Electronic Visit Verification has been a federal requirement under the 21st Century Cures Act since 2020 for personal care services and 2023 for home health services. But the enforcement environment in 2026 looks very different from the early years of implementation. States that previously accepted marginal or incomplete EVV data are moving to hard edits that automatically reject non-compliant claims before payment is issued. For IDD agencies, this is not a compliance nuisance. It is a direct threat to cash flow.
What EVV Is Required to Capture
Under CMS requirements, EVV systems must capture the following data elements for every qualifying visit:
- The type of service performed
- The individual receiving the service
- The date of service
- The location of service delivery
- The individual providing the service
- The time the service begins and ends
For IDD agencies providing home and community-based services under Medicaid waivers, this means every DSP providing in-home support or community access services needs to verify visits electronically at the point of service, not after the fact.
The Unique EVV Challenges IDD Agencies Face
IDD agencies face a set of EVV complications that are distinct from traditional home health providers:
The location issue: HCBS services for people with IDD are often delivered in community settings, not a fixed home address. A client attending a community integration activity, visiting a family member, or participating in a supported employment placement may be at a different location every day. GPS-based EVV systems designed around a static home address create exception flags that do not accurately reflect a legitimate service delivery.
The scheduling complexity: IDD service schedules change frequently based on client needs, family circumstances, and staffing availability. When planned schedules do not match actual service delivery and EVV data reflects the actual visit, the mismatch can create exception flags that billing staff must manually resolve before a claim can go out.
The caregiver population: Many DSPs working with IDD clients are not experienced with technology-based systems. Training gaps, missed clock-ins, and forgotten clock-outs create EVV exceptions that multiply quickly across a large staff population.
The multi-site and multi-payer reality: Many IDD agencies serve clients across multiple Medicaid waiver programs with different EVV requirements, different state aggregators, and different validation rules. Managing compliance across Ohio HCBS waivers, for example, looks different than managing compliance under a day program or supported employment waiver.
What Happens When EVV Is Non-Compliant
The consequences of EVV non-compliance are no longer theoretical. States including Texas moved to hard-edit enforcement in early 2026, meaning claims with incomplete or inaccurate EVV data are automatically rejected before any human review. Illinois established compliance thresholds requiring agencies to maintain at least 75% EVV visit compliance or face monitoring, reporting requirements, and potential referral to the Office of the Inspector General.
For an IDD agency with active clients in multiple waiver programs, a cascade of EVV exceptions can translate to significant revenue held up in denials and appeals. Billing staff spend hours resolving exceptions instead of submitting clean claims, and cash flow projections become unreliable.
The State-by-State Complexity
EVV requirements are not uniform across states. Each state has chosen its own EVV model, its own approved aggregators, and its own validation rules. As of 2026, the most common aggregators include Sandata and HHAeXchange, but states including Maryland and New Mexico mandate specific systems with no flexibility for provider choice. States like Florida and New York use different systems for different payers within the same state.
IDD agencies operating across state lines face the compounded complexity of managing compliance with multiple systems simultaneously. The billing coordinator at a multi-state agency may be submitting EVV data to three different state aggregators with three different sets of validation requirements.
How Vertex Approaches EVV for IDD Agencies
Vertex’s EVV Module is designed specifically for IDD agencies rather than adapted from a home health model. The app-based tool enables DSPs to capture visit data in the field, with that information flowing directly into billing workflows rather than requiring manual reconciliation between separate systems.
When EVV data is captured at the point of service and connected directly to the billing platform, your team is working from verified records rather than trying to reconstruct visit data when a claim is flagged. That integration between EVV capture and Vertex Billing Manager reduces the exception volume that billing coordinators have to manage and increases the percentage of clean claims submitted on the first pass.
Practical Steps for Strengthening EVV Compliance
Beyond software, IDD agencies can reduce EVV-related denials by taking these steps:
- Conduct monthly internal audits of EVV data, sampling a cross-section of claims and verifying that start times, end times, service types, and locations are consistent with service records
- Train all DSPs on EVV requirements at onboarding and at least annually, with refreshers when state requirements change
- Assign a compliance owner who monitors state-level EVV policy updates and communicates changes to billing and operations teams
- Review exception reports weekly rather than waiting until claim submission to discover data quality problems
- Document your EVV implementation, vendor contracts, and staff training records so that in the event of an audit, you can demonstrate a systematic approach to compliance
Connect with Vertex Systems to learn how the EVV Advocate integrates with your billing workflow and what the implementation process looks like for agencies at your scale.
