Response to OIG Audit of Colorado’s Electronic Visit Verification System

July 21, 2026

Media Contact
Marc Williams
Department of Health Care Policy & Financing
720-626-0801 (Cell)

HCPF does not agree with many of the key conclusions in the Office of Inspector General's (OIG) report and is working with our federal partners, including the Centers for Medicaid and Medicaid Services (CMS), to address the findings and reduce any associated financial implications. The Colorado Department of Health Care Policy and Financing (HCPF) recognizes audits are an important opportunity to identify areas to improve oversight of our programs and have robust dialogue with our federal partners to ensure we are addressing findings in a meaningful way.

HCPF's review indicates that the majority of findings were isolated documentation issues, not evidence that services were not delivered or that caregivers were ineligible to provide care. The audit does not demonstrate that payments were made for services that were not authorized and rendered, nor does it identify fraud or intentional misuse of Medicaid funds.

HCPF also notes inconsistencies in OIG's approach to fiscal findings across states, including differing treatment of similar issues in other audits, which raises concerns about the equitable application of federal oversight standards.

Additionally, the audit's conclusions rely on extrapolation from a small sample of findings which may overstate the prevalence of issues when applied broadly across a diverse provider population delivering millions of services annually.

Colorado was one of the early adopters of electronic visit verification (EVV), requiring EVV since August 2020. HCPF has invested significant effort in implementation, provider guidance, and compliance oversight. As a result, Colorado has been continually identified as a leader in EVV and has been used as a model by the Centers for Medicaid and Medicaid Services (CMS) and other states.

Colorado's EVV program meets the core requirements of the 21st Century Cures Act and reflects HCPF's strong commitment to program integrity. HCPF has already implemented system and policy improvements addressing several of the issues identified in the audit and will continue working collaboratively with federal partners to ensure accurate interpretation of program requirements and appropriate resolution of the audit findings.

About the Colorado Department of Health Care Policy & Financing: The Department administers Health First Colorado (Colorado's Medicaid program), Child Health Plan Plus, and other programs for Coloradans who qualify. These health care programs now cover about one in four Coloradans. For more information about the Department, please visit hcpf.colorado.gov.