HCBS Compliance Blind Spot Map
The 5 areas where Colorado IDD agencies most commonly fall out of compliance — often without realizing it until an audit or denial surfaces the gap.
01
EVV Data Gaps
Electronic Visit Verification data doesn't match billed service times. Clock-in/out happens on paper or personal phones, creating unverifiable records.
- Mismatched start/end times between EVV and billing
- Manual overrides with no audit trail
- GPS location missing or inconsistent
02
Incomplete DSP Documentation
Service notes are missing required elements — or completed days after the visit. During audits, undocumented care = unbillable care.
- Notes lack individual-specific goal language
- Signatures missing or backdated
- Documentation not submitted within waiver timelines
03
Authorization Boundary Violations
Services delivered outside approved hours, dates, or service types. Agencies often don't catch this until a denial — or worse, a recoupment.
- Hours exceed monthly authorization cap
- Service type billed doesn't match authorization
- Expired authorizations still active in scheduling
04
Incident Reporting Failures
Critical incidents not reported within required timelines, or reported without required detail. This creates regulatory and legal exposure.
- Reports filed late or not at all
- Required follow-up documentation missing
- Pattern of incidents not escalated to HCPF/OCL
05
Staff Training Record Gaps
DSP training certifications expired or not documented. Auditors check this — and agencies with paper records frequently fail.
- CPR/First Aid certifications lapsed
- Annual trainings not documented in personnel files
- New hire orientation records incomplete or missing
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