Michigan IDD and home and community-based service providers entered 2026 facing one of the most significant shifts in their billing environment in years. The Michigan Department of Health and Human Services finalized its EVV enforcement approach, requiring all home health and personal care service providers to route billing through the state’s designated aggregator. The MI Health Link program was replaced entirely by a new integrated care model. MI Choice waiver amendments with an anticipated July 2026 effective date changed service authorizations for some participants. And for developmental disability service providers, the combined effect of these changes created a compliance landscape that demands current knowledge and systems that can keep pace.
This is what Michigan IDD and disability service providers need to know to bill accurately and protect reimbursement in 2026.
Michigan’s Waiver Landscape for IDD Providers
Michigan’s Medicaid program for individuals with developmental disabilities operates primarily through the Habilitation Supports Waiver, known as the HSW, which is administered through Prepaid Inpatient Health Plans, known as PIHPs, and community mental health service programs. The HSW provides community support services for adults and minors with developmental disabilities, including supported community living, adult foster care, day program services, supported employment, respite, and skills training.
On January 1, 2026, Michigan replaced the MI Health Link program with MI Coordinated Health, a new integrated care program for individuals who are enrolled in both Medicare and Medicaid. MI Coordinated Health uses a Highly Integrated Dual Eligible Special Needs Plan model to combine medical care, behavioral health, prescription drugs, and long-term services and supports under one health plan. Providers who were previously billing through MI Health Link for dually eligible clients needed to complete re-credentialing with MI Coordinated Health plan contracts before continuing to serve those clients.
The MI Choice waiver, Michigan’s primary HCBS waiver serving elderly and physically disabled adults who require nursing facility-level care, has a proposed amendment with an anticipated effective date of July 1, 2026, which includes adding Structured Family Caregiving as a new service option for MI Choice participants. Providers serving MI Choice participants should confirm how their Waiver Managing Agency is implementing this amendment and whether any existing service plans require modification.
The 2026 EVV Hard Cutover: What It Means for IDD Providers
The most operationally significant billing change for Michigan HCBS providers in 2026 is the completion of EVV hard enforcement. On January 1, 2026, MDHHS implemented a hard cutover to EVV for managed care home health care service codes requiring EVV. The hard cutover applies to all dates of service on or after September 3, 2024, and beginning January 1, 2026, Michigan’s Community Health Care Partners requires all home health service billing to be transmitted via HHAeXchange.
This means claims for covered services that do not have an associated, complete EVV record in HHAeXchange will not be payable. The visit must be documented through the EVV system before a claim can be created and submitted. Missing or incomplete EVV records will prevent a claim from being created and will impact provider payment until the EVV record is complete.
Michigan confirmed that its EVV compliance policy took full effect beginning April 1, 2026, covering MI Choice, MI Health Link HCBS, and personal care services through Medicaid Managed Care. For IDD agencies providing personal care and community support services under these programs, this enforcement applies to all qualifying visits.
How Michigan’s EVV Model Works
Michigan uses an open vendor model for EVV, which means providers have two options:
First, providers can use the state-provided HHAeXchange system at no cost. MDHHS awarded a five-year IT contract to HHAeXchange to serve as Michigan’s EVV aggregator. Regardless of which EVV system a provider uses, all visit data must flow through HHAeXchange before claims can be processed.
Second, providers may continue using a third-party EVV system of their choice, provided that system meets state requirements and transmits visit data to HHAeXchange through electronic data interchange. Providers using a third-party EVV system are responsible for the cost of that system and for maintaining the EDI connection to HHAeXchange.
All impacted providers, regardless of which EVV solution they select, are required to complete the HHAeXchange Provider Onboarding Form. Agencies that have not completed this onboarding cannot transmit visit data to HHAeXchange and cannot create billable claims for covered services.
For IDD agencies using Vertex EVV Manager, the system is designed to integrate with state aggregators including HHAeXchange. Confirming that your Vertex EVV configuration is transmitting data correctly to the Michigan HHAeXchange portal is the critical compliance step for Michigan providers.
Services Covered by Michigan EVV Requirements
EVV requirements in Michigan apply to Medicaid-funded services delivered in the home or community, including:
- Personal care services delivered through the state plan and Medicaid managed care plans
- Home health care services requiring an in-home caregiver visit
- MI Choice waiver services provided in the home or community setting
- HSW community support services that include home-based delivery
Home Help individual caregivers who live with their client may be exempt from EVV requirements. Providers should review the Michigan Medicaid Provider Manual, Electronic Visit Verification chapter, to confirm exemption eligibility for specific caregiver arrangements.
Day program services and facility-based services are generally not subject to EVV requirements, as EVV applies specifically to home and community-based visits. IDD agencies operating both day programs and community-based supports need to clearly identify which services in their billing are subject to EVV and which are not, and ensure their documentation workflows reflect that distinction.
Common Michigan EVV Compliance Failures
The most common EVV compliance failures that Michigan IDD providers experienced during the transition to hard enforcement include:
Incomplete HHAeXchange onboarding: Providers who had not completed onboarding by the hard cutover date had no pathway to submit EVV-validated claims, creating immediate billing disruptions. Onboarding completion is the foundational requirement before any other EVV compliance work is meaningful.
Third-party EVV systems not transmitting to HHAeXchange: Providers using existing EVV tools assumed those tools were transmitting to HHAeXchange when the EDI connection had not been configured or tested. Validating your transmission pipeline before enforcement is critical. A visit that is documented in your EVV system but not received by HHAeXchange is not compliant.
DSPs not completing visit documentation at point of service: EVV requires that visit data be captured at the time of service, not reconstructed after the fact. DSPs who delay documentation or fail to complete clock-out records create exceptions that hold up claims. Training and accountability for EVV completion at point of service is a workforce management requirement as much as a technology one.
GPS and location exceptions for community-based services: IDD clients receiving community-based services are often not at a fixed home address. GPS-based EVV systems that require a static address generate location exceptions for visits conducted in community settings. Providers need to understand how their EVV system handles community-based location documentation and how to resolve location exceptions without creating billing delays.
Protecting Revenue in Michigan’s 2026 EVV Environment
For Michigan IDD agencies that want to protect reimbursement in the current enforcement environment:
Confirm HHAeXchange onboarding is complete for your agency and all relevant program sites. This is a one-time requirement but a foundational one.
Validate your EVV transmission pipeline with a test visit before assuming all visits are transmitting correctly to HHAeXchange.
Build a weekly EVV exception review into your billing workflow. Exceptions identified and resolved before claim submission do not affect your billing cycle. Exceptions discovered at submission hold up payment.
Train all DSPs on EVV requirements at onboarding and conduct refreshers when state requirements or your EVV system changes. DSP-level documentation discipline is where EVV compliance is won or lost in daily operations.
Connect EVV data directly to your billing workflow rather than managing them as separate processes. Vertex EVV Manager integrates visit verification data with Vertex Billing Manager so that claims are built from verified EVV records automatically rather than requiring manual reconciliation.
Connect with the Vertex Systems team to discuss Michigan-specific billing support and how the Vertex platform handles HHAeXchange integration for Michigan HCBS providers.
