The 21st Century Cures Act requires EVV for all Medicaid personal care and home health services delivered in a patient's home. Every state has implemented it — but they haven't all implemented it the same way. The system your state uses, the model it operates under, and the exceptions it generates all determine what EVV compliance costs your agency each month.
Congress passed the 21st Century Cures Act in December 2016 to address concerns about Medicaid fraud in home and community-based care. The EVV mandate is one of the act's most operationally significant requirements for home care agencies — not because compliance is complex, but because non-compliance has a direct and immediate impact on billing.
EVV required for all Medicaid-funded personal care services delivered in a patient's home. States that failed to implement by this date faced federal matching fund reductions.
EVV extended to home health services — skilled nursing visits, physical therapy, and other home health disciplines with an in-home service component.
Type of service, individual receiving services, individual providing services, date of service, location of service, and time the service begins and ends.
EVV is not documentation software. It is a real-time verification system — every visit must be confirmed at the moment it happens, not reconstructed afterward. Each of the six required data elements ties directly to claim validation. A gap in any one of them creates an exception that blocks billing.
The specific service code must match the authorized service type in the state billing system. A mismatch between the EVV service code and the authorization is one of the most common exception triggers.
The client or participant identifier in the EVV record must match an active Medicaid authorization. Visits outside an active authorization window generate exceptions regardless of whether care was delivered.
The caregiver clocking in must be enrolled, credentialed, and active in the state billing system. A lapsed certification or an unenrolled caregiver identity blocks the EVV record from validating.
The visit date must fall within the active authorization period. Reauthorization gaps — periods where authorization has expired and not yet been renewed — create exceptions for every visit in the gap window.
GPS coordinates captured at clock-in and clock-out must match the approved service address within an acceptable radius. Caregivers who clock in from vehicles, neighboring addresses, or facilities trigger GPS-mismatch exceptions.
Visit start and end times must be captured at the point of care, not entered manually after the fact. Retroactive time entries require manual exception correction and carry audit exposure in states with strict enforcement.
States implement EVV under one of three structural models. The model determines which system you must use, how much flexibility you have in capturing visit data at the point of care, and where exceptions must be resolved before billing.
The state designates a required aggregator — all EVV data must flow to that system. Agencies may use any compliant EVV tool for point-of-care capture, provided data reaches the state aggregator in the required format. The aggregation requirement is non-negotiable; the capture method has flexibility.
A designated aggregator is required, with some structured flexibility in how visit data is captured. Some hybrid states allow alternative capture tools with integration requirements; others layer MCO-specific requirements on top of the state aggregator. More operationally complex than Open.
The state requires agencies to use a specific system for both visit capture and aggregation. No approved alternative tools. The state system is the only compliant option. Agencies must use the designated system directly — there is no integration pathway from a third-party tool.
States with dedicated CareBravo EVV pages are linked below. All other states show the verified aggregator and model for reference. EVV requirements can change as states respond to CMS guidance and contract renewals — always verify current requirements directly with your state Medicaid agency for billing-critical decisions.
| State | EVV System / Aggregator | Model | Notes |
|---|---|---|---|
| Alaska ↗ | Therap | Hybrid | ALI waiver context. Telephony recommended for low-connectivity areas. |
| Arizona ↗ | AHCCCS In-House | Open | Transitioned from Sandata to AHCCCS in-house system October 2025. Agencies that haven't updated integrations need immediate action. |
| Arkansas ↗ | AuthentiCare (PCS) / Sandata (HHCS) | Open | Two separate systems by service type. Agencies billing both PCS and home health must manage two exception queues. |
| California ↗ | Sandata (CalEVV) | Hybrid | State-managed CalEVV portal built on Sandata. Applies to IHSS and MSSP programs. Verify IHSS phased rollout status with CDSS. |
| Colorado ↗ | Sandata | Hybrid | HCPF administers. EBD waiver. Sandata is the state-designated aggregator. |
| Connecticut ↗ | Sandata | Hybrid | HUSKY Health program. CHCPE community care context. |
| Delaware ↗ | Sandata | Hybrid | Diamond State Health Plan Plus. Small-market agencies carry proportionally heavier exception burden per staff member. |
| D.C. | Sandata | Hybrid | DC DHCF. Sandata aggregator for Medicaid home care services. |
| Florida ↗ | Netsmart / HHAeXchange / Coastal Care | Payer Choice | Payer-choice model. Required system varies by MCO and plan. Verify required system with each payer you contract with before first claim submission. |
| Georgia ↗ | Netsmart (formerly Tellus) | Open | GAMMIS billing system. CCSP and SOURCE waiver programs. DBHDD credentialing required for waiver services in addition to GAMMIS enrollment. |
| Hawaii ↗ | Sandata | Open | Med-QUEST program. Telephony options for connectivity-variable island service areas. |
| Idaho ↗ | Sandata | Provider Choice | IDHW. Provider choice does not mean compliance flexibility — Sandata aggregation required for all approved tools. |
| Illinois ↗ | HHAeXchange | Hybrid | CCP (Dept on Aging / CCU authorizations) and HSP (DHS participant-directed). HFS billing. CCU reauthorization tracking is the highest-value operational task for CCP agencies. |
| Indiana ↗ | Sandata | Open | FSSA. A&D waiver and TBI waiver context. |
| Iowa ↗ | CareBridge | Managed Care Choice | Iowa HHS. Verify required system with each managed care plan. CCW and NOW waivers. |
| Kansas ↗ | AuthentiCare (Fiserv) | Provider Choice | KDHE/KDADS. FE, PD, and TBI waiver programs. |
| Kentucky ↗ | Therap | Hybrid | CHFS. Model Waiver, SCL, and Michelle P. Waiver programs. |
| Louisiana ↗ | LaSRS (Statistical Resources, Inc.) | Open | LaSRS is Louisiana's state-specific system — not Sandata or HHAeXchange. CCW and NOW waiver context. Tasha's state — Louisiana Medicaid guide → |
| Maine ↗ | Sandata | Open | MaineCare branding. DHHS. |
| Maryland ↗ | ISAS (In-Home Supports Assurance System) | State Mandated | ISAS is both the capture system and the aggregator — no third-party capture tools accepted. Community Pathways, CSLA, and HCBO waivers. |
| Massachusetts ↗ | Sandata | Hybrid | MassHealth/EOHHS. PCA program has participant-directed components — verify current EVV applicability with EOHHS. |
| Michigan ↗ | HHAeXchange | Open | Final transition phase 2024–2026. Agencies not yet enrolled need immediate action. Verify current enrollment status with MDHHS. |
| Minnesota ↗ | HHAeXchange | Open | DHS. Medical Assistance branding. PCA Choice/fiscal agent structure. BI, CADI, and DD waivers. |
| Mississippi ↗ | HHAeXchange | Open | DOM. Independent Living Waiver context. |
| Missouri ↗ | Sandata | Open | MO HealthNet branding. ADW and Comprehensive Waivers. |
| Montana ↗ | Sandata | Open | Frontier geography — telephony recommended for low-connectivity rural service areas. EPPD and Big Sky waivers. |
| Nebraska ↗ | Netsmart | Open | Nebraska's Netsmart instance is separate from Georgia's GAMMIS-integrated deployment — verify Nebraska-specific requirements directly with DHHS. |
| Nevada ↗ | Sandata | Open | DHCFP. Frail Elderly and Community-Based Care waivers. Rural service area coverage note. |
| New Hampshire ↗ | AuthentiCare (Fiserv) | Open | DHHS. CFI and ABD waiver programs. |
| New Jersey ↗ | HHAeXchange | Open | DMAHS/DHSS. Personal Preference Program context. High-density market — exception volume scales significantly at 90+ patients. |
| New Mexico ↗ | AuthentiCare (Fiserv) | State Mandated | AuthentiCare required for both capture and aggregation — no third-party tools. Mi Via and DD waiver programs. |
| New York ↗ | HHAeXchange / CareBridge / eMedNY | Provider Choice | Multi-MLTC complexity. HHAeXchange most widely used. eMedNY is the fee-for-service pathway. Verify required system with each MLTC plan. |
| North Carolina ↗ | Sandata (Direct) / HHAeXchange (MCOs) / CareBridge (Healthy Blue) | Hybrid | Multi-aggregator state. Sandata for Medicaid Direct; HHAeXchange for most LME/MCOs (Vaya, Alliance, Trillium); CareBridge specifically for Healthy Blue. Wrong system = wrong aggregator for that claim. |
| North Dakota ↗ | Sandata | Open | Frontier geography considerations similar to Montana. Basic Care and A&D waivers. |
| Ohio ↗ | Sandata | Open | ODM + ODA dual agency. PASSPORT Waiver is Ohio's largest HCBS program, administered through Area Agencies on Aging. |
| Oklahoma ↗ | AuthentiCare / HHAeXchange | Hybrid | Dual system by service type. Verify required system by service line. ADvantage and Homeward Bound waivers. |
| Oregon ↗ | eXPRS Mobile-EVV | Provider Choice | State-built system integrated into eXPRS billing platform — not Sandata or HHAeXchange. National vendor integrations do not transfer. K Plan (1915(k)) and ODDS programs. |
| Pennsylvania ↗ | Sandata (FFS) / HHAeXchange (some MCOs) | Open | Payer-split. Sandata for fee-for-service; specific HealthChoices MCOs may require HHAeXchange. Wrong-system submissions surface at billing, not capture. |
| Rhode Island ↗ | Sandata | Open | EOHHS. Global Consumer Choice Compact and Community Supports waivers. |
| South Carolina ↗ | AuthentiCare (Fiserv) | State Mandated | Direct-use mandate — no third-party capture tools. Community Supports and HASCI waivers. |
| South Dakota ↗ | Therap | Open | Tribal reservation and frontier service areas. Telephony recommended for remote connectivity. DSSF and EDAC waivers. |
| Tennessee ↗ | Sandata (agency) / PPL (self-directed) | Hybrid | Agency-directed care uses Sandata; PPL for self-directed participants. CHOICES and Employment and Community First CHOICES programs. |
| Texas ↗ | TMHP (State) / HHAeXchange (MCOs) | Hybrid | Hard-edit enforcement active as of 2026 — unmatched claims auto-denied at TMHP. Most STAR+PLUS and STAR Kids MCOs require HHAeXchange. Verify per MCO plan. |
| Utah ↗ | DHHS In-House | Provider Choice | State-built system — not Sandata or HHAeXchange. National integrations do not apply. Aging, Physical Disability, and MAP waivers. |
| Vermont ↗ | Sandata | Open | DVHA/AHS. Green Mountain Care program context. |
| Virginia ↗ | Provider Choice (approved vendor list) | Provider Choice | No single state vendor. Agencies select from the DMAS-approved vendor list. Verify current approved options directly with DMAS — the list is updated periodically. |
| Washington ↗ | ProviderOne | Provider Choice | HCA ProviderOne is Washington's Medicaid claims system. EVV data must transmit through ProviderOne. COPES and DDA waiver programs. |
| West Virginia ↗ | HHAeXchange | Open / Hybrid | BMS. HHAeXchange required for West Virginia Medicaid home care EVV. |
| Wisconsin ↗ | Sandata | Open | DHS. Family Care and IRIS waiver programs. |
| Wyoming ↗ | CareBridge | Open | DHSS. Home-based waiver programs. CareBridge is the state aggregator. |
Data current as of early 2026. EVV requirements change as states respond to CMS guidance, system contracts expire, and programs evolve. Arizona completed a major transition from Sandata to an AHCCCS in-house system in October 2025. Texas moved to hard-edit enforcement in early 2026. Michigan completed its transition to HHAeXchange through 2024–2026. Always verify current requirements directly with your state Medicaid agency or managed care organization for any billing-critical operational decision.
EVV compliance isn't a regulatory overhead cost. It's a billing prerequisite. An unresolved exception is an undelivered payment — not a compliance flag. The dollar figure is predictable, and it scales with patient volume.
Estimated monthly revenue loss from EVV exceptions, lapsed caregiver credentials, and documentation gaps that block claim submission at 30 active patients. This is one of three CareDrain vectors.
The exception rate stays consistent as agencies grow. Revenue loss scales with visit volume. Exception management that worked at 30 patients breaks at 90 without a systematic process.
Compliance drain is one of three revenue loss vectors. Authorization drain (~$2,400) and claims drain (~$1,100) typically account for the remaining loss. Most agencies lose across all three simultaneously.
The exception that compounds: An unresolved EVV exception doesn't sit in a queue waiting to be fixed indefinitely. Every state has a correction window — after which, the visit becomes permanently unbillable. At 30 patients with a 5% unresolved exception rate, that's roughly $600 per month leaving the agency permanently. The dollar figure doesn't show up in any single denial. It shows up in the gap between what your agency delivered and what it collected.
The figures above are averages derived from CareBravo agency data. Your actual number depends on your patient count, your payer mix, your state's EVV system, and the specific gaps in your current process. The CareDrain Diagnostic quantifies all three revenue loss vectors for your agency in about three minutes — and the PDF profile is yours to keep without a sales call.
Run the Free Diagnostic →Eight questions about your current billing, authorization tracking, and compliance systems. Your estimated monthly drain — broken down by authorization drain, claims drain, and compliance drain — delivered to your inbox.
EVV is a technology-based system that records when and where Medicaid home care visits occur. It captures six required data elements at the point of care: type of service, individual receiving services, individual providing services, date of service, location of service, and time the service begins and ends. Federal law requires EVV for all Medicaid-funded personal care services and home health services delivered in a patient's home.
The 21st Century Cures Act (signed December 2016) requires all state Medicaid programs to implement EVV. The mandate for personal care services took effect January 1, 2020. The mandate for home health services took effect January 1, 2023. States that failed to implement compliant systems by these dates face reductions in federal Medicaid matching funds (FMAP). All 50 states and D.C. now have EVV in place.
No. States made independent decisions about EVV implementation. The most common aggregators are Sandata and HHAeXchange, but many states use Netsmart, AuthentiCare, Therap, LaSRS, CareBridge, ProviderOne, or state-built systems. Some states (Florida, New York, North Carolina) use different systems for different payers. Several states (Maryland, New Mexico, South Carolina) mandate a specific system with no alternatives. The table above lists the verified aggregator and model for all 50 states and D.C. as of 2026.
Open: a required aggregator, flexible capture method. Agencies may use any compliant EVV tool provided data reaches the state aggregator. Hybrid: a required aggregator with structured flexibility — often adds MCO-specific requirements on top of the state aggregator. State Mandated: agencies must use a specific system for both capture and aggregation, no approved alternatives. The model determines how much flexibility you have and whether a third-party tool integration is compliant in your state.
CareBravo delivers EVV compliance as part of its operational output — clock-in verification, GPS validation, state aggregator transmission, and exception resolution are managed continuously rather than surfaced for your team to work. CareBravo integrates with state-required EVV systems (Netsmart, HHAeXchange, Sandata, and others) and manages exception queues before billing windows close. Your team doesn't monitor exception queues or investigate individual visit discrepancies — that work is delivered as completed operational output.
A visit with an unresolved exception cannot be billed. If the exception is not resolved before the state's correction window closes, the visit becomes permanently unbillable — regardless of whether care was delivered and documented. In states with hard-edit enforcement (such as Texas as of 2026), unmatched claims are automatically denied at the state aggregator level without reaching a reviewer. The correction window varies by state, but it is always finite. Exception management is not optional — it is the difference between a delivered visit and a paid visit.
Most agencies that lose money to EVV exceptions lose far more to authorization drain and unworked claim denials. The CareDrain Diagnostic quantifies all three vectors for your agency — so you know exactly what's recoverable and where the biggest dollar opportunity is.