Wisconsin Electronic Verification Visit: Risk Management Considerations for New Enforcement Efforts

Below are some considerations in preparation for the May 1, 2023 effective date:

1. Evaluate current compliance with EVV submissions. Determine your organization’s current completion rate and accuracy of submissions. This will help determine if changes to process are needed.
2. Evaluate training procedures to determine effectiveness. The EVV Training and Training Workers pages have some helpful resources and information to aid in training employees how to check in/out of visits and use of the EVV portal.
3. Establish or confirm an internal auditing/monitoring process to ensure submissions are complete and accurate. The process should include information to address the handling of late or forgotten entries.
4. Evaluate devices workers use for EVV and whether these devices have proper security features (network, software, locking features, etc.). Incorporate security and HIPAA considerations in employee training for EVV, such as privacy considerations with the device and the process for a lost or stolen device. Include considerations regarding employer vs. employee owned devices and how security is affected. Consider having a Mobile Device Management (MDM) platform to enforce security requirements on both types of devices. Ensure that policies and procedures lay out any security requirements applicable to employees.
5. Assess the process for incorporating EVV into your Corporate Compliance program. For example, consider adding EVV to the proactive auditing schedule and include audit results on the Compliance Committee agenda. Remind employees that EVV information is housed by DHS and adds to the organizational data available to the federal government potentially having an effect on false claims accusations. Account for any potential HIPAA breaches relating to EVV and report as necessary to the federal Office of Civil Rights (OCR).
6. Ensure recordkeeping practices follow Wis. Admin. Code § DHS 106.02(9) and Wis. Stat. § 49.45(3)(f). Providers are required to produce or submit documentation to DHS upon request. Update internal record retention schedule to reflect EVV records.