Best Practices for DVCs

The DVC should remain an objective, independent third party and avoid acting in a consulting capacity.

The DVC’s focus should be to determine, after a thorough evaluation, if an SO’s systems, programs, data, and related elements are correct, reliable, valid, and complete based on instructions and standards outlined in the DV Manual, its appendices, and CMS’s policies.

The DVC should remain impartial. CMS’s standards for organizational independence require that the contractor who conducts or helps with any pre-DV activities throughout the year and the DVC of the reported data can’t be the same. For example, DVCs shouldn’t pass judgment on the perceived value of an SO’s systems, programs, and data or develop findings based on personal preferences or any other method not addressed in the outlined standards or CMS policies.