By: Paul Mason, Director of Strategic Partnerships at LTCPro
For: Administrators and business office leaders at assisted living and home and community-based service providers across the United States billing Medicaid waiver services, who need their EVV records to hold up if a federal or state auditor asks for them.
Key Takeaway: HHS-OIG’s active Electronic Visit Verification audit series has already found millions of dollars in Medicaid overpayments tied to visit verification gaps, including one 2026 state audit that flagged over $53 million in confirmed and disputed federal reimbursement. Waiver providers now need EVV records that match the approved service plan exactly, not just visit records that exist, since federal auditors are actively testing that specific alignment, state by state.
Table of Contents
- Why EVV Enforcement Looks Different in 2026
- What EVV Actually Requires, and Which Waiver Authorities It Covers
- What Federal Auditors Are Actually Finding
- Building an EVV Record That Survives an Audit
- Where EVV Fits Into the Rest of Your Waiver Billing
- How LTCPro Supports EVV-Ready Waiver Billing
- FAQ
A Colorado Medicaid audit released in July 2026 found the state’s Electronic Visit Verification system didn’t verify that all personal care visits were actually recorded in it, then traced that gap to $8,072,870 in confirmed federal overpayments, with another $45,688,080 set aside pending further review (HHS-OIG, Electronic Visit Verification System for Medicaid In-Home Services). That is not a hypothetical compliance risk. It is money HHS-OIG has already told a state to account for, tied directly to EVV gaps that look identical to what most waiver providers assume is a solved problem.
Why EVV Enforcement Looks Different in 2026
Electronic Visit Verification has been federally required for years, but for most of that window, enforcement was about getting systems live, not scrutinizing what they actually captured. Section 12006(a) of the 21st Century Cures Act set the terms (Medicaid.gov, Electronic Visit Verification):
Personal care services: EVV required by January 1, 2020
Home health services requiring an in-home visit: EVV required by January 1, 2023
Penalty for missing the deadline without an approved exemption: incremental federal funding reductions of up to 1%
HHS-OIG’s current audit series changes the picture. It’s an active, multi-year effort built to test whether states implemented EVV according to federal and state requirements, and whether they complied with those requirements when actually claiming Medicaid in-home personal care services.
Completed reviews: Kansas and Colorado
Active reviews: four more states, announced as recently as March 2026
Series timeline: expected to run through fiscal year 2028
This is not a one-time check. It’s a rolling federal audit program, and both completed reviews found real, dollar-quantified problems.
For a facility or waiver provider, the practical effect is that the standard has quietly shifted from “does an EVV system exist” to “does every visit in the EVV system actually reconcile against the approved plan of care, and can the provider produce the paperwork behind it on request.” That second bar is considerably harder to clear, and it’s the one auditors are now applying.
What EVV Actually Requires, and Which Waiver Authorities It Covers
EVV isn’t a single national system. It’s a federal requirement that every state implement its own EVV system to electronically capture when a covered visit starts and ends, and the mandate reaches further into waiver billing than most providers assume. It applies to (Medicaid.gov, Electronic Visit Verification):
Personal care services delivered under Section 1905(a)(24), 1915(c), 1915(i), 1915(j), 1915(k), and Section 1115 authorities
Home health services requiring an in-home visit, under Section 1905(a)(7)
That means EVV requirements travel with the service, not just the waiver program name on your contract. A provider delivering personal care under a 1915(c) waiver, a state’s 1915(i) State Plan option, or 1915(k) Community First Choice is subject to the same underlying EVV obligation, even though the billing rules, rate structures, and state administration differ across those three authorities. Knowing which authority a given service falls under isn’t just an eligibility question; it determines exactly which EVV rules and exception processes apply.
This matters operationally because a provider serving residents under more than one authority, say, a 1915(c) waiver for some residents and 1915(k) Community First Choice for others, cannot assume a single EVV exception policy covers both. State Medicaid agencies build their EVV systems around the state plan, not around a universal federal template, so several things can differ by authority within the same state:
Manual-entry rules
Required data fields
How GPS exceptions get reviewed
Curious whether your facility’s EVV setup is actually configured correctly for every waiver authority you bill under? LTCPro can map your current services against their governing authority and flag any mismatched EVV configuration.
Get an EVV Authority Mapping Review →What Federal Auditors Are Actually Finding
This is the part most waiver billing guidance skips, because it requires looking at what auditors actually found, not what the rule says on paper.
In Kansas, HHS-OIG found:
The state’s EVV system didn’t require every in-home personal care visit to be recorded and verified in it
The state didn’t consistently check that the tasks billed on a claim matched the tasks actually approved in the resident’s person-centered service plan
The state lacked adequate provider documentation requirements to back up what was billed
In Colorado, the findings were more severe and came with a specific dollar figure attached. The state’s EVV system didn’t verify that every personal care visit was recorded, and the resulting claims didn’t always comply with federal and state requirements. HHS-OIG’s recommendations, all still open as of this writing, show exactly where the gaps were (HHS-OIG, Electronic Visit Verification System for Medicaid In-Home Services):
Limits on how often attendants could use manual entries instead of the EVV system itself
System edits to confirm every visit had a matching EVV record
GPS exception review requirements
Unit-to-approved-plan matching
Attendant identity verification between EVV records and timesheets
Read as a checklist, those recommendations are close to a map of where a waiver billing operation is most likely to have a gap it doesn’t know about yet: manual entry overuse, visits missing from the system entirely, location data nobody reviews, units that don’t reconcile against the plan of care, and attendant identity that doesn’t match across records.
Want to know if your EVV manual-entry rate or GPS exception volume would raise the same flags OIG’s audits are trained to catch? LTCPro can run that comparison against your current EVV data.
Request an EVV Audit Readiness Check →Building an EVV Record That Survives an Audit
Treat the OIG recommendations above as the actual audit criteria, because that’s effectively what they are for any state under active review.
Cap manual entry usage and require a supervisor review above a set threshold. An occasional manual entry for a genuine connectivity failure is normal. An attendant whose manual-entry rate is consistently high is exactly the pattern federal auditors are now trained to look for.
Reconcile every EVV record against the approved service plan, not just against the schedule. A visit that happened and was logged in EVV can still be a compliance problem if the tasks recorded don’t match what the person-centered service plan actually authorized.
Review GPS and location exceptions on a defined cadence, not only when a claim gets denied. Colorado’s audit specifically flagged the absence of a requirement to review and correct location exceptions before claims went out.
Verify attendant identity across EVV records and timesheets. A mismatch between who the EVV system shows delivered a visit and who signed the corresponding timesheet is one of the specific gaps named in the Colorado findings.
Confirm background screening and required assessment documentation are retained, not just completed. Both Kansas and Colorado’s findings extended beyond the visit record itself into whether providers could actually produce the supporting documentation an auditor asked for.
Where EVV Fits Into the Rest of Your Waiver Billing
EVV compliance doesn’t operate in isolation from the rest of waiver billing, it depends on it:
Authorization and level-of-care tracking: a visit can be perfectly recorded in EVV and still generate a denial if the underlying authorization has expired or the unit count exceeds what’s approved. LTCPro’s Medicaid billing lifecycle hub covers authorization tracking and level-of-care determinations in depth.
Denial patterns after a clean EVV record: these are usually payer- or documentation-related rather than EVV-related. Our denial reduction guide covers that ground.
Provider enrollment: EVV compliance doesn’t protect a claim if the billing provider’s own Medicaid enrollment has lapsed. Our provider enrollment guide covers the enrollment and revalidation side separately.
How LTCPro Supports EVV-Ready Waiver Billing
LTCPro supports Medicaid waiver billing for assisted living and home and community-based service providers with EVV data review built into the same workflow as eligibility tracking, authorization management, and claims submission, so a visit verification gap gets caught before it becomes a state or federal audit finding rather than after.
Ready to see where your own EVV data would hold up against the same standards OIG just applied to Colorado and Kansas? Bring LTCPro your current EVV export for a direct review.
Talk to a Waiver Billing Specialist →FAQ
What is Electronic Visit Verification and which Medicaid services require it?
Electronic Visit Verification is a federally mandated system that electronically records when a covered Medicaid visit starts and ends. It’s required for Medicaid personal care services and for home health services that require an in-home visit, under Section 12006(a) of the 21st Century Cures Act.
Which HCBS waiver authorities does the EVV mandate cover?
The mandate applies to personal care services delivered under Section 1905(a)(24), 1915(c), 1915(i), 1915(j), 1915(k), and Section 1115 authorities, and to in-home health services under 1905(a)(7). The specific billing and exception rules can still vary by which authority and which state administers the service.
What happens if a state or provider doesn’t comply with EVV requirements?
States that miss EVV implementation deadlines without an approved good-faith exemption face incremental federal funding reductions of up to 1%. Providers whose claims don’t have compliant, matching EVV records are the ones actually at risk during an audit, since noncompliant claims are what recent HHS-OIG reviews have flagged for repayment.
What did HHS-OIG’s 2026 EVV audits actually find?
HHS-OIG’s Colorado audit, completed in July 2026, found the state’s EVV system didn’t verify every personal care visit was recorded, resulting in $8,072,870 in confirmed federal overpayments and another $45,688,080 set aside for further review. An earlier Kansas audit found similar gaps in verifying that billed tasks matched the resident’s approved service plan.
Does EVV work the same way in every U.S. state?
No. EVV is a federal mandate, but each state builds and administers its own EVV system, exception rules, and manual-entry policies. A multi-state waiver provider needs state-specific EVV procedures rather than assuming one state’s exception process or documentation standard applies everywhere.
LTCPro provides revenue cycle management, medical billing and accounts receivable, prior authorization, accounts payable, payroll, and bookkeeping services for skilled nursing and assisted living facilities across the United States, backed by proprietary long-term care financial software.
