Texas EVV Compliance 2026: the HHSC 80% threshold and what to do this quarter
Texas HHSC resumed strict EVV usage reviews in March 2026. Agencies under 80% face corrective action. Here's the practical breakdown plus a live score calculator.
Quick answer
In Texas, your EVV usage score must stay at 80%+. Below that, HHSC opens a Corrective Action Plan. Try the live score calculator ↓
Texas reactivated strict EVV reviews in March 2026. The clock is real.
Live EVV usage score calculator
Move the sliders to your numbers. The bar shows where you are vs. the HHSC threshold.
You qualify for a Corrective Action Plan. Move quickly.
Estimate only. Your official HHSC EVV usage score is calculated by the state aggregator (HHAeXchange) on the review period HHSC selects. Verify your real score in the HHAeXchange portal.
What changed in 2026
After a multi-year ramp-up that emphasized education and grace periods, Texas HHSC moved to a strict-enforcement posture in March 2026. Three things you should know:
- Compliance reviews resumed. HHSC is now actively reviewing agency EVV usage scores quarterly. Agencies under 80% receive a notice within roughly 30 days of the review period.
- The 80% threshold is the floor, not the target. HHSC will continue to issue corrective action even if you sit at 81% for two periods in a row, on the theory that the trajectory matters.
- Visit-maintenance windows are enforced. Once an EVV exception ages past the maintenance window (typically 60 days), the visit cannot be corrected and becomes a permanent score hit.
For a broader 50-state EVV reference, see our EVV requirements by state guide.
Texas at scale, in real numbers
Texas has roughly 500,000+ Medicaid recipients receiving home and community-based services. HHSC's 2026 enforcement push isn't hypothetical: agencies are receiving CAP notices in the first quarter after the review period closes.
How HHSC calculates the score
The formula is simple in theory and brutal in practice:
What counts as "verified": the EVV record matches the schedule on all six required data elements (service type, member, date, location, caregiver, time) within HHSC tolerance.
What hurts the score: visits with no EVV record (caregiver forgot to clock in), visits with mismatches that exceed tolerance, and visits where exceptions weren't resolved in the maintenance window.
What doesn't hurt the score: visits where exceptions were resolved correctly during the visit-maintenance window. The score is forgiving as long as you reconcile.
Corrective Action Plan timeline
If your score falls below 80%, here's the typical sequence:
- Day 0
Review period closes
HHSC pulls EVV usage data from HHAeXchange.
- Day 15–30
Notice of non-compliance
You receive a formal notice. CAP submission required within 30 days of the notice.
- Day 30–45
CAP drafted + submitted
Root cause analysis, remediation plan, and weekly EVV usage reporting commitment.
- Day 45–180
CAP active, weekly reports due
Submit weekly EVV usage data. HHSC reviews trend.
- Day 180+
Outcome
If above 80%: CAP closed. If still below: extended monitoring, payment hold, or contract action.
How to improve fast
If your score is below 80% or trending toward it, four moves get you healthy:
Mandatory mobile GPS clock-in
Eliminates location and time mismatches at the source. The single biggest single-quarter improvement we see.
Daily exception reconciliation
Each morning, a 15-minute review of yesterday's EVV exceptions. Fix while still in the maintenance window.
Caregiver training pass
New caregivers contribute most of the unverified visits. A short refresh on clock-in/clock-out saves the score.
Weekly score dashboard
Make the EVV usage score visible to schedulers and supervisors weekly so the trend is everybody's problem.
Texas EVV FAQ
Texas EVV: how we got here
The 2026 strict-enforcement push is the end of a 7-year ramp. Knowing the history is how you predict the next escalation.
- 2016
21st Century Cures Act signed
Federal law requires every state to implement EVV for Medicaid personal care (PCS, by 1/1/2020) and home health (HHCS, by 1/1/2023). FMAP penalties for non-compliant states.
- 2019
Texas selects DataLogic, then HHAeXchange
HHSC initially contracted DataLogic; reassigned aggregator to HHAeXchange ahead of go-live to meet federal deadlines.
- 2020
Texas PCS go-live (delayed from 1/1/2020 to 12/1/2020)
Texas received a Cures Act good-faith exemption that pushed go-live; agencies began EVV submission late 2020 with broad transition tolerances.
- 2021–2022
Soft enforcement phase
HHSC published EVV usage scores monthly but did not act on sub-threshold scores. Most agencies treated EVV as “ramp up”.
- 2023
HHCS go-live for home health
Texas added home health care services to EVV. Same aggregator (HHAeXchange), separate visit types and tolerances.
- 2024
Quiet enforcement signaling
HHSC bulletins began noting that strict enforcement would resume. Most agencies still under-invested in EVV reconciliation.
- March 2026
Strict enforcement resumes
HHSC actively reviews EVV usage scores quarterly. Agencies under 80% receive a formal Corrective Action Plan with weekly reporting and possible payment hold.
- Expected next
Higher threshold + broader audits
Industry expectation: HHSC will raise the threshold above 80% within 12–18 months and expand audits to claim-level review. Build a buffer now.
What actually triggers a Corrective Action Plan
Not every dip below 80% triggers a CAP. HHSC weighs three factors:
Score below 80% in the most recent quarterly review
A single quarter under threshold opens the door. Two quarters in a row almost always triggers a formal CAP.
Trend is downward, even from a high baseline
An agency at 88% trending toward 82% may receive a warning. Trajectory matters as much as level.
Aged exceptions past the visit-maintenance window
Permanent score hits from unfixed exceptions weigh heavier than recent ones. The maintenance window closes in days.
Top 10 EVV exception reason codes (and how to fix them)
These are the codes HHSC EVV usage reports surface most often. The fix for each is operational, not vendor-dependent.
| Reason | What it means | How to fix |
|---|---|---|
| Manual entry by office | Office staff entered the visit times instead of caregiver clock-in. | Mandatory mobile clock-in; only allow office override with documented reason. |
| Outside service area / GPS | Caregiver clocked in beyond the GPS tolerance for the client address. | Verify client address; widen tolerance for rural areas; check device GPS accuracy. |
| Late clock-in | Caregiver clocked in past the scheduled start + tolerance. | Late-clock-in alert at +10 min to coordinator; coach repeat offenders. |
| Missing clock-out | Visit started but no clock-out recorded. | Push notification at scheduled end + 10 min; require end-of-shift checklist. |
| Service code mismatch | Visit performed for a different service code than scheduled. | Lock service code at schedule level; only authorized roles can change. |
| Caregiver not authorized | Caregiver assigned without required cert or auth on file. | Pre-visit check at assignment; auto-block scheduling if cert expired. |
| Duplicate visit | Same client + caregiver + window submitted twice. | Dedupe at submission; review caregiver clock-in pattern. |
| Late visit maintenance | Exception not resolved before maintenance window closed. | Daily exception reconciliation; never weekly. |
| Client not enrolled | Client not active in Medicaid on visit date. | Monthly Medicaid eligibility verification. |
| Aggregator format error | Submitted EVV record failed aggregator validation. | Verify with vendor; may require trading-partner spec update. |
What HHSC actually asks for during a CAP review
If you receive a CAP notice, here's the document set HHSC expects in your initial response. Compile this in advance, not after the notice arrives.
- Quarterly EVV usage score history (last 4 quarters minimum)
- Exception report with aged exceptions broken out by reason code
- Root-cause analysis: which 2–3 reason codes drive most exceptions
- Remediation plan with specific actions, owners, and dates
- Caregiver training records related to EVV (mobile app, clock-in, clock-out)
- Exception-resolution workflow documentation (who handles, in what window)
- Weekly EVV usage report commitment for the duration of the CAP
- Mobile-clock-in adoption rate by caregiver
- Service-area / GPS tolerance settings per client (rural exemptions documented)
For the broader 50-state EVV picture, see our EVV requirements by state guide.
Texas EVV glossary
Ten Texas-specific terms that show up in every HHSC bulletin.
HHSC
Texas Health and Human Services Commission. The state agency that runs Medicaid in Texas, including EVV oversight.
TMHP
Texas Medicaid & Healthcare Partnership. The administrative services contractor that processes Medicaid claims.
CDS / CDA
Consumer-Directed Services / Consumer-Directed Attendant. Texas-specific self-direction program with its own EVV submission rules.
EVV usage score
Verified EVV visits divided by total billable visits in the review period. Must stay at 80%+ to avoid CAP.
CAP (Corrective Action Plan)
Formal HHSC remediation requirement issued to agencies under threshold. Includes weekly reporting + remediation actions.
Visit maintenance window
The period after a visit when EVV exceptions can still be edited (typically 60 days). After it closes, exceptions become permanent score hits.
HHAeXchange (TX aggregator)
The state-designated EVV aggregator for Texas. Replaced DataLogic during the original 2019 procurement.
PCS / HHCS
Personal Care Services / Home Health Care Services. The two visit types subject to EVV under the Cures Act.
Open EVV model
Texas's implementation model: agencies can use any compliant EVV vendor that submits to HHAeXchange.
iQIES
CMS's Internet Quality Improvement & Evaluation System. Used for OASIS-E submission, separate from EVV but often confused.
Sources
- [1]Texas HHSC: Electronic Visit Verification
- [2]Texas HHSC: EVV Compliance Reviews
- [3]CMS: Medicaid EVV Compliance Status
- [4]HHAeXchange: Texas EVV Aggregator
Sources accessed May 3, 2026. Texas EVV requirements change frequently, verify against the HHSC EVV bulletin before relying on this article for compliance decisions.
Cal works with Texas home care agencies on EVV compliance and HHAeXchange aggregator integration as part of AveeCare's Texas Medicaid product work. This guide reflects the HHSC March 2026 enforcement update and current visit-maintenance windows.
Behind every EVV record is a real visit. Get the recording right.
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Stay above 80% with less effort
AveeCare ships mandatory mobile clock-in, daily EVV exception reports, and a weekly compliance dashboard. Try the live demo or talk to us about Texas EVV setup.