The software requirement
Case management software for IDD providers must track authorization units against delivered services in real time and capture the six EVV data elements required by the 21st Century Cures Act: type of service, individual receiving service, date, location, individual providing service, and start and end times. The federal EVV mandate applies to personal care services delivered under sections 1905(a)(24), 1915(c), 1915(i), 1915(j), 1915(k), and Section 1115 of the Social Security Act.
The tracking must happen before billing. States enforce EVV through hard edits that automatically reject non-compliant claims before payment, and authorization tracking failures result in unbillable services regardless of whether the service was actually delivered.
What authorization tracking actually means
Each Medicaid waiver authorization specifies a service code, a unit count, and a date range. The software must:
- Deduct units from the authorization balance as services are documented
- Block documentation or flag warnings when approaching unit limits
- Track multiple concurrent authorizations per client, each with different service codes
- Alert staff before authorization expiration dates
- Prevent billing submissions for services that exceed authorized units or fall outside the authorization window
The six EVV data elements
Federal law at SSA section 1903(l)(5)(A) requires the system to 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
Web-based timesheets alone do not meet the requirement. According to CMS guidance, "web-based timesheets alone do not provide the state with auditable confirmation of the data entered by the provider and approved by the individual. Consequently such a system would not be sufficient for electronically verifying the six data elements."
Federal deadlines and penalties
The compliance dates are January 1, 2020 for personal care services and January 1, 2023 for home health services. States that fail to implement EVV face Federal Medical Assistance Percentage reductions on this schedule:
| Year | FMAP Reduction | |------|----------------| | 2020 | 0.25% | | 2021 | 0.5% | | 2022 | 0.75% | | 2023 and after | 1.0% |
For home health services, the reduction started at 0.25% for 2023 and 2024, increases to 0.50% in 2025, 0.75% in 2026, and reaches 1% annually from 2027 onward.
States may apply for a one-year good faith effort exemption if they demonstrate unavoidable delays.
State-by-state differences
Illinois
Illinois requires providers to approve EVV records "as near to point-in-time as possible" and EVV records must precede all approved service hours submitted to ACES$ by the designated billing deadlines. The state set a 75% EVV compliance threshold for home health care services providers by September 30, 2025, with quarterly monitoring.
Tennessee
Tennessee requires providers serving DDA (Department of Disability and Aging) programs to use the state-provided Therap system at no cost for basic functionality. Providers serving TennCare personal care and home health services use Sandata or CareBridge as the EVV aggregator. The Department of Intellectual and Developmental Disabilities pays for the system.
EVV applies to all Personal Assistance services and Respite Levels 1-4, affecting more than 1,700 people in the Statewide, CAC and Self-Determination Waivers. The 21st Century Cures Act does not require EVV for Supported Living services or other residential services in Tennessee.
California
California implemented EVV for personal care services on January 1, 2022 and home health services on January 1, 2023. By June 1, 2023, regional center providers of personal care and home health care services were required to transmit Cures Act compliant data to the state's EVV system.
The state contracted with Sandata Technologies to provide the CalEVV system, available free to providers, though providers may use their own alternate EVV system. California's service codes subject to EVV include:
- 062: Personal Assistance
- 465: PD Respite Services – Family Member
- 858: Homemaker Services
- 862: In-Home Respite Services Agency
- 864: In-Home Respite Worker
- 896: Supported Living Services
Live-in caregivers are exempt from EVV in California but not in Missouri.
Missouri
Missouri requires providers to log into the EVV Aggregation System (EAS) at least once a week to ensure complete and accurate data continues to be sent. The state requires a memo field detailing activities performed for Division of Developmental Disabilities services.
Missouri has no live-in caregiver exemption, unlike California.
North Carolina
North Carolina's Tailored Plans launched on July 1, 2024, and EVV requirements for services in those plans became effective on that date. Programs subject to EVV include NC Medicaid in-home Personal Care, Home Health, Community Alternatives Program for Children (CAP/C), Community Alternatives Program for Adults (CAP/DA), self-directed personal attendant care services, Innovations Waiver, TBI Waiver and the 1115 Managed Care Demonstration Waiver.
West Virginia
West Virginia's deadlines aligned with federal requirements: January 1, 2020 for Personal Care Services and January 1, 2023 for Home Health Care Services. The state received CMS approval for an extension of the FMAP reduction until January 1, 2021.
The Intellectual/Developmental Disabilities Waiver (IDDW) is specifically identified as a program requiring EVV for hands-on, direct-care services.
What providers commonly get wrong
Assuming residential services require EVV
Supported Living and other residential services are exempt from the federal EVV mandate. The requirement applies only to services "provided during an in-home visit." Providers waste time and money implementing EVV for services that are not subject to the mandate.
Billing before EVV records are approved
In Illinois, EVV records must precede all approved service hours submitted to the billing system. Submitting claims before EVV approval results in automatic rejection. The state requirement is that approval happens "as near to point-in-time as possible," not at month-end.
Relying on web-based timesheets
Web-based timesheets where staff manually enter start and end times do not meet the federal definition of electronic verification. The system must capture the data elements electronically, with auditable confirmation. Manual entry systems result in claim denials even when the timesheet data is accurate.
Missing the authorization window
Billing the wrong code, exceeding the authorized unit count, or submitting claims after the authorization window closes all result in claim denial. One lapsed authorization or mismatched service code can open a retrospective review spanning months of claims.
Not monitoring the state system weekly
Missouri explicitly requires providers to log into EAS at least once a week. Providers who check only at month-end discover data transmission failures too late to correct them before billing deadlines.
How authorization units and EVV connect
The authorization defines what can be billed. EVV proves it was delivered. Both must align or the claim fails.
A service authorization might approve 80 units of personal care (service code 062) for January 1 through March 31. The software must:
- Capture EVV data for each visit (the six required elements)
- Convert clock-in and clock-out times to billable units using the state's unit definition
- Deduct those units from the 80-unit authorization balance
- Block or flag any attempt to document service after 80 units are consumed
- Reject any claim submission for dates outside January 1 to March 31
- Ensure EVV records are approved before the billing system receives the claim
A failure at any step makes the service unbillable, even if the service was provided and documented.
Waiver renewal cycles
Section 1915(c) waivers are initially approved for three years, with renewals of up to five years. Authorization tracking systems must accommodate changes to service definitions, unit calculations, and billable activities that occur during waiver renewals. A service code that was billable under the previous waiver version may have different unit definitions or documentation requirements under the renewal.
State enforcement approaches
States enforce EVV through automated claim edits, not warnings. Missing EVV data results in immediate claim rejection. California specifies that if DHCS determines non-compliance, the state may provide technical assistance, require a corrective action plan, recover overpayments, impose enrollment or monetary sanctions, or take other remedial action.
Illinois tracks compliance quarterly and uses escalating remediation for providers who fail to meet the 75% threshold by the September 30, 2025 deadline.
What the software must do simultaneously
The system must:
- Accept EVV data from mobile devices in real time (or store and forward when offline)
- Match each visit to an active authorization
- Calculate units consumed based on service type and duration
- Deduct units from the correct authorization balance
- Prevent unit overruns
- Flag approaching authorization expiration dates
- Store all six EVV elements in a format the state can audit
- Transmit EVV data to the state system on the state's required schedule
- Generate claims only for services with complete, approved EVV records
- Handle multiple service codes per client with different unit definitions
This happens across hundreds of clients, dozens of staff, and multiple service types, every day.
Comparison of state-specific requirements
| State | EVV Start Date | Compliance Threshold | State Vendor Required | Live-in Exemption | Weekly Check Required | |-------|----------------|---------------------|----------------------|-------------------|----------------------| | Illinois | Sept 1, 2023 (PSW), Jan 1, 2024 (HHCS) | 75% by Sept 30, 2025 | No | Not specified | No | | Tennessee | Aligned with federal dates | Not specified | Yes (Therap) | Not specified | No | | California | Jan 1, 2022 (PCS), Jan 1, 2023 (HHCS) | Not specified | No (CalEVV available) | Yes | No | | Missouri | Aligned with federal dates | Not specified | No | No | Yes (EAS login) | | North Carolina | July 1, 2024 (Tailored Plans) | Not specified | No | Not specified | No | | West Virginia | Jan 1, 2020 (PCS), Jan 1, 2023 (HHCS) | Not specified | No | Not specified | No |
The cost of getting it wrong
Claim denials are one consequence. Retrospective audits are worse. When a state identifies authorization tracking errors or EVV non-compliance during an audit, the review period can extend to all claims submitted during the authorization period. Providers face recoupment of payments already received, even for services that were actually delivered.
Providers cannot bill for services without compliant EVV data, and states cannot pay claims that lack the required verification elements.
What to verify before selecting software
Ask vendors:
- Does the system track authorization units in real time, or only at month-end?
- How does it prevent documentation when authorization units are exhausted?
- Does it capture all six EVV elements electronically, or does it rely on manual entry?
- Can it transmit to your state's specific EVV aggregator or vendor requirement?
- Does it block claim generation for services without approved EVV records?
- How does it handle multiple concurrent authorizations for the same client?
- Can it accommodate your state's unit definitions and service code structure?
Request a demonstration using your actual authorization scenarios and state requirements, not generic examples.
AgenciesForge tracks authorization units and EVV on one record, with charting, scheduling, and billing included.