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Colorado Could Improve Its Electronic Visit Verification System and Claimed Federal Medicaid Reimbursement for Millions of Dollars in Personal Care Services That Did Not Comply With Federal and State Requirements

Issued on  | Posted on  | Report number: A-07-24-03260

Why OIG Did This Audit

  • As required by the 21st Century Cures Act, Colorado uses an Electronic Visit Verification (EVV) system to verify that a personal care services (PCS) attendant has arrived on the job and assisted a Medicaid enrollee with Medicaid-approved tasks.
  • EVV was developed to address weaknesses in the PCS program that contribute to improper payments, questionable quality of care, and notable amounts of fraud.
  • This audit examined whether Colorado implemented an EVV system in accordance with Federal and State requirements and complied with Federal and State requirements when claiming PCS.

What OIG Found

Colorado implemented an EVV system but did not verify that all PCS visits were recorded and verified in that system. Additionally, Colorado did not always comply with Federal and State requirements when claiming PCS. Specifically, of the 160 sampled PCS claims, we identified the following:

What OIG Recommends

We make six recommendations to Colorado related to its EVV system and provision of PCS, including that it refund $8.0 million (Federal share) in estimated overpayments to the Federal Government and that it work with CMS to determine the allowability of the estimated $45.7 million (Federal share) that we set aside. We also make procedural recommendations regarding system edits, improved monitoring of providers, and the establishment of policies and procedures. The full recommendations are in the report.

Colorado disagreed with most of our findings and recommendations.

26-A-07-081.01 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency refund $8,072,870 (Federal share) in estimated overpayments to the Federal Government.

26-A-07-081.02 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency work with CMS to determine the allowability of the estimated $45,688,080 (Federal share) that we have set aside, and refund to the Federal Government any amount that is determined to be unallowable.

26-A-07-081.03 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency improve its EVV system by: (1) establishing system edits and/or formal policy requirements governing attendants' use of manual entries and by implementing limit thresholds for how often manual entries can be used; (2) implementing system edits to verify that all PCS visits have corresponding EVV records; (3) requiring providers to verify that all PCS visits are entered in the EVV system; (4) implementing system edits that capture the location of services provided, and establishing requirements for providers and attendants to document and verify the actual location where PCS is provided; (5) implementing system edits that require providers to review and then correct GPS exceptions; (6) requiring providers to monitor the use of EVV reason codes and confirm their appropriate application; and (7) requiring providers to verify that the names of the attendants identified on EVV records match the names of the attendants who signed the corresponding timesheet

26-A-07-081.04 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency improve its procedures to verify that: (1) providers maintain documentation that attendant background screenings are completed for all attendants, and (2) providers complete and maintain ASMPs for all enrollees receiving consumer-directed PCS.

26-A-07-081.05 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency implement system edits to verify that: (1) units paid match the units approved on the enrollees' plans of care, and (2) rates paid are in accordance with the State's approved rates.

26-A-07-081.06 to CMS - Open Unimplemented
Update expected on 01/16/2027
We recommend that the State agency develop and implement requirements that attendants who render consumer-directed PCS document on their timesheets the level of detail necessary to support that the rendered services complied with the enrollees' ASMPs.

View in Recommendation Tracker