The 21st Century Cures Act mandated Electronic Visit Verification for Medicaid-funded personal care services nationwide. By now, every state has an EVV requirement in place or is enforcing one. In Virginia, Maryland, and DC, EVV is active and enforced — and it is showing up in payer audits. Here is what you need to understand about EVV compliance beyond just having the technology: WHAT EVV IS REQUIRED TO CAPTURE At minimum, federal law requires EVV to capture: 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. Your EVV system must capture all six of these data points for every Medicaid-funded personal care visit. A system that captures check-in and check-out but not GPS location verification, or one that allows manual overrides without documentation of the reason, is not fully compliant. THE AUDIT RISK IN EVV DATA Auditors are increasingly sophisticated about EVV data. They are looking for: GPS coordinates that do not match the client's address — the caregiver was not actually at the service location. Visit times that are suspiciously consistent — visits that always start and end on the hour, every time, with no variation, may indicate manual entry rather than real-time capture. Claims for visits where no EVV record exists at all. Billed hours that consistently exceed EVV-documented hours. Any of these patterns in your EVV data creates audit exposure even if the care was actually delivered. Clean EVV data is your first line of defense. MANAGING LEGITIMATE EVV EXCEPTIONS There will be visits where EVV does not capture correctly — technology failures, locations without GPS signal, client privacy situations that require manual entry. Every EVV system has an exceptions process for these situations. Your agency must have a written policy for how exceptions are handled: who approves them, how they are documented, and what the maximum exception rate should be. An agency with an exception rate above 5 to 10% is going to get scrutiny.