EVV Requirements by State (2026)
Electronic visit verification (EVV) is a federal requirement, from Section 12006 of the 21st Century Cures Act, for Medicaid-funded personal care and home health visits. Every EVV system must record six details for each visit, but every state runs EVV its own way: most let agencies use a third-party system that sends those details to the state’s aggregator, a few require one vendor, and private-pay visits are outside the federal rule.
Where EVV comes from.
Electronic visit verification proves a home visit happened. Instead of a paper timesheet filled in afterwards, the caregiver records the start and end of the visit electronically, usually on a phone, and the record carries the who, what, when and where of the visit.
The rule comes from Section 12006 of the 21st Century Cures Act, signed in December 2016. It added subsection (l) to Section 1903 of the Social Security Act and directs every state Medicaid program to require EVV for Medicaid-funded personal care services (PCS) and home health care services (HHCS) that involve an in-home visit, in fee-for-service Medicaid and Medicaid managed care alike.
- 01
January 1, 2020
The original deadline for personal care services.
- 02
January 1, 2021
The extended PCS deadline for states that asked CMS for a good faith effort exemption. Most states used it, which is why many list 2021 as their PCS start date.
- 03
January 1, 2023
The deadline for home health care services. Some states moved later with CMS approval; Texas, for example, required EVV for HHCS from January 1, 2024.
Who is covered
If you bill Medicaid, directly or through a managed care plan, for personal care, attendant care, homemaker, respite or skilled home health visits in the home, EVV almost certainly applies to those visits. Private-pay visits are outside the federal mandate.
If a state does not comply, its federal Medicaid match (FMAP) is cut on an escalating CMS schedule: 0.25 percentage points in the first year, rising to 1 percentage point in later years, with a separate schedule for home health. The penalty lands on the state, not on agencies. Agencies feel it through claims: in most programs, a Medicaid claim for an EVV service must match a verified visit record or it is denied or pended.
Six details every visit must record.
The law is short on technology and specific on data. Every EVV system, whether the state built it or you bought it, has to verify these six for each visit.
Type of service
What care was provided.
Person receiving care
The client the visit was for.
Person providing care
The caregiver who delivered it.
Date of service
The day the visit happened.
Location
Where the service was delivered.
Start and end time
When the visit began and ended.
Location is taken twice, not tracked
Location is captured at clock-in and clock-out, not continuously. Colorado’s program FAQ says so plainly: the Cures Act requires location only at the beginning and end of a visit. GPS is the common method, but states also accept telephony from the client’s landline and fixed devices in the home.
Six is the floor, not the ceiling
States and managed care plans add their own rules on top: reason codes for manual edits, live-in caregiver exemptions, service code tables and claims-matching windows. The law also says EVV must be minimally burdensome, build on systems already in use and follow HIPAA, which is why most states let agencies keep a system they already had, as long as the data reaches the state.
Five ways states run EVV.
CMS gave states control over how to run EVV, and they settled into five models. Yours decides whether you can pick your own software, whether you must connect to a state aggregator, and who pays.
- 01
Provider choice
The state supplies no system. Each agency picks and pays for its own, and the state defines how the data is sent, often as fields on the claim. Washington will not mandate or recommend a system and takes the EVV elements with claims in ProviderOne; New York’s Choice Model sends all data to the New York State EVV Data Aggregator.
- 02
State-mandated vendor
The state contracts one vendor and every agency must use its system, with no third-party option. Some states started here and later opened up: Mississippi moved from a closed model to an open vendor model in 2023. Check your state’s current page, not an older list.
- 03
State-run system
The state builds and runs EVV itself, usually inside its Medicaid management information system. This is uncommon for agency care. Arizona took its aggregator in-house on October 1, 2025, replacing Sandata, and still accepts data from alternate vendors that pass its review.
- 04
Open model
The most common. The state offers a free system and runs a data aggregator; agencies can use it or a third-party system certified to send the six elements in the state’s format. Ohio, Pennsylvania, Massachusetts, Colorado, Illinois, Michigan, North Carolina, Georgia, Florida (fee-for-service home health) and California describe their programs this way.
- 05
Managed care plan choice
Each managed care organization picks its own EVV vendor or aggregator, so an agency contracted with several plans can submit to more than one. Florida’s personal care services and parts of Massachusetts and Iowa work this way.
The practical question
For most agencies the model comes down to one question: can we use our own scheduling and clock-in software, and if so, where do we send the data? The table below answers it for 15 states.
EVV requirements in 15 large states.
| Model | State system or aggregator | Third-party EVV allowed? | |
|---|---|---|---|
| California | Open. PCS live January 1, 2022; HHCS January 1, 2023. | CalEVV (Sandata) for agency providers. Individual IHSS and WPCS providers paid directly by the state use the CDSS IHSS EVV app, Electronic Services Portal, or Telephone Timesheet System instead. | Yes. Name your vendor in the CalEVV self-registration portal; the vendor completes Sandata certification before sending data to the aggregator. |
| Texas | State-mandated vendor plus approved proprietary systems. PCS January 1, 2021; HHCS January 1, 2024. | HHAeXchange is the single state EVV vendor system, delivered through TMHP (Accenture). DataLogic/Vesta and AuthentiCare were retired by October 1, 2023. | Only as an HHSC-approved EVV Proprietary System Operator (PSO), after an operational readiness review through TMHP. |
| Florida | Open vendor model for fee-for-service home health; managed care plans set their own PCS requirements. | AHCA contracted HHAeXchange for fee-for-service home health effective October 1, 2024, replacing the Netsmart (Tellus) system. | Yes for fee-for-service home health if the system integrates with HHAeXchange. Verify each managed care plan’s aggregator. |
| New York | Choice Model (provider choice), selected in 2020. PCS January 1, 2021; HHCS January 1, 2023. | New York State EVV Data Aggregator, used for reporting and audit. | Yes. Any Cures Act compliant system that submits to the state aggregator; the state chose not to mandate a vendor. |
| Ohio | Open (state solution plus Alternate EVV). | Sandata, under contract with the Ohio Department of Medicaid, provides the state system and the aggregator. | Yes. ODM publishes Alternate EVV resources and Sandata runs alternate EVV support for Ohio. |
| Pennsylvania | Open (state solution plus third-party or Alternate EVV). | DHS Aggregator, built on Sandata data specifications. | Yes. Third-party systems send the six CMS elements to the DHS Aggregator using the published specifications. |
| Illinois | Hybrid, the state’s own word for an open model. HHCS live December 31, 2023. | HHAeXchange, selected March 2022 as state vendor and aggregator. DRS and Department on Aging data integrated from March 2, 2026. | Yes. Any qualified vendor, but data must be submitted through the HHAeXchange EDI process. |
| Arizona | Open with an in-house state aggregator (EVV 2.0). | AHCCCS EVV Aggregator, run by AHCCCS itself since October 1, 2025. Sandata was the vendor and aggregator before that. | Yes. AHCCCS publishes an Alternate Vendor review tool to check that a vendor meets its requirements. |
| Georgia | Open. PCS live 2021; HHCS expansion still being determined by DCH. | Netsmart Mobile Caregiver+, the state solution, at no cost. | Yes, from the DCH-published list of third-party vendors integrated with the state solution. |
| Washington | Provider Choice Model. The state will not mandate or recommend a system. | ProviderOne is the aggregator; EVV elements travel with claim submissions. | Yes, by design. All home care agency caregiving employees must use EVV; the agency picks the system. |
| Colorado | Hybrid (state solution or Provider Choice). | Sandata provides the State EVV Solution at no cost and aggregates third-party data. | Yes. HCPF keeps a list of vendors that have interfaced with Sandata. |
| Michigan | Open. Statewide implementation completed in 2024. | HHAeXchange, awarded a five-year contract in March 2023 for collection, aggregation, and pre-billing. | Yes. MDHHS and HHAeXchange publish technical specifications for third-party integration. |
| North Carolina | Open (state vendor plus Alternate EVV). | Sandata is the state vendor and the aggregator for all third-party systems. HHAeXchange is a separate solution used by some managed care plans. | Yes. Agencies may use an Alt EVV system of their choice and submit to the Sandata Aggregator; confirm plan-specific rules. |
| New Jersey | Open (per vendor sources); DMAHS lists HHAeXchange as the state EVV vendor. | HHAeXchange, selected by DMAHS in August 2020 as the state aggregation solution for NJ FamilyCare. | Yes, if the system integrates with the HHAeXchange aggregator. Verify current steps with DMAHS. |
| Massachusetts | Open model, EOHHS’s own description. | Sandata is the state system for agency-based services and runs the EOHHS data aggregator. | Yes. Alt-EVV systems send all six CMS elements to the aggregator daily and are declared in the Sandata self-registration portal. |
Each row was checked against the state Medicaid agency’s own EVV page, or a state notice, in September 2026; where only vendor sources were available, the row says so. Sandata and HHAeXchange run the aggregator in most of these states and Netsmart runs Georgia’s, while Washington and New York leave the software choice to the agency. Even a free state system is usually only for visit capture and reporting (Massachusetts notes its Sandata system has no billing or payroll functions). EVV programs change vendors and rules often, so confirm with your state before signing a software contract.
What changed in 2026.
Two states tied payment more tightly to EVV data this year. Both were checked against the state’s own notices in October 2026.
Missouri: claims must match a visit
Since April 1, 2026, MO HealthNet denies claims for personal care and other services authorized by the Division of Senior and Disability Services when there is no matching visit in the state’s EVV aggregator. Home health care providers followed on June 1, 2026.
The match checks the client number, dates of service, provider Medicaid ID, procedure code and modifiers, and units, so billed units have to equal the units recorded.
Minnesota: compliance rates and HHAeXchange
Minnesota DHS requires every provider to enroll with HHAeXchange, the state’s system, whatever EVV system it uses. From January 1, 2026, at least 50% of billed visits needed complete EVV data, and from July 1, 2026, at least 80%.
Providers under the bar get corrective action notices each quarter, and DHS may take back paid claims or stop payment.
Private-pay only? Check three things.
The federal mandate is a condition on Medicaid funding. If none of your visits are billed to Medicaid, Section 12006 does not require EVV and there is no state aggregator to report to. Before relying on that, check:
- Whether a state licensing rule for home care agencies requires electronic timekeeping on its own
- Whether a Veterans Affairs, long-term care insurance or Medicaid waiver contract you hold adds its own visit verification terms
- Whether you plan to accept Medicaid clients in the next year or two
Why private-pay agencies use EVV anyway
- Payroll accuracy. GPS-stamped clock-ins end the end-of-week argument about when a shift actually started.
- Family trust. Adult children paying the invoice increasingly ask for proof of visits, and a verified visit log answers before they ask.
- Billing disputes. A verified record with time and location is much stronger evidence than a handwritten timesheet.
- Future readiness. If you later take a Medicaid contract, caregivers already have the habit and your data already has the six elements.
How to pick an EVV-capable system.
Whether your state is open, provider choice or mandated, the software questions are similar. Use this list to evaluate a system or audit the one you have.
- 01
Captures all six elements at the point of care
Service type, client, date, location, caregiver, and start and end times, with location taken at clock-in and clock-out.
- 02
Offers more than one capture method
GPS on the caregiver’s phone is standard. Check whether your state also expects telephony or a fixed device for clients without a caregiver smartphone.
- 03
Works offline
Rural homes and apartment buildings lose signal. The app should store the punch on the phone and sync when a connection returns, keeping the original timestamp.
- 04
Flags exceptions instead of editing them
Early, late, missed or out-of-range punches should go to a supervisor to approve with a reason code, because most states require reason codes on manual edits.
- 05
Keeps an audit trail
Who changed what, when and why. State aggregators and managed care audits both ask for it.
- 06
Exports in your state’s format
Or connects to a vendor that does. In open-model states, confirm the vendor is certified or integrated with your specific aggregator (Sandata, HHAeXchange, Netsmart or a state-run aggregator), not just certified somewhere.
- 07
Handles live-in and other exemptions
Several states, including California and Ohio, have live-in caregiver rules that change what must be captured.
- 08
Feeds payroll and billing
Approved visits should flow to payroll hours and claims without re-keying, since re-keying is where EVV records and claims stop matching.
- 09
Keeps data private
Caregiver location should be captured only at clock-in and clock-out, and the vendor should be willing to sign a business associate agreement.
- 10
Has a plan for change
Ask how the vendor handled a recent state transition, such as Texas moving to HHAeXchange in 2023, Florida in 2024 or Arizona in 2025.
How Hailo handles EVV.
Hailo’s caregiver app records clock-in and clock-out with GPS, so each visit carries the caregiver, the client, the service, the date, the start and end times, and the location at both ends. The app works offline and syncs the punch later with its original timestamp. Early and late punches raise approval flags for the office instead of being changed automatically, and approved visits export to payroll.
Hailo captures the six EVV data elements and exports them. Hailo does not claim to be a certified aggregator vendor in any state. If your state requires submission to a state aggregator, confirm the path with your state Medicaid agency or managed care plan, and ask us how Hailo’s exported visit data fits it before you switch systems.
Visit record · Eleanor Brooks
- Clock-in2:04 PM · GPS
- Clock-out6:01 PM · GPS
- Late clock-in flaggedFor approval
- Six EVV details captured
Not legal advice. This guide is general information compiled from public federal and state sources as of September 2026. It is not legal, regulatory or billing advice, and state EVV programs change often. Confirm current requirements with your state Medicaid agency, your managed care plans and qualified counsel before making compliance or purchasing decisions.
What changed in EVV rules in 2026?
Missouri began denying personal care claims with no matching visit in its EVV aggregator on April 1, 2026, and home health claims on June 1, 2026. Minnesota now requires every provider to enroll with HHAeXchange and to have complete EVV data for at least 80% of billed visits from July 1, 2026, with corrective action for providers below that.
Does EVV apply to private-pay home care visits?
No. The federal requirement in Section 12006 of the 21st Century Cures Act covers Medicaid-funded personal care and home health visits, so private-pay visits are outside it. Some agencies use EVV for every visit anyway, for payroll accuracy and family trust, and a few states or contracts add their own timekeeping rules, so check your state licensing rules and payer contracts.
What are the six EVV data elements?
The type of service performed, the individual receiving the service, the date of the service, the location of service delivery, the individual providing the service, and the time the service begins and ends. Location is captured at clock-in and clock-out, not continuously.
Can an agency use its own EVV system in an open-model state?
Usually yes, if the system (or a vendor it connects to) is certified to send the six data elements to the state’s aggregator in the required format. Ohio, Pennsylvania, Massachusetts, Illinois, Michigan, Colorado, North Carolina, Georgia and California all allow alternate or third-party EVV systems. Texas is the main exception among large states: there you must use HHAeXchange or be approved as a proprietary system operator.
What happens if a Medicaid claim has no matching EVV record?
It depends on the state and plan, but the usual outcome is a denied or pended claim. Colorado, for example, has required an EVV record before claims processing for mandated services since January 1, 2021, and Texas managed care plans deny unmatched EVV claims. The federal FMAP penalty applies to the state, not to individual agencies.
Does the caregiver need a smartphone?
Not necessarily. GPS on a mobile app is the most common method, but states also accept telephony (calling from the client’s phone) and fixed devices in the home. Texas says it is reducing the use of alternative devices, so check which methods your state still supports.
Is Hailo a certified EVV aggregator vendor?
No. Hailo captures the six EVV data elements with GPS clock-in and clock-out, works offline, flags early and late punches for approval and exports approved visits. Confirm your state’s submission path with your state Medicaid agency before relying on any system for aggregator reporting.
Sources: CMS / Medicaid.gov: Electronic Visit Verification; CMS: Section 12006 of the 21st Century CURES Act EVV Systems, Session 1 (FMAP reduction schedule); Congress.gov: 21st Century Cures Act, H.R. 34 (Section 12006); ACL: CMS Provides Guidance on Good Faith Effort Extensions for States; California DHCS: California Electronic Visit Verification (CalEVV); California CDSS: IHSS Electronic Visit Verification Help; Texas HHSC: Electronic Visit Verification; Texas HHSC: EVV Proprietary Systems; HHSC Notice: EVV Vendor Transition Overview (via Superior HealthPlan); Florida AHCA: Home Health Services Electronic Visit Verification; New York State DOH: NY Medicaid Electronic Visit Verification Program; Ohio Department of Medicaid: Electronic Visit Verification; Sandata: Ohio (ODM) Resources; Pennsylvania DHS: Third-Party/Alternate EVV; Illinois HFS: Illinois Electronic Visit Verification; Arizona AHCCCS: Electronic Visit Verification; Georgia DCH: EVV Third-Party Information; Washington DSHS: Electronic Visit Verification; Colorado HCPF: EVV Solution Information; Colorado HCPF: EVV Frequently Asked Questions; Michigan MDHHS: EVV Caregivers and Providers FAQs; NC Medicaid: EVV Update for Providers Using a Third-Party Alternate EVV Vendor; New Jersey DMAHS: Electronic Visit Verification; Mass.gov: Electronic Visit Verification for Agency-based Providers; Missouri DSS: EVV Claims Validation Hard Launch begins April 1, 2026; Minnesota DHS: Electronic visit verification (2026 compliance schedule); HHAeXchange: State-by-State EVV Guide; TripLog: EVV Compliance Requirements by State (Mississippi model change)
Related guides.
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Home care scheduling and EVV software: fill open shifts with suggested caregivers, verify visits from the caregiver app and send approved hours to billing.
Call-off coverage playbook
How home care agencies handle caregiver call-offs: a written policy, a backup bench, a 10-minute coverage protocol, and the metrics that cut no-shows.
Best software (2026)
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