Pennsylvania’s Department of Human Services updated the requirements for Electronic Visit Verification (EVV) compliance last August. While the threshold for manual edits still sits at 15 percent, the new guidelines outline more specific penalties for violators. Enforcement begins in 2026, so it’s best to start preparing now.
Here’s what fee-for-service delivery and managed care delivery providers should know about the recent EVV changes, and how to prepare.
What is Electronic Visit Verification (EVV)?
Electronic Visit Verification, or EVV for short, is a fraud-preventing digital system used to verify Medicaid-funded personal care and health services. It confirms whether care providers showed up, provided the right services, and logged accurate times. The process was mandated after the 21st Century Cures Act was passed in 2016.
EVV is required for all Personal Care Services (PCS) and Home Health Services (HHCS), regardless of delivery model. Both FFS (fee-for-service) and care-enrolled providers need to comply.
Providers are responsible for monitoring their EVV compliance status. You can view your manual entry percentage for each reporting period in the EVV aggregator.
- Log in to the aggregator and select Reports on the left-side menu.
- Under Report Type, tick Date Range Reports.
- Click the Report Name dropdown menu and select EVV Compliance.
- Select the date range and account, then click Run Report.
New EVV Monitoring and Enforcement Rules for 2026
The Pennsylvania Department of Human Services detailed how EVV compliance will be monitored and enforced across different provider types. Here are the main changes that you should know.
Quarterly EVV Threshold Monitoring
The department will notify care providers when they exceed the 15% threshold. Starting in 2026, noncompliant FFS providers will see official EVV alert notices directly from the Pennsylvania Department of Human Services (DHS).
The department will also send a list of noncompliant providers to managed care organizations (MCOs). In turn, they must notify their care-enrolled providers. They’re accountable for making sure their in-network providers are following EVV rules based on the official DHS guidelines.
Enforcement of Noncompliance Notice for Consecutive Violations
Providers who exceed the 15% threshold for two consecutive quarters will receive a formal notice of noncompliance. It’ll be issued by the appropriate program office (e.g., OMAP, OLTL, or ODP). Violators will also need to submit a corrective action plan (CAP) that outlines how they plan to achieve full compliance moving forward. Some common corrective actions include:
- staff training
- internal monitoring
- process reassessments
- request for technical assistance
Failure to stay compliant during or following the CAP period might result in additional sanctions. The department will assess the following factors:
- Extent of Noncompliance: The magnitude of deviation is assessed based on how many EVV records required manual edits during the review periods.
- Compliance Trajectory: Providers who are showing progress might receive a lighter sanction than those who refuse to correct deficiencies.
- Corrective Action Status: The department will review whether the provider took the necessary steps outlined in their CAP.
- Repeatedness: How many consecutive quarters has the provider been exceeding the threshold since the bulletin took effect?
Monitoring and Compliance for Managed Care Organizations
For participant-directed care models (OLTL and ODP), the Common Law Employer (CLE) is responsible for meeting EVV requirements. They aren’t enrolled in Medicaid directly, so they won’t receive notices from the department. Instead, program coordinators monitor their compliance.
- In OLTL programs, if a CLE’s manual edits exceed 15%, their Service Coordinator (FFS) or MCO (managed care) must initiate corrective action. Noncompliance may lead to involuntary removal from the program.
- In ODP programs, CLEs working with Support Service Professionals (SSPs) will be subject to oversight from the Department or Administrative Entity. Repeated violations can also lead to removal from the participant-directed model.
Resources for the EVV Monitoring Guidelines in Pennsylvania
All the changes outlined above are part of the Department of Human Services’ Medical Assistance Bulletin MAB2025082901. It was issued in August 2025. You can also refer to the following resources for service authorizations, service rendering, and billing.
- Medical Assistance Bulletin MAB2024082301
- MCO PCS and HHCS information and updates
- PROMISe™ Provider Handbook and Billing Guide
- MA Bulletin 05-20-03
- MA Bulletin 07-20-04
- MA Bulletin 05-22-09
Navigate EVV Compliance With Confidence With ShiftCare
ShiftCare gives providers the tools to stay compliant with evolving EVV rules, including dedicated features to support EVV compliance in Pennsylvania. From real-time alerts and automated visit tracking to audit-ready records, ShiftCare can help agencies meet the 85% threshold, reducing manual processes so you can focus on what matters most – care delivery. Talk to our sales team today by requesting a demo or start a free trial to explore the tools at your own pace.
