21st Century Cures Act EVV: what your agency must do.

The 21st Century Cures Act became law in December 2016. Buried in it, Section 12006 created a nationwide requirement: every state Medicaid program must implement Electronic Visit Verification (EVV) for two categories of service — Medicaid-funded personal care services (PCS) and home health care services (HHCS).

EVV is, in plain terms, the electronic proof that a visit really happened: a digital record, captured at the point of care, that a specific caregiver delivered a specific service to a specific client at a specific time and place. The goal was to reduce Medicaid fraud and improper payments for visits that were billed but not delivered as claimed.

Critically, the Cures Act set the what, not the how. It defined the data EVV must capture and the deadlines, but left each state to choose how to implement it — which is why EVV looks different from one state to the next.

The statute is specific about the data every EVV system must record for each visit. These six elements are the same in every state:

Note the last one. The start and end times are where compliance most often breaks down in the field — a caregiver who is present but clocks in late can turn a delivered visit into a denied claim. That single data element is the reason missed-clock-in follow-up matters so much; more on that below.

The Cures Act set staggered deadlines and enforced them by reducing the federal share of a state’s Medicaid spending — the Federal Medical Assistance Percentage, or FMAP — for non-compliance. The reduction starts small and escalates each year:

Agencies never see the FMAP reduction directly — states do. But states pass the pressure straight down: they make EVV a condition of Medicaid billing, so for a provider, non-compliant or incomplete EVV simply means claims don’t get paid.

Because the Cures Act let states choose their implementation, CMS recognizes several EVV models. Which one your state picked determines whether you can keep your own system or must use a state-designated one:

• Provider Choice — the agency selects its own EVV system, as long as it meets state requirements and submits the data.
• Open Vendor / aggregator model — the state provides an EVV system but lets agencies use an alternate EVV-capable platform that feeds a central aggregator.
• MCO Choice — the managed care organizations choose the EVV approach for their networks.
• State Mandated (in-house or single vendor) — the state requires a specific EVV system for all providers.

Vendors such as HHAeXchange, Sandata, Tellus/Netsmart, and CareBridge act as the state aggregator or designated system in various states. To see which model and aggregator applies where you operate, see EVV requirements by state.

For a home care agency, Cures Act EVV compliance comes down to a short list:

• Know your state’s model and aggregator — and whether you may keep your current platform or must use a designated one.
• Use an EVV-capable system that captures all six data elements and submits them in your state’s required format.
• Get caregivers clocking in and out correctly — the operational reality that determines whether visits are actually verified.
• Catch and fix exceptions fast — missed and late clock-ins, before the visit window and the claim are lost.

The first two are a software decision. The last two are an operations problem — and they’re where revenue quietly leaks. A platform records that a caregiver didn’t clock in; it doesn’t pick up the phone and fix it. That gap is exactly what EVV clock-in chasing closes: HeyHomeCare detects the overdue clock-in and reaches the caregiver in real time, in English or Spanish, before the window closes — without ever submitting EVV itself.