What is Electronic Visit Verification (EVV)?

If you run a home care agency that bills Medicaid, you have almost certainly heard the term "electronic visit verification" in the past few years. State Medicaid agencies send letters about it. Clearinghouses reject claims without it. Caregivers ask what they need to download. And regulators are beginning to deny payment when it is missing.

This article explains what EVV is, why it exists, what it requires, and how it works in practice -- so you can make informed decisions about your agency's compliance program.

What Electronic Visit Verification Is

Electronic visit verification is a technology requirement that Medicaid imposes on providers of home-based care. At its core, EVV means using a digital system -- typically a smartphone app, a web portal, or a telephony line -- to record the start and end of every home care visit in real time. The record must capture specific data elements defined by federal law, and that record must eventually flow to your state Medicaid agency before a claim can be paid.

Before EVV, most home care visits were documented on paper timesheets. A caregiver would write down when they arrived and when they left, a supervisor would review and sign the sheet, and the agency would submit a claim based on those self-reported hours. That model created significant opportunity for billing fraud and made it nearly impossible for regulators to audit visit data at scale.

EVV replaces the paper timesheet with a verified digital record. The verification comes from GPS coordinates (confirming the caregiver was physically at the service address), timestamps generated at the moment of clock-in and clock-out (not entered after the fact), and identity confirmation tied to the caregiver's account. The result is a tamper-resistant audit trail for every visit.

Why EVV Exists: The 21st Century Cures Act

The federal mandate for EVV comes from Section 12006 of the 21st Century Cures Act, signed into law in December 2016. The law required all states to implement EVV for Medicaid-funded personal care services (PCS) and home health services (HHS) or face a reduction in their Federal Medical Assistance Percentage (FMAP) -- the federal share of Medicaid funding.

The original deadlines were January 1, 2020 for personal care services and January 1, 2023 for home health services. Congress extended both deadlines after states reported implementation challenges during the COVID-19 public health emergency. Every state is now required to have an operating EVV system for both service types.

The policy rationale for EVV rests on two pillars. First, Medicaid home care is one of the highest-fraud areas in the entire Medicaid program. The U.S. Department of Health and Human Services Office of Inspector General has documented cases where agencies billed for visits that never occurred, billed for longer visits than were provided, and billed for services delivered by caregivers who were not present. EVV creates an independent record that makes these fraud patterns detectable and prosecutable.

Second, home care is a patient safety issue. Medicaid beneficiaries receiving home-based services are often elderly or disabled individuals who depend on those visits for basic needs -- bathing, medication reminders, meal preparation, and mobility assistance. EVV creates accountability for the delivery of those visits and gives states visibility into whether beneficiaries are actually receiving the care their care plans prescribe.

For more on the enforcement timeline and what is happening in 2026, see our article on the 21st Century Cures Act deadline.

Who Must Use EVV

Any provider billing Medicaid for personal care services or home health services must use an EVV system. This includes:

Home care agencies employing W-2 caregivers
Consumer-directed or self-directed programs where the beneficiary hires individual providers
Home health agencies providing skilled nursing or therapy at home
Managed care organizations and their network providers in states where Medicaid is administered through MCOs

The specific services covered vary by state. At the federal level, the mandate applies to:

Personal care services (PCS) -- non-medical assistance with activities of daily living such as bathing, dressing, grooming, and mobility, typically delivered by a home health aide or personal care attendant
Home health services (HHS) -- skilled nursing visits, physical therapy, occupational therapy, and speech-language pathology delivered in the home setting and authorized under a physician's plan of care

Many states have expanded their EVV requirements beyond the federal floor to include home and community-based services (HCBS) waiver programs, adult day services with a home component, and other service types. Check with your state Medicaid agency for the precise list of procedure codes that require EVV in your state.

Private-pay home care -- services not billed to Medicaid -- is not covered by the federal mandate, though some agencies use EVV software for private-pay visits as well for scheduling and quality control purposes.

The 6 Required EVV Data Elements

The 21st Century Cures Act specifies exactly what an EVV record must capture. There are six required data elements:

Type of service performed
Individual receiving the service (the Medicaid beneficiary)
Date of the service
Location where the service was delivered
Individual providing the service (the caregiver or provider)
Time the service begins and ends

These six data elements are the minimum. States may require additional fields -- some require a plan-of-care reference number, a prior authorization code, or a diagnosis code at the visit level. Your EVV system must capture all six federal elements plus any state-specific additions for your claims to pass validation.

For a detailed breakdown of each data element and how EVV systems capture them, see our article on the 6 EVV data elements.

How EVV Works in Practice

The mechanics of EVV vary by system, but the standard smartphone-based workflow looks like this:

Before the visit

After the caregiver authenticates into the app on a session-protected device, a scheduled visit appears for them. The app shows the beneficiary's name, service address, scheduled start and end times, and any task checklist tied to the care plan -- visible only to the assigned caregiver under role-based access controls. The caregiver drives to the home.

At clock-in

When the caregiver arrives, they open the app and tap a check-in button. The app records a GPS coordinate and a precise timestamp at that moment. The EVV system confirms that the GPS coordinate is within an acceptable distance of the authorized service address -- typically the beneficiary's home address on file. The caregiver's identity is confirmed by their account login; some systems add biometric confirmation (fingerprint or face recognition) for cold-start security.

If GPS is unavailable -- weak signal, restricted permissions, or rural dead zones -- a well-designed EVV system does not block the visit. Instead, it records a manual attestation and flags the visit for supervisor review. Care always takes priority over data collection, and states account for GPS exceptions in their EVV policies.

During the visit

The caregiver delivers care. Many EVV systems allow caregivers to document tasks completed during the visit -- activities of daily living, medication reminders, mobility assistance -- building a richer record of service delivery beyond just the timestamps.

At clock-out

When the visit ends, the caregiver taps a check-out button. The app records a second GPS coordinate and timestamp. The system calculates the visit duration from the two timestamps. The complete visit record -- all six federal data elements -- is now stored in the EVV system.

Transmission to the state aggregator

EVV records do not go directly from your software to your state Medicaid agency. They pass through a state aggregator -- a middleware platform designated by the state to collect and validate EVV data from all providers and EVV systems operating in that state. The aggregator validates each record against the state's business rules and then makes the data available for the state's Medicaid management information system (MMIS) to use in claim adjudication.

This aggregator layer is why your EVV software must be compatible with your specific state's designated aggregator. A system that integrates with Sandata will not automatically work in an HHAeXchange state, and vice versa.

From EVV record to paid claim

Once your EVV record is in the state aggregator and matches a submitted claim, the claim can adjudicate normally. In states with hard-edit enforcement, claims submitted without a matching EVV record -- or with EVV records that fail validation -- are denied at the clearinghouse before they ever reach Medicaid. This is why EVV compliance is ultimately a revenue issue, not just a regulatory checkbox.

State Aggregators: Sandata and HHAeXchange

When Congress passed the 21st Century Cures Act, it gave each state flexibility in how to implement EVV. States could build their own EVV portal, contract with a third-party aggregator, or use a hybrid model. In practice, two vendors have captured most of the market:

Sandata Technologies -- used by California, New York, Ohio, and many other states. Sandata provides both a state portal that providers can use for free and an aggregator API that third-party EVV software integrates with.
HHAeXchange -- the aggregator for Illinois, Michigan, Texas, New Jersey, and several other states. HHAeXchange similarly offers a free provider portal alongside an open vendor model that allows third-party systems to submit EVV data via API integration.

Washington uses Sandata as its state aggregator. Florida uses HHAeXchange, though Florida routes submissions through HHAeXchange's V5 flat-file EDI path rather than the modern REST API used in other HHAeXchange states -- meaning providers in Florida must confirm that their EVV software supports that submission format specifically.

For agencies evaluating vendors, understanding which aggregator your state uses is a critical first step. If a software vendor does not have a certified integration with your state's aggregator, your EVV data will not flow to the state, and your claims will not pay.

For a head-to-head comparison of the two largest aggregators, see our article on Sandata vs HHAeXchange.

EVV Enforcement in 2026

Many agencies operated under a grace period during EVV rollout. States were going live, but claims with missing or incomplete EVV data were often paid anyway -- states used "soft edits" that logged violations but did not deny claims. That grace period is ending.

In 2026, states are moving to hard-edit enforcement. A hard edit is a claim rejection that happens automatically when an EVV record is missing or invalid. The claim does not enter the adjudication queue. It is returned to the provider as denied. To get paid, the agency must correct the EVV record and resubmit.

Illinois is an example of the current enforcement environment. Illinois has required a 75% quarterly EVV compliance threshold for Home Health Care Services (HHCS) provider agencies since September 30, 2025. On February 10, 2026, HFS issued an updated EVV policy effective April 1, 2026 that introduced the current three-strike remediation structure: agencies that fall below the threshold in a State Fiscal Year quarter face mandatory administrator LMS training within 30 days for the first strike, a Compliance Action Plan within 10 business days for the second, and referral to the HFS Office of Inspector General for the third. Illinois agencies that went live on HHAeXchange in March 2026 -- particularly those covered by IDoA and IDHS-DRS -- are in the first SFY quarter of live operation under the updated rules right now.

Michigan implemented a hard cutover on January 1, 2026: claims without a corresponding EVV record became unpayable. There is no soft-edit fallback. If the EVV record is missing, the claim is denied.

The pattern is consistent across states: regulators spent several years building infrastructure and educating providers, and they are now using financial penalties to enforce adoption. Agencies that have not implemented a compliant EVV system face direct revenue risk in 2026.

How to Choose EVV Software for Your Agency

Not all EVV software is the same. The minimum requirement is that a system captures the six federal data elements and transmits them to your state's aggregator. Beyond that, the quality of the software determines how much administrative burden falls on your staff.

Key questions to ask any EVV vendor:

Is the system certified with my state's aggregator (Sandata, HHAeXchange, or state-built)?
Does the system handle GPS exceptions without blocking care delivery?
Can caregivers use their personal smartphones, or is proprietary hardware required?
Does the system connect EVV visit data to claim submission, or is that a manual step?
What does the system cost, and are there per-claim or per-submission fees in addition to the base price?

Pricing transparency is worth examining carefully. Quote-only pricing typically means costs that scale unpredictably as your agency grows. Flat-rate pricing -- a platform fee plus a fixed per-caregiver seat -- gives you a predictable cost structure and makes it easier to evaluate ROI against the revenue protected by compliance.

For a full framework on evaluating EVV vendors, see our guide on how to choose EVV software. For guidance specific to smaller agencies, see our article on EVV for small agencies (5-50 caregivers).

Frequently Asked Questions

Is EVV required for private-pay home care?

No. The federal EVV mandate applies only to Medicaid-funded services. Private-pay visits -- services billed directly to clients or private insurance -- are not subject to the 21st Century Cures Act requirement. Some agencies choose to use EVV software for all visits regardless of payer, but there is no regulatory obligation to do so for non-Medicaid services.

What happens if a caregiver cannot get a GPS signal?

GPS failures are a documented reality of home care, particularly in rural areas or multi-unit buildings where satellite signals are blocked. States account for this in their EVV policies by allowing a certain percentage of visits to be documented via manual attestation -- where the caregiver certifies their presence without GPS verification. Most states allow manual attestation for a defined percentage of visits per billing period (commonly 10-20%). Visits exceeding that threshold may be flagged for review or denied. Your EVV system should flag GPS exceptions automatically so your administrative staff can monitor and resolve them before claim submission.

Can I use the state-provided EVV system instead of purchasing software?

In states that use Sandata or HHAeXchange as the aggregator, providers can typically access a free portal maintained by the aggregator vendor. Illinois providers, for example, can use the HHAeXchange provider portal at no cost to record visits and transmit EVV data. The free portal covers basic EVV requirements but does not include scheduling, billing integration, care plan management, or reporting. Agencies with significant administrative complexity -- more than a handful of caregivers, multiple payers, or recurring schedule management needs -- typically find that purpose-built agency software saves more in staff time than it costs in licensing fees.

How long do I need to retain EVV records?

Medicaid record retention requirements vary by state but generally require providers to retain medical and billing records for a minimum of five years from the date of service. Some states require longer retention periods. EVV records are considered billing documentation and fall under the same retention rules as claim records and care plans. Your EVV software should maintain these records in a format that is accessible for audit purposes throughout the retention period.

Does EVV apply to adult day services or transportation?

The federal mandate covers personal care services and home health services as defined under 42 CFR. Adult day services, non-emergency medical transportation, and other HCBS waiver services are not covered by the federal EVV mandate -- but individual states may extend EVV requirements to those service types. Check with your state Medicaid agency or your managed care organization for a complete list of covered service codes.

What is the difference between an EVV system and a state aggregator?

An EVV system is the software your agency and caregivers use to record visits -- the app, the dashboard, the scheduling tools. A state aggregator is the middleware platform your state designates to collect EVV records from all providers and make that data available to the state Medicaid system. Your EVV software must integrate with your state's aggregator via an API to transmit visit records electronically. The two are separate systems with separate functions; you need both.