On May 16, the Centers for Medicare and Medicaid Services (CMS) issued guidance on implementation of electronic visit verification (EVV) required in the 21st Century Cures Act. Congress directed CMS to issue this guidance at least one year before the implementation deadline of January 19, 2019. The statute requires EVV for personal care services and home health services. However, the guidance provides a very expansive interpretation that includes any service where assistance with activities of daily living or instrumental activities of daily living is provided in part in the home. Furthermore, it leaves many decisions with privacy implications up to states. The Arc believes the short time frame is insufficient for states to engage with stakeholders to implement these requirements in a way that does not put an undue burden on providers and does not violates the privacy of beneficiaries.