New Resource: EVV Report on Reasons for Implementation Delays

The implementation of electronic visit verification (EVV) has caused significant concern among disability advocates because of privacy and technical challenges. As a resource for our members as they work with their states on implementing this federal rule in a manner that protects the well-being of individuals served, we are sharing a report by Applied Self-Direction which “analyzed the various reasons [state and CMS gave for implementation] delay[s] and organized them by theme. The following document includes these major themes and the specific related reasons cited by CMS in their approval letters to states.” Note that all states except for Tennessee applied for an EVV implementation delays. At this time all requests have been approved except for those of South Carolina and the territory of Guam, which CMS lists as still pending.

Themes among the delay requests, as reported by Applied Self Direction, include:

• A prolonged request for proposals (RFP) process for vendors (21 states)
• Technology issues (18 states)
• Competing state priorities (14 states)
• Budget limitations (13 states
• Provider engagement and training (12 states)
• State processes (9 states)
• Stakeholder engagement and training (9 states)
• Responding to stakeholder feedback (8 states)
• Accommodating unique issues for self-direction (8 states)
• Staffing limitations (7 states)
• Adjusting for CMS guidance (6 states)
• Vendor issues (5 states)
• Complexity of coordinating with multiple agencies (4 states)
• Issues identified in implementation (3 states)
• Coordinating with financial management services providers (3 states)
• State legislation (1 state)
• Negotiating with unions (1 state)
• New waiver (1 state)