Minnesota EVV in 2026: What the Cures Act Actually Requires

EVV — Electronic Visit Verification — has been federally mandated for Medicaid-funded personal care services since 2020 (extended for home health to 2023). But the requirements are still widely misunderstood, especially in Minnesota where DHS adds its own implementation rules.

Here's the actual list — and what penalties non-compliance carries.

The federal floor (21st Century Cures Act §12006)

For every visit, EVV must capture:

1. Type of service performed. Mapped to a service code on the claim.
2. Individual receiving the service. Identified by Medicaid ID.
3. Date of service.
4. Location of service delivery. Home address (or actual community location for community-based services).
5. Individual providing the service. Identified by employee ID.
6. Time the service begins and ends.

These six data points must be captured electronically — not on paper, not data-entered after the fact.

What MN DHS adds

Minnesota's implementation requires:

• Use of a DHS-approved EVV system (or the state's free aggregator).
• Caregiver and recipient verification at time of visit (signature, biometric, or telephony confirmation).
• Visit modifications must include reason codes and supervisor approval.
• Real-time submission of EVV data to the aggregator within a defined window.

Common misconceptions

• "GPS is required." Federal rules require location, not specifically GPS. Telephony with caller-ID verification or fixed-device check-in are also acceptable. GPS is the most common implementation, not the only one.
• "EVV replaces care plans." It doesn't. EVV is about verifying the visit happened. The care plan governs what was supposed to happen.
• "EVV applies to all services." It applies to PCS and HHCS funded by Medicaid. Private pay is exempt federally, though MN may have stricter state rules.

Penalties for non-compliance

• Claim denial. Claims for visits without compliant EVV data are denied at adjudication.
• Recoupment. Audits can claw back paid claims if EVV data is missing or modified without justification.
• Loss of provider status. Repeated non-compliance can trigger DHS provider review.

The pragmatic checklist

If you're a MN home care agency, you should be able to answer "yes" to all of these:

• [ ] We use a DHS-approved EVV vendor (or the free aggregator).
• [ ] Every caregiver clocks in and out from a verified location.
• [ ] We have a fallback for clients without smartphones (telephony or fixed device).
• [ ] Modifications to visits include reason codes.
• [ ] EVV data is submitted to the aggregator in real time.

If any of those are "sort of" — that's where to focus.

See how Lumix handles MN EVV →