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Federally mandated electronic verification of Medicaid home visits
The federally mandated electronic system under Section 12006 of the 21st Century Cures Act that captures six required data elements at the point of care — service type, recipient, date, location, caregiver, and start/end time — to confirm Medicaid-funded personal care and home health visits occurred, with states facing escalating FMAP penalties for missing implementation deadlines.
Electronic Visit Verification (EVV) is a federally mandated system that electronically confirms a Medicaid-funded home visit actually happened. Section 12006 of the 21st Century Cures Act requires every state to use EVV for Medicaid personal care services (PCS) and home health care services (HHCS) that require an in-home visit [1].
EVV captures six data elements at the point of care, each set by statute: the type of service performed, the individual receiving the service, the date of service, the location of service delivery, the individual providing the service, and the time the service begins and ends [2]. Agencies collect these via mobile app, telephony, or fixed device and transmit them to the state's EVV aggregator, where each visit is matched against the claim. Federal compliance deadlines run by service type. States had to require EVV for Medicaid PCS by January 1, 2020, and for HHCS by January 1, 2023. The mandate reaches PCS delivered under Social Security Act sections 1905(a)(24), 1915(c), 1915(i), 1915(j), 1915(k), and 1115, and home health services under section 1905(a)(7). Non-compliance triggers an escalating Federal Medical Assistance Percentage (FMAP) reduction against the state. For PCS, the reduction is 0.25 percentage points for 2019 and 2020, 0.5 points for 2021, 0.75 points for 2022, and a full 1 percentage point for 2023 and every year after. For HHCS, a parallel schedule runs 0.25 percentage points in 2023, 0.5 in 2024, 0.75 in 2025, and 1 percentage point for 2026 and each year after. A state that documented a "good faith effort" but encountered unavoidable delays could receive a one-year reprieve from the reduction. CMS lets each state pick an implementation model — provider choice, MCO choice, a state-mandated in-house or single-vendor system, or an open model — without endorsing any vendor.
EVV enforcement has moved from the state's FMAP exposure down to the individual claim line. In most states an unverified or exception-flagged visit will not adjudicate, so a high manual-edit rate is effectively a denial pipeline that ties up cash. EVV match rate functions as a core RCM metric: every visit that requires a manual reason code is a visit at risk of recoupment on audit. Because the six data elements and the penalty framework are federal but the system model, exception rules, and acceptable reason codes are set state by state, a multi-state operator cannot run one EVV playbook — denial and clawback risk concentrates in the states with the worst-performing exception resolution.
No — the federal mandate applies only to Medicaid-funded personal care and home health services. Many agencies still extend EVV to all payers for operational consistency, and Medicare Advantage or managed Medicaid plans may impose their own visit-verification terms by contract.
In most states the claim will not pay until the visit is matched or the exception is corrected. Persistent manual overrides also flag the agency for post-payment review, where unverified visits are prime recoupment targets.
Personal care services under Social Security Act sections 1905(a)(24), 1915(c), 1915(i), 1915(j), 1915(k), and 1115, plus home health services under section 1905(a)(7).
Only through an approved good-faith-effort request, which grants a one-year reprieve when the state shows it adopted the technology but hit unavoidable delays.
Vitalis Care is the end-of-life care app that helps hospices deliver compassionate care — while staying on top of schedules, field operations, documentation, compliance, and reimbursement.
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