The technology market offers no shortage of solutions that could meet the new requirements. But for agencies with more progressive strategies, the Cures Act is a timely backdrop to think more broadly, and seize an opportunity to differentiate service.
The federal EVV deadlines for personal care and home health services have passed, including the extensions. If you’re in a state with an open or provider choice mandate, the decision now is which caregiver mobile app meets your state’s EVV requirements.
The AlayaCare platform is an end-to-end, cloud-based platform with an incorporated mobile, GPS-based EVV that works across every module. Don’t let accountability get in the way of providing better client outcomes.
EVV requirements for caregiver mobile apps
The 21st Century Cures Act requires caregiver mobile apps used for Medicaid visits to capture six data points. Those six data points are the federal minimum for personal care and home health visits. Your state’s EVV model and vendor rules decide which app your caregivers can use.
In its 2018 CMS guidance on Section 12006, the Centers for Medicare & Medicaid Services (CMS) says every EVV system must electronically verify:
- Type of service performed
- Individual receiving the service
- Date of the service
- Location of service delivery
- Individual providing the service
- Time the service begins and ends
The CMS EVV implementation timeline sets two federal deadlines. States had to implement EVV for personal care services (PCS) by Jan 1, 2020 and for home health care services (HHCS) by Jan 1, 2023. CMS good-faith extensions gave states that applied up to one more year: Jan 1, 2021 for PCS and Jan 1, 2024 for home health.
The penalty for missing those deadlines falls on states. According to the CMS FAQ on Section 12006, states face reductions of up to 1 percentage point in federal Medicaid match. For home health, the cut is 0.25 points in 2023–2024 and rises to 1 point from 2027.
Providers don’t pay that federal penalty, but they still face their state’s claim rules.
CMS identifies five state EVV models: provider choice, managed care plan choice, state-mandated in-house, state-mandated external vendor, and open vendor, which CMS calls a hybrid. CMS endorses none of them. Your state’s model decides which apps your caregivers can use.
Beyond the federal floor, EVV compliance requirements vary by state model, aggregator, and covered services. States are adding performance thresholds on top of the federal minimum. For example, Michigan’s Medicaid EVV rules set an 85% auto-verified threshold per quarter, per payer, effective Apr 1, 2026.
Does EVV track caregiver location?
EVV captures caregiver location at the start and stop of each visit, and that meets the federal minimum. Federal rules don’t require GPS or continuous tracking of caregivers as they move through the community. States may still require more location data.
The same CMS guidance on Section 12006 states “there is no requirement to use global positioning services (GPS).” CMS adds that capturing the location where service starts and stops meets the Cures Act minimum. Interactive Voice Response (IVR) is a common alternative to GPS.
A CMS presentation on EVV quality monitoring confirms that continuous tracking of caregivers “is not required.” CMS also lets states require more information to control fraud, waste, and abuse. Check your state’s rules before you choose an app.
Introducing AlayaCare’s Electronic Visit Verification (EVV) solution
AlayaCare’s EVV solution captures GPS-enabled or IVR (telephony) verification for every visit and sends date and time stamped visit reports to the office. Meet state EVV mandates and get reliable proof of every visit with AlayaCare’s EVV solution.
With this new feature, your agency can:
- Gain reliable proof of visit
- Increase compliance and efficiency
- Capture GPS-enabled verification or IVR (telephony)
- Generate date and time stamped visit reports
- Create and receive real-time schedule updates
- Categorize and analyze visit data with advanced reporting
- Benefit from secure communication between caregivers and the office
Agency challenges and how AlayaCare EVV solves them:
Home care agencies face four recurring EVV challenges: paper-based check-ins, missing mobile apps, caregiver travel to remote or unfamiliar areas, and slow post-visit quality assurance. Each challenge below is paired with how AlayaCare EVV solves it.
Challenge #1
Many organizations still don’t have an adequate software solution that enables caregivers to check in to client visits or submit real-time data to remain compliant with state EVV mandates. Home care continues to be labor intensive largely because several stakeholders remain loyal to the paper world.
Solution
AlayaCare is an end-to-end software platform with a fully integrated and compliant EVV solution that allows caregivers to document their visits in real-time, at the point of care, so supervisors can track activity as it happens. North Country Home Services reached 95% EVV with AlayaCare. If you’re in an open or provider choice state, AlayaCare could be the solution for you.
Challenge #2
Many software vendors don’t offer a mobile app resulting in tedious EVV workarounds. Some organizations are finding the need to outsource to a third party EVV vendor which can be quite costly.
Solution
AlayaCare’s integrated EVV solution is built into our native mobile app, with one-tap clock-in and clock-out and GPS verification. Caregivers can clock in and out only when they’re within the approved radius of the client’s home during the scheduled visit.
An offline mode covers areas out of cellular or Wi-Fi range. IVR is available in multiple languages and dialects, and the app supports more than 10 languages.
Challenge #3
Many caregivers, particularly those working in remote areas but also for some in urban centers, often travel extensive distances or into unfamiliar neighborhoods. For these caregivers, EVV does double duty: it records the visit for compliance and tells the home office where they checked in.
Solution
Aside from remaining compliant, being able to offer peace of mind that the home office can check in and verify location in real-time is a subtle, but real, added perk for top talent.
Challenge #4
Some home care EVV solutions lack critical Quality Assurance resulting in hours of post-visit data validating. Without automated QA rules, office staff check clock-in times, visit durations, authorizations, and GPS exceptions one visit at a time.
Solution
The HHS Office of Inspector General EVV audits include a July 2026 single-state review of Colorado’s personal care services. That audit recommended Colorado adopt edits “that require providers to review and then correct GPS exceptions.” AlayaCare’s audit-ready compliance workflows flag those exceptions for review using configurable EVV QA rules and exception flags.
AlayaCare has built in QA best practices. Business rules and logic streamline the approvals process. Visits that violate logic are flagged as red. Agencies can adjust certain settings for automated approval:
- Start time allowance (what is the permitted clock-in time vs. scheduled start time)
- Visit duration (what is the percentage of time completed vs. scheduled time)
- Authorizations (was a visit within the limits of the payer)
- GPS/Telephony exceptions (are there differences between GPS distance and a client’s address)
- Tasks completed (what constitutes a required task that is finished)
AlayaCare EVV software solution
AlayaCare’s EVV feature gives your agency GPS or IVR verification and date and time stamped visit reports in one integrated system. Whether your agency is currently operating on paper documentation or you’re working on a dated legacy solution, AlayaCare could be the solution you’ve been looking for.
Learn more about how we can help drive your organization forward.
Frequently asked questions
According to CMS guidance on Section 12006 of the 21st Century Cures Act, an EVV system must electronically verify six elements. They are the service type, the person receiving it, the date, the location, the person providing it, and start and end times. That’s the federal minimum, and your state’s model and vendor rules decide which app you may use.
EVV records location when a visit starts and stops. A CMS presentation on EVV quality monitoring confirms continuous tracking “is not required,” though states may require more. In the AlayaCare mobile app, caregivers can clock in and out only within the approved radius of the client’s home during the scheduled visit.
Per to CMS guidance on Section 12006, “there is no requirement to use global positioning services (GPS).” CMS names Interactive Voice Response (IVR) as a common alternative. States can set stricter rules, so confirm what your state Medicaid program requires before you choose a system.
The penalty falls on the state. Per the CMS FAQ on Section 12006, states that miss the deadline face reductions of up to 1 percentage point in federal Medicaid match. For home health, the cut is 0.25 points in 2023–2024 and rises to 1 point from 2027. Providers don’t pay that penalty, but they still face their state’s claim rules.
States choose from five EVV models: provider choice, managed care plan choice, state-mandated in-house, state-mandated external vendor, and open vendor. CMS calls the open vendor model a hybrid and endorses none of them. Check your state Medicaid agency’s EVV page to see which model applies and whether you can pick your own app.
Yes. AlayaCare’s mobile app includes an offline mode for areas out of cellular or Wi-Fi range. Clock-in and clock-out still work only within the approved radius of the client’s home during the scheduled visit. Caregivers can also use IVR in multiple languages and dialects, and the app supports more than 10 languages.
Updated , originally published