solution users can be found on the EVV State Solution Provider Information website.
Training for Provider Choice system users can be found on the EVV Provider Choice Systems Information website.
Training materials will cover administrative and direct care worker functions within the State EVV Solution and how to utilize the Data Aggregator. The Department has and continues to collect stakeholder feedback on additional training materials that would be helpful to stakeholders. The Department is not coordinating training efforts for direct care workers or Provider Choice systems. These trainings are the responsibility of provider agencies.
Training is mandatory for State EVV Solution users and Provider Choice system users to receive log-in credentials to the provider portal of the EVV State Solution and Data Aggregator.
If an agency is choosing to use a Provider Choice system for EVV, will the agency still need to complete the State EVV Solution training?
No. Completing Data Aggregator or State EVV Solution training generates log-in credentials for a provider agency. Each provider agency is only allowed one set of credentials per Provider Medicaid ID; therefore, the agency must choose which training to complete based on their EVV system.
At this time, Department offered training is for provider agencies and provider agencies are responsible for training direct care workers. Per stakeholder request, the Department has developed additional State EVV Solution reference training materials for caregivers.
Training provided by the Department is free of cost. While training is mandatory to receive log-in credentials, the provider agency will be responsible for deciding if they compensate their staff for attending trainings. The Department will not reimburse expenses incurred for training.
The Department has incorporated stakeholder feedback throughout the design of State EVV Solution. Each subcommittee has developed a list of recommendations for the Department to consider for system design and policy decisions. For example, stakeholders asked that the Department not verify a service location against a member’s home or other pre-determined location. The Department thoughtfully considered this recommendation and ultimately agreed that predetermined locations could create undue burden on a member’s ability to receive services in the community. This is just one of many examples of how stakeholder feedback has been incorporated into the design of the State EVV Solution.
The State EVV Solution vendor; Sandata, offers a call center for Colorado EVV users. If technical support question goes to the Department or DXC call center, it will be referred to the Sandata call center for resolution.
Page last updated: January 17, 2020
NOTE: This FAQ is a living document, check back for updates.
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