Delivering Statewide Compliance Readiness for Federally Mandated EVV Program

The Arizona Health Care Cost Containment System (AHCCCS) was required to implement Electronic Visit Verification (EVV) under the 21st Century Cures Act to monitor Medicaid-funded personal care and home health services. This introduced a complex, federally mandated program with strict compliance requirements, multiple stakeholders, and a defined timeline.

The state lacked sufficient internal resources to manage the program and engaged external vendors to deliver the solution. However, oversight, coordination, and execution control across vendors, agencies, and stakeholders were not yet established. Without structured governance, the program risked delays, compliance gaps, and misalignment across participating organizations.

The objective was to establish program-level governance and execution oversight to guide AHCCCS through certification, planning, and readiness for EVV implementation. This required coordinating across state agencies, healthcare providers, managed care organizations, and vendors while ensuring compliance with CMS requirements and independent verification and validation (IV&V) standards.

Execution focused on introducing structure, visibility, and control across a multi-stakeholder, compliance-driven program. Planning and requirements sessions were led to define the future-state business model and align stakeholders on program expectations. Business requirements workshops were facilitated across 12 state agencies to gather input and ensure alignment across impacted groups.

Vendor execution was actively managed through structured status reporting, progress tracking, and daily oversight to ensure implementation activities remained aligned with program objectives. Risk management sessions were conducted to assess program impact, identify potential issues, and establish mitigation strategies.

Ownership of critical program artifacts was established to maintain compliance with state and federal expectations, including the project charter, work plans, RAID logs, decision logs, scorecards, and investment justification documentation. A centralized SharePoint environment was created to support secure collaboration and document management across vendors and stakeholders.

Stakeholder communication was formalized through consistent reporting to executive leadership, state divisions, and external partners, ensuring visibility into status, decisions, and upcoming milestones. Coordination with the IV&V vendor ensured that program activities aligned with certification requirements and independent oversight expectations.

AHCCCS achieved CMS certification and completed the business-side implementation lifecycle required to move the EVV program forward. This enabled the state to secure a waiver, providing additional time to transition into technical implementation without overextending internal IT resources.

The program established a controlled and compliant execution environment, improving coordination across agencies, vendors, and healthcare partners. Leadership gained consistent visibility into program status, risks, and decisions, strengthening confidence in delivery and regulatory alignment.

The result was a structured foundation for statewide EVV implementation, positioning AHCCCS to proceed with technical delivery while maintaining compliance, operational readiness, and cross-functional alignment.