Why EVV Compliance Still Trips Up Home Care Agencies
Under the 21st Century Cures Act, all Medicaid personal care and home health services must use an Electronic Visit Verification (EVV) system to record key visit details who provided care, to whom, when, and where (CMS, 2023).
While most agencies have adopted EVV software, compliance lapses still happen when systems aren’t consistently audited or integrated with staff supervision protocols.
CMS and state Medicaid agencies have noted that the most common EVV deficiencies include:
- Missing or mismatched visit timestamps
- GPS data not aligning with the client’s service address
- Incomplete caregiver credentials or unverified identity
- Visit edits without documented justification
These issues may seem minor but can lead to Medicaid recoupments, civil monetary penalties, and even provider disenrollment.
Supervision Rules: More Than Just a Signature
Every Medicaid home care program requires supervisory oversight of direct care staff. But the frequency and documentation standards vary:
Personal Care Services (PCS) often require RN or supervisor visits at least every 90 days.
Skilled Nursing or Home Health Aides under Medicare-certified agencies must have supervisory assessments every 14 to 60 days depending on service type.
Some states like Georgia, Virginia, and Texas mandate in-person supervision within the first 30 days of service initiation.
Even if EVV records a visit, missing supervision notes can still create compliance findings. EVV confirms time, but supervision confirms quality.
How to Strengthen Your EVV and Supervision Program
1. Conduct Quarterly Internal EVV Audits
Compare EVV logs to service documentation and billing records. Look for inconsistencies like overlapping shifts, late visit approvals, or missing signatures.
If you find more than 5% mismatches per quarter, that’s a sign your policies or staff training need tightening.
2. Align Policies and Training
Update your internal policies to match your state’s EVV system (e.g., Sandata, HHAeXchange, AuthentiCare). Each platform has slightly different data and compliance fields.
3. Require Supervisor Verification
Implement a checklist for supervisory visits:
- Confirm EVV location data matches the service site.
- Review caregiver documentation for completeness.
- Note any client condition changes.
- Sign electronically within 48 hours.
4. Integrate EVV Data with Payroll and Billing
This reduces manual data entry errors. CMS recommends using systems that sync time and attendance data directly into your billing platform (CMS, 2023).
5. Schedule a Compliance Review
Quarterly reviews with an external consultant or compliance officer help identify blind spots and verify documentation readiness before a Medicaid audit.
Example: Common EVV Audit Finding
An agency in Virginia had 15% of visits missing caregiver GPS verification because their staff used “manual clock-ins” during service outages. Result: State Medicaid auditors disallowed all affected claims, totaling $47,000 in overpayments.Lesson: Agencies must document every manual correction and ensure backup verification procedures are clearly written in policy.
FAQ
It records the caregiver, client, service date, start/end time, and location, proving that care was delivered as billed.
Document the outage, collect a signed paper timesheet, and upload it with supporting notes within 24 hours. Keep a copy for audit purposes.
Yes, for Medicaid-funded personal care and home health services. Private-pay services are typically exempt unless bundled with Medicaid billing.
Sources
- Centers for Medicare & Medicaid Services (CMS). EVV Fact Sheet for States, 2023.
- HHS Office of Inspector General (OIG). EVV Implementation and Compliance Review, 2022.
- National Association for Home Care & Hospice (NAHC). Home Care Supervision Standards, 2024.
Next Step:
Magnate Consulting helps home care agencies stay compliant with EVV, supervision, and Medicaid documentation requirements. From internal audits to staff training and corrective actions, we help agencies strengthen compliance and prevent costly errors.
