50-State Reference · 2026

EVV Requirements by State (2026): aggregators, models, deadlines, penalties

An interactive 50-state reference for EVV requirements in 2026. Filter by aggregator, search your state, see the model and the most recent enforcement update.

By Calvin Nesvig, Founding Partner·Published May 3, 2026·Updated May 3, 2026·14 min read

Quick answer

All 50 states require EVV under the 21st Century Cures Act. The differences are aggregator, model, and enforcement. Find your state ↓

50/50
States with EVV live
Sandata
Most-used aggregator (26 states)
80%
TX usage-score threshold
4
EVV implementation models

50-state EVV requirements reference

Click any state for the full record: aggregator, model, enforcement, penalties, and links to the state's EVV bulletin.

Last reviewed May 3, 2026 · 51 entries
Aggregator:
Model:
Enforcement:

Most enforcement-aggressive states (2026)

  • Sandata
  • HHAeXchange
  • Sandata
  • HHAeXchange

Closed-model states (no vendor choice)

  • AuthentiCare
  • Sandata
  • AuthentiCare
  • Tellus/Netsmart
  • AuthentiCare

Showing 50 of 50 states. State data shifts as contracts recompete; always verify against the linked state EVV bulletin before signing implementation paperwork.

The 4 EVV implementation models, explained

CMS allows states to pick one of four EVV models. The model your state chose decides how much choice you have in EVV vendors.

Open Model

Agencies can use any EVV vendor as long as the data flows to the state aggregator. Most flexible. Most common in 2026.

Pros
  • Vendor choice
  • Plug-in your existing software
  • Easier to switch
Cons
  • You're responsible for getting data right

Closed Model

Agencies must use the state-contracted EVV vendor. No choice. Easiest for the state.

Pros
  • One throat to choke
  • Guaranteed format compatibility
Cons
  • No vendor choice
  • Locked into state's contract pricing
  • No competitive pressure

Provider Choice

Agency picks any vendor. State doesn't mandate an aggregator format, agencies submit per state spec.

Pros
  • Total flexibility
Cons
  • Heavier implementation lift

MCO Choice

The managed care organization picks the vendor for its contracted providers. Common in NY, TN.

Pros
  • MCO handles contracting
Cons
  • Different MCOs may pick different vendors
  • Multi-MCO agencies juggle multiple systems

Aggregators in plain English

An EVV aggregator is the central system that collects and verifies data from all the EVV vendors used by providers in a state. It's the middle layer between your scheduler and the state's Medicaid claim payment system.

  • Sandata, the largest state-aggregator vendor; uses JSON-format submissions over secure FTP or REST API. Common in eastern and central states.
  • HHAeXchange, large MCO-friendly aggregator; flat-file uploads via secure portal or SFTP. Common in coastal states (CA, NY, MA, NJ).
  • Tellus / Netsmart, mid-size aggregator owned by Netsmart; XML-based submissions. Common in Florida, Georgia, Nebraska.
  • AuthentiCare, First Data / FirstCloud aggregator; common in closed-model states (Iowa, Oklahoma, Arkansas).
  • CareBridge, newer aggregator with Virginia and a few other states.

Penalties + 2026 enforcement updates

EVV moved from a paperwork problem to a payment problem in 2026. Here are the most consequential 2026 enforcement changes:

Texas: 80% threshold + corrective action (March 2026)

HHSC resumed strict EVV usage reviews. Agencies under 80% EVV compliance now face a formal corrective action plan, with provider-payment holds for repeated non-compliance.

Ohio: hard-deny on mismatches (early 2026)

Where Ohio previously allowed claim edits when EVV records and the schedule disagreed, it now denies the claim outright. Recoupment risk on previously-paid claims.

Federal: FMAP reduction risk for states

Under the Cures Act, states that don't implement EVV face Federal Medical Assistance Percentage (FMAP) reductions. Most states are now in compliance, but extension-period states still face this penalty.

Caregiver with elderly clients in a common-room setting, representing daily care visits

EVV is a payment problem, not a paperwork problem

Every Medicaid personal-care visit needs an EVV record that matches the schedule. When the two disagree past the state's tolerance, the claim is denied or recouped. In 2026, multiple states moved from soft-warning to hard-deny.

How AveeCare handles EVV across all 50 states

AveeCare captures EVV data at clock-in and clock-out with GPS, the service performed, and caregiver/client identity. We export to Sandata, HHAeXchange, Tellus/Netsmart, AuthentiCare, and CareBridge formats. The default flow is export-based: AveeCare generates the file, your agency or biller submits it to the state. Direct integrations with state aggregators are available on request and typically require execution of a trading-partner agreement with the state and AveeCare. See our terms of service section 9.2.1 for the full description.

For Texas-specific guidance see our Texas EVV compliance 2026 guide. For our broader compliance reference see the EVV compliance guide.

FAQ

CN
Calvin Nesvig
Founding Partner, AveeCare

Cal works with home care agencies on EVV implementation across multiple states and reviews state Medicaid bulletins as part of AveeCare's product compliance work. Verify state-specific requirements with the state Medicaid agency before relying on this article for billing decisions.

Blue and white US state map illustrating the variance in EVV implementation across states

No two states implement EVV the same way. Pick the platform with all of them.

EVV across all 50 states, in one platform

AveeCare exports to every major aggregator format and supports Medicaid billing nationwide.