Last updated: November 2026
An electronic visit verification (EVV) compliance program is an agency's written policy, exception procedure and reconciliation routine for the visit records that states require for Medicaid personal care and home health services. The federal requirement is Section 12006(a) of the 21st Century Cures Act, and each state sets how agencies comply. Integral Healthcare Solutions (IHS) is a consulting firm. It drafts the EVV policy, the exception and manual-edit procedure, the reconciliation checklist and the staff training for your approval, and your agency operates them.
This is compliance services work, one of three IHS practice lines. It is not legal advice, and IHS supplies no EVV software.
What does federal law require for electronic visit verification?
Federal law requires each state to implement EVV for Medicaid personal care and home health services that require an in-home visit by a provider. The Medicaid.gov EVV page (page opened 2026-11-04) says: "Section 12006(a) of the 21st Century Cures Act mandates that states implement EVV for all Medicaid personal care services (PCS) and home health services (HHCS) that require an in-home visit by a provider." The duty sits on the state; your obligations as an agency come from your state Medicaid agency.
The dates and the penalty on states
"States must require Electronic Visit Verification (EVV) use for all Medicaid-funded PCS by January 1, 2020 and HHCS by January 1, 2023." (Medicaid.gov EVV page). The statute reduces a state's Federal medical assistance percentage (FMAP) for quarters in which the state does not require EVV, on the schedule below (42 U.S.C. 1396b(l), page opened 2026-11-04). The reductions do not apply to a state that, as of December 13, 2016, already required an electronic verification system for both service types and keeps requiring it. A state that demonstrates to the Secretary a good faith effort and unavoidable system delays is exempt only for personal care in 2020 and home health in 2023.
| Service type | FMAP reduction by calendar year |
|---|---|
| Personal care services | 0.25 percentage points in 2020; 0.5 in 2021; 0.75 in 2022; 1 point in 2023 and each year after |
| Home health care services | 0.25 percentage points in 2023 and 2024; 0.5 in 2025; 0.75 in 2026; 1 point in 2027 and each year after |
The six data points
The statute defines an EVV system as one that electronically verifies, for each visit, the type of service performed, the individual receiving it, the date, the location of service delivery, the individual providing it, and the time the service begins and ends (42 U.S.C. 1396b(l)).
What the statute leaves to the state
The Cures Act says nothing in the section should be read to require a particular or uniform EVV system by all agencies or entities that provide these services (42 U.S.C. 1396b(l), note to section 1396b). Subject to the exceptions above, a state must consult agencies so the system is minimally burdensome, and give the people who furnish services the opportunity for training on it.
What have federal auditors found when EVV is weak?
HHS-OIG audited two states and found gaps between EVV records, claims and the six data points. The audits examined state agencies, not providers, and Colorado disagreed with most of OIG's findings.
Colorado, July 2026
In the OIG Colorado report A-07-24-03260 (issued 07/17/2026), OIG says that "Colorado implemented an EVV system but did not verify that all PCS visits were recorded and verified in that system." Of 160 sampled personal care net claim lines (OIG's unit), 91 had at least one EVV compliance issue, and some had more than one: 62 included manually entered visits, 17 included visits not entered into the EVV system, 16 lacked a documented service location, and 16 had unreviewed GPS exceptions. OIG estimated from its sample that 52 percent of claim lines in its sampling frame did not comply with Federal and State requirements, and, at the lower limit of a 90 percent confidence interval, that Colorado claimed at least 8,072,870 dollars (Federal share) in unallowable reimbursement for state fiscal year 2024. The estimate has several causes, including excessive units and rates paid, not only EVV gaps.
Kansas, August 2024
In the OIG Kansas report A-07-23-03255 (issued 08/20/2024), OIG found that Kansas "did not require all in-home PCS visits to be recorded and verified in that system and did not always comply with requirements when claiming in-home PCS". Nine of 105 sampled claim lines had an EVV compliance issue, among them four entered through a web portal and not verified in real time. Kansas agreed with all of OIG's recommendations.
What IHS takes from them
This is IHS's reading, not OIG's statement about agencies. Auditors look at hand-entry volume, whether each hand entry carries a reason, whether exceptions are reviewed, and whether every billed visit has a matching record. OIG's recommendations to Colorado are for a state, not rules for agencies; they include limits on manual entries and provider review of GPS exceptions and reason codes.
Who needs it and what triggers it
Medicaid personal care and home health agencies need an EVV program when any of these happens (IHS's observations, not federal text):
- The state launches or changes an EVV system or aggregator, and your procedures no longer match it.
- Manual edits pile up without documented reasons.
- Scheduling, EVV and billing records stop lining up.
How IHS helps
IHS writes the agency's EVV rules down so schedulers, caregivers and billers follow the same ones. Dr. Thomas G. Goddard, the founder of IHS, leads the work. These steps are IHS method:
- Gather your state's EVV instructions and vendor reports, and list what each requires of the agency.
- Draft the EVV policy: who captures visits, how, by when, and what happens when capture fails.
- Draft the exception and manual-edit procedure with reason codes, approvals and a review schedule.
- Build a reconciliation checklist that matches scheduled visits, EVV records and billed claims before claims go out.
- Draft staff training and a short competency check for caregivers, schedulers and billers.
- Run a mock review: IHS samples claims and your team produces the matching visit record, so gaps show before an auditor finds them.
What you supply. State EVV instructions, vendor access and reports, sample exceptions, and the schedulers and billers who run the process. Your leadership approves each document. Your vendor handles software settings, and your counsel handles contract and recoupment questions.
The real limit. Thresholds, exemptions and system rules vary by state, and IHS reads yours rather than assuming them. IHS does not deal with the state or the vendor for you. Your agency files, sends and signs whatever the state requires.
What to have ready
Each item ties to the six statutory data points (42 U.S.C. 1396b(l)) or to your state's layer.
- A list of your Medicaid personal care and home health services, matched to the program types the Medicaid.gov EVV page names.
- Your state Medicaid agency's current EVV instructions.
- The EVV system or aggregator you use, with access and reports.
- A sample of recent exceptions and manual edits, with the reason for each.
- A note of how each of the six data points is captured today.
- The names of the schedulers and billers who touch visit data.
- Your latest comparison of scheduled visits, EVV records and claims, or a note that none exists.
- Counsel's contact for contract and recoupment questions.
The free introductory call is the next step for turning that list into a program.
How it compares
EVV set-ups differ by who runs the system.
| Model | What the sources show | What the agency program has to cover |
|---|---|---|
| State-operated or state-contracted system | Colorado offers a free contracted system (OIG Colorado report A-07-24-03260) | State portal procedures, state exception lists, state-defined reason codes |
| Provider-chosen system | Colorado allows it if technical and program requirements are met (OIG Colorado report A-07-24-03260); no single system is required of all agencies (42 U.S.C. 1396b(l)) | Vendor settings, data transmission to the state, your own exception monitoring |
Vendor software builds in edits that stop mechanical errors. It does not write the policy on who may override an edit and why. IHS builds that policy; your vendor supplies the software.
What it costs
Authority fees: the federal sources we opened publish no fee for agencies. Check your state and your vendor for system or aggregator charges.
Consulting: IHS scopes each engagement after a free introductory call, and this page carries no IHS figure. Scope moves with the programs you bill, the sites, the EVV systems you touch and the exceptions in your records.
Internal staff time: schedulers, billers, caregivers and your compliance lead will spend time on training, exception review and reconciliation.
What this is not
- It is not legal advice and not a statement of your state's rules. IHS is a consulting firm, not a law firm.
- It is not EVV software, and IHS does not configure or sell any.
- It is not a guarantee about audits, claims or state decisions, and IHS does not deal with your state or your EVV vendor. Your agency does.
Frequently asked questions
What does the Cures Act require for electronic visit verification?
Section 12006(a) requires states to implement EVV for Medicaid personal care and home health services that require an in-home visit by a provider (Medicaid.gov EVV page, page opened 2026-11-04). The duty is on the state, so your state Medicaid agency tells agencies what to do.
When did electronic visit verification become required?
States must require EVV use for Medicaid-funded personal care services by January 1, 2020 and for home health services by January 1, 2023, per the Medicaid.gov EVV page. Both dates have passed.
What happens to a state that misses the EVV requirement?
Its Federal medical assistance percentage is reduced, by 1 percentage point a year for personal care from 2023 and for home health from 2027 (42 U.S.C. 1396b(l), page opened 2026-11-04). The statute exempts a state that already required a system for both service types on December 13, 2016, and, for one year per service type, a state that demonstrates to the Secretary a good faith effort and unavoidable system delays.
What data does an EVV system have to capture?
Six points per visit: type of service, individual receiving it, date, location, individual providing it, and start and end time (42 U.S.C. 1396b(l)). Your state may add requirements, so its instructions control the detail.
Do we have to use the state's EVV system?
Federal law does not require one uniform system for all agencies (42 U.S.C. 1396b(l), note to section 1396b). Colorado offers a free contracted system and lets providers use their own if it meets technical and program requirements (OIG Colorado report A-07-24-03260, page opened 2026-11-04). Your state's instructions answer this.
Why do manual edits draw audit attention?
In Colorado, OIG found manual entries could not be electronically verified on the six data points and the state had no edits limiting them (OIG Colorado report A-07-24-03260). OIG audited the state, not an agency. That auditors watch manual-edit volume is IHS's reading.
What is an EVV exception procedure, and why keep reason codes?
It says who may change or add a visit record, when, and with what approval. A reason code with a usable note makes each change explainable later. This is IHS method, built around your state's code list.
What does Integral Healthcare Solutions (IHS) draft, and does IHS deal with the state or the vendor?
IHS drafts the EVV policy, exception and manual-edit procedure, reconciliation checklist and staff training for your approval. IHS does not deal with the state or the vendor and supplies no software. IHS scopes each engagement after a free introductory call.