EVV Requirements by State (2026): What Home Care Agencies Must Do

Electronic visit verification (EVV) is a federal requirement for Medicaid-funded personal care and home health visits, but every state runs it differently. This guide explains what the law actually requires, how the state models differ, what 15 large states expect from agencies, and what to do if you only bill private pay.

By the Hailo teamUpdated September 3, 202612 min read

What EVV is and where the requirement comes from

Electronic visit verification is a way of proving that a home visit happened. Instead of a paper timesheet filled in after the fact, 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 requirement 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. The mandate applies to fee-for-service Medicaid and to Medicaid managed care alike.

The deadlines

January 1, 2020: original deadline for personal care services.
January 1, 2021: extended PCS deadline for states that requested a good faith effort exemption from CMS. Most states used this extension, which is why many state programs list 2021 as their PCS start date.
January 1, 2023: deadline for home health care services. Some states moved later with CMS approval; Texas, for example, required EVV for HHCS starting January 1, 2024.

The penalty for a state that does not comply is a reduction in its federal Medicaid match (FMAP). CMS guidance lays out an escalating schedule: 0.25 percentage points in the first year, rising to 1 percentage point in later years, with a separate schedule for HHCS. That penalty lands on the state, not on individual agencies. Agencies feel it indirectly: states enforce EVV through claims. In most programs a Medicaid claim for an EVV-applicable service must match a verified visit record or it is denied or pended.

The six required data elements

The statute is short on technology and specific on data. Every EVV system, whether the state built it or you bought it, has to electronically verify six things for each visit:

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.
The time the service begins and ends.

Two points trip agencies up. First, location is captured at clock-in and clock-out, not continuously. Colorado's program FAQ states this plainly: the Cures Act requires location only at the beginning and end of a visit, and the Colorado program collects it only at those two moments. GPS is the common method, but states also accept telephony (calling from the client's landline) and fixed devices in the home. Second, the six elements are a floor, not a ceiling. States and managed care plans layer their own rules on top: reason codes for manual edits, live-in caregiver exemptions, service code tables, and claims-matching windows.

The federal law also says the system must be minimally burdensome, must take into account existing best practices and EVV systems already in use, and must be conducted in accordance with HIPAA and other privacy requirements. That language is why most states allow agencies to keep a system they already had, as long as the data reaches the state.

The five state models, explained

CMS gave states operational control over how to implement EVV, and states settled into five recognizable models. Which model your state chose determines whether you can pick your own software, whether you must connect to a state aggregator, and who pays.

1. Provider choice

The state does not supply or recommend an EVV system. Each agency selects and pays for its own, and the state defines how the data must be submitted, often as fields on the claim itself. Washington is the clearest example: DSHS says it will not mandate which system is used and will not recommend one solution over another, and the required EVV elements are submitted with claims to ProviderOne, the state's data aggregator. New York calls its version the Choice Model and requires all providers and fiscal intermediaries to send data to the New York State EVV Data Aggregator.

2. State-mandated external vendor (closed model)

The state contracts with one vendor and every agency must use that vendor's system. There is no third-party option. Some states started here in 2019 and 2020 and later opened up; Mississippi, for instance, moved from a closed model to an open vendor model in 2023. Check your state's current page rather than an older list.

3. State-mandated in-house system

The state builds and operates the EVV system itself, usually inside its Medicaid management information system, and providers must use it. This is uncommon for agency-based care. Arizona recently brought the aggregator function in-house: effective October 1, 2025, AHCCCS stopped using Sandata as its EVV vendor and aggregator and now operates the AHCCCS EVV Aggregator directly, while still accepting data from alternate vendors that pass its review.

4. Open model (state solution plus alternate EVV)

The most common model. The state provides a system at no cost to providers and also runs a data aggregator. Agencies may use the free state system or keep their own third-party system, provided that system is certified to send the six data elements to the aggregator in the state's format. Ohio, Pennsylvania, Massachusetts, Colorado, Illinois, Michigan, North Carolina, Georgia, Florida (fee-for-service home health) and California all describe their programs this way, using terms like Alternate EVV, Alt-EVV, third-party EVV, or hybrid.

5. Managed care plan choice

In states that deliver most long-term care through managed care, the state may let each managed care organization pick its own EVV vendor or aggregator. Agencies contracted with several plans can end up submitting to more than one aggregator. Florida's personal care services and parts of Massachusetts and Iowa work this way, which is why vendor lists sometimes show a state as open for providers and closed for payers.

EVV requirements by state: 15 large states

Each row was checked against the state Medicaid agency's own EVV page or a state-published notice where one was available. Where the model label is the state's own word, it is used as written. Where only vendor sources were available, the row says so. EVV programs change vendors and rules regularly, so treat this as a starting point and confirm with your state before signing a software contract.

State	Model	State system / 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.

A pattern is visible: Sandata and HHAeXchange run the aggregator in most of these states, Netsmart runs Georgia's, and Washington and New York leave the software choice entirely to the agency. Even in states that supply a free system, that system is usually a visit-capture and reporting tool; Massachusetts notes that its Sandata system has no billing or payroll functions. Most agencies still need scheduling, payroll and billing software alongside it, which is the main reason third-party systems are so widely used.

What if you are private-pay only?

The federal mandate is a condition on Medicaid funding. If none of your visits are billed to Medicaid, Section 12006 does not require you to use EVV, and you have no state aggregator to report to. Check three things before relying on that: whether any state licensing rule for home care agencies independently requires electronic timekeeping, whether any Veterans Affairs, long-term care insurance, or Medicaid waiver contracts you hold add their own visit verification terms, and whether you plan to accept Medicaid clients in the next year or two.

In practice many private-pay agencies use EVV anyway, for reasons that have nothing to do with Medicaid:

Payroll accuracy. GPS-stamped clock-ins remove 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 the question before it is asked.
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, your caregivers are already in the habit and your data already has the six elements.

How to pick an EVV-capable system: a checklist

Whether your state is open, provider choice, or mandated, the software questions are similar. Use this list when evaluating a system or auditing the one you have.

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.
Offers more than one capture method. GPS on the caregiver's phone is standard; check whether the state also expects telephony or a fixed device for clients without a caregiver smartphone.
Works offline. Rural homes and apartment buildings lose signal. The app should store the punch locally and sync when a connection returns, keeping the original timestamp.
Flags exceptions instead of silently editing them. Early, late, missed, or out-of-range punches should be surfaced for a supervisor to approve with a reason code, because most states require reason codes on manual edits.
Records an audit trail. Who changed what, when, and why. State aggregators and managed care audits both ask for this.
Exports in your state's format, or connects to a vendor that does. In open-model states, confirm the vendor is certified or has completed integration with your specific aggregator (Sandata, HHAeXchange, Netsmart, or a state-run aggregator), not just certified somewhere.
Handles live-in and other exemptions. Several states, including California and Ohio, have live-in caregiver rules that change what must be captured.
Feeds payroll and billing. Approved visits should flow to payroll hours and to claims without re-keying, since re-keying is where EVV records and claims stop matching.
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.
Has a plan for change. Ask the vendor how they 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 Agency'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 of the visit. The app works offline and syncs the punch later with its original timestamp. Early and late punches raise approval flags for the office to review rather than being altered automatically, and approved visits export to payroll.

Hailo captures the six EVV data elements and exports them. Hailo does not currently claim to be a certified aggregator vendor in any state. If your state requires submission to a state aggregator, confirm the submission path with your state Medicaid agency or managed care plan and ask us how the exported visit data fits that path before you switch systems.

Disclaimer

Frequently asked questions

Does EVV apply to private-pay home care visits?

No. The federal requirement in Section 12006 of the 21st Century Cures Act applies to Medicaid-funded personal care and home health visits. Private-pay visits are outside it. Some agencies use EVV for all visits anyway for payroll accuracy and family trust, and a few states or contracts may impose 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 I keep my current scheduling software in an open-model state?

Usually yes, if the software (or a vendor it connects to) is certified to send the six data elements to your 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 common 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 notes 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.