Texas EVV Compliance Guide for Home Care Agencies

What Is Electronic Visit Verification (EVV)?

Electronic Visit Verification (EVV) is a technology-based system that records when and where home care services are delivered. Every visit a caregiver makes to a client's home must be electronically verified — capturing the caregiver's identity, the client being served, the type of service provided, the location of the visit, and the precise start and end times.

EVV was mandated at the federal level by the 21st Century Cures Act (2016), which required all states to implement EVV for Medicaid-funded personal care services (PCS) and home health care services (HHCS). Failure to comply triggers a reduction in federal Medicaid matching funds — first 0.25%, rising to 1% by year 4.

For Texas home care agencies, EVV is not optional. It is a legal requirement to receive Medicaid reimbursement, and non-compliance directly threatens your revenue and your agency's operating license.

Texas HHSC EVV Requirements

The Texas Health and Human Services Commission (HHSC) oversees EVV implementation for the state. Texas uses a hybrid model — agencies can use either the state's free EVV system (provided by Sandata Technologies) or an approved Alternative EVV (AltEVV) system, as long as it meets HHSC specifications and transmits data to the state aggregator.

The Six Required Data Points

Every EVV record must capture the following six elements for each visit:

1. Type of service performed — the specific service code (e.g., personal care, respite, habilitation)
2. Individual receiving the service — the Medicaid recipient's ID
3. Date of service — the calendar date the visit took place
4. Location of service delivery — GPS coordinates or verified address of where the service was delivered
5. Individual providing the service — the caregiver's identification (NPI, employee ID, or state-assigned number)
6. Time service begins and ends — exact clock-in and clock-out times

Approved Visit Verification Methods

Texas HHSC accepts multiple methods for capturing EVV data, but each method must be used consistently and produce auditable records:

• GPS-enabled mobile app — caregiver uses a smartphone app to check in/out at the client's location (most common and preferred method)
• Fixed telephony — caregiver calls from the client's landline phone to verify presence at the home
• Electronic device at the home — a fixed device installed at the client's residence
• Biometric device — fingerprint or other biometric confirmation at point of care

Mobile app-based GPS verification is the dominant method for most Texas agencies due to cost and ease of deployment. However, any method must comply with HHSC's technical specifications and data transmission requirements.

Key Deadlines and Compliance Timeline

Both the PCS and HHCS deadlines have passed. As of 2026, Texas HHSC is in active enforcement mode — agencies without compliant EVV systems face claim denials, recoupments, and potential termination from the Medicaid program.

Common EVV Compliance Gaps Texas Agencies Miss

After working with dozens of Texas home care agencies, these are the compliance failures that show up most frequently — and the ones auditors look for first:

1. Missed or Incomplete Check-Ins

The single most common EVV failure. A caregiver forgets to check in via the mobile app, or checks in after they've already started the visit, or forgets to check out. Even a small percentage of missed check-ins accumulates into significant compliance exposure when audited over a 90-day period.

2. GPS Location Mismatch

If a caregiver's GPS coordinates at check-in don't match the client's address of record, the EVV record fails location verification. Common causes: caregivers checking in from their car before entering the home, GPS drift in rural areas, or incorrect addresses in the system.

3. Service Code Mismatches

The service code in the EVV record must match the service code on the claim. Agencies often have EVV configured to capture one service type, then bill for a different (and higher-reimbursed) service code. This is a serious compliance violation that can trigger fraud investigation.

4. Caregiver Identity Errors

Some agencies allow caregivers to share login credentials for convenience, or a supervisor checks in on behalf of a caregiver who is running late. Both practices invalidate the EVV record — the check-in must be performed by the actual caregiver providing the service.

5. Real-Time Data Transmission Failures

Texas HHSC requires EVV data to be transmitted to the state aggregator within 24 hours of service delivery (and in many cases, in real time). Agencies using AltEVV systems that batch-upload weekly are frequently out of compliance without knowing it.

6. Paper Backup Processes Still in Use

Some agencies maintain EVV systems but allow caregivers to use paper timesheets in emergency situations. Any visit that is not electronically verified is non-compliant — paper records cannot substitute for EVV data regardless of circumstances.

How to Prepare for a Texas HHSC EVV Audit

HHSC conducts both scheduled and unannounced compliance reviews. An audit typically involves a data matching exercise: the auditor pulls EVV records and claims data for a specific time period and checks for discrepancies. Here's how to stay ready:

Before an Audit

• Run monthly internal EVV audits — pull all visits with missing check-ins, GPS mismatches, or transmission errors and resolve them before billing
• Verify your EVV system is actively transmitting data to the HHSC aggregator — don't assume it is; check the transmission logs
• Ensure every caregiver has individual login credentials — no shared accounts
• Cross-reference service codes in your EVV records against your billing codes — they must match exactly
• Document your EVV policy in writing — including procedures for technical failures, caregiver training, and exception handling
• Keep caregiver training records — HHSC may request proof that caregivers have been trained on EVV procedures

During an Audit

If you receive an audit notice, you'll typically have a short window (5–10 business days) to respond with documentation. Have your EVV system administrator export complete records for the audit period immediately. If your EVV vendor provides compliance reports, pull those now — don't wait for the auditor to ask.

Common audit documentation requests include: a full EVV data export for the audit period, claims remittance reports for the same period, caregiver schedules and authorization files, and evidence of real-time data transmission to the aggregator.

Texas Medicaid EVV Mandate — Full Details

Texas's Medicaid EVV mandate covers a broad range of programs and service types. Understanding exactly which programs require EVV is critical — agencies that serve multiple funding sources sometimes assume EVV only applies to certain programs.

Programs Covered Under Texas EVV

The following Texas Medicaid programs require EVV for all applicable visits:

• Community Attendant Services (CAS) — personal care for adults with disabilities
• Primary Home Care (PHC) — personal care for elderly and disabled individuals
• Home and Community-based Services (HCS) — supports for people with intellectual/developmental disabilities
• STAR+PLUS Home and Community-Based Services (HCBS) — managed care waiver services
• Community Living Assistance and Support Services (CLASS)
• Deaf Blind with Multiple Disabilities (DBMD) Waiver
• Home Health services — skilled nursing, therapy, home health aide visits billed to Medicaid

If your agency operates under any of these programs, every billable visit requires a valid EVV record. There are no grandfather exceptions for long-standing providers.

The Consequences of Non-Compliance

Non-compliance with Texas EVV requirements has real financial and operational consequences:

• Claim denials — visits without valid EVV records are denied at adjudication
• Recoupments — HHSC can recoup previously paid claims if audits reveal EVV deficiencies
• Corrective action plans — repeated non-compliance triggers mandatory corrective action with monitoring
• Provider termination — egregious or sustained non-compliance can result in removal from the Texas Medicaid program

How to Build a Compliant EVV Operation in 2026

Getting and staying EVV-compliant isn't just about buying software — it's about process. Here's a practical framework:

Step 1: Choose the Right EVV System

You have two options: use the state-provided Sandata EVV system (free, but limited features) or implement an AltEVV system that connects to the HHSC aggregator. AltEVV systems typically offer better scheduling integration, real-time alerts for missed check-ins, and automated compliance reporting — worth the cost for agencies with 10+ caregivers.

Step 2: Train Every Caregiver

EVV compliance lives or dies at the caregiver level. A system is only as good as the people using it. Train every caregiver on: how to use the mobile app, when to check in (before starting care, not after), what to do if the app doesn't work, and why compliance matters for their continued employment. Retrain quarterly, not just during onboarding.

Step 3: Automate Your Exception Workflows

When a caregiver misses a check-in, someone at the agency needs to know immediately — not two days later when you're trying to bill. Set up automated alerts so your scheduling team gets notified within 30 minutes of a missed check-in. Then have a clear process for resolving exceptions: did the visit happen? Does it need to be manually adjusted? Who approves adjustments and how are they documented?

Step 4: Run Monthly Compliance Reports

Before billing, run a compliance report against your EVV data. Look for: visits with no check-in, visits with GPS mismatches, transmission errors to the aggregator, and service code discrepancies. Fix issues before submitting claims — it's far easier than responding to a denial or audit.

Step 5: Document Everything

Write down your EVV policy, your exception procedures, and your audit response protocol. If you're ever reviewed, a documented process signals competence. Auditors treat agencies that can't produce written procedures very differently from those that can.

Summary: Texas EVV at a Glance

Texas EVV compliance is not complicated — but it requires consistent execution across every visit, every caregiver, every day. The agencies that get into trouble aren't usually the ones who never heard of EVV. They're the agencies that have systems in place but don't monitor them, or that allow exceptions and workarounds to accumulate until the exposure becomes material.

The fundamentals are clear:

• Every Medicaid-funded home care visit must be electronically verified
• Six data elements must be captured accurately for each visit
• Data must be transmitted to HHSC in real time or within 24 hours
• Missed check-ins, GPS mismatches, and service code errors are the top audit triggers
• Non-compliance means denied claims, recoupments, and potential termination from the Medicaid program

If your agency doesn't have a real-time dashboard showing your EVV capture rate, your transmission status, and your exception queue — you're flying blind. That's the gap CareHive is built to close.