If your agency bills MassHealth for home health or personal care delivered in a member's home, Electronic Visit Verification is now part of getting paid, not a future project.
Massachusetts launched its agency-based EVV system in late 2024, and by 2026 the program has moved into the stage where a claim can be held up if its visit record does not check out. This guide lays out what the Commonwealth requires, who has to comply, how the state system works, and the steps that keep your claims clean. It is written for owners, administrators, and compliance staff who want a plain answer rather than a legal brief.
What EVV Is, and Why Massachusetts Uses It
Electronic Visit Verification is software that confirms a home visit happened the way it was billed. At the point of care, the system records who provided the service, who received it, what was delivered, where it took place, and when it started and ended. MassHealth then checks the claim against that record before it pays. In the Commonwealth's own words, EVV is meant to make sure services are delivered appropriately, cut down on paper timesheets, and reduce billing errors and unauthorized spending. It replaces a caregiver's after-the-fact memory with a time-stamped record the state can verify.
The Federal Rule Behind the State Requirement
Massachusetts did not invent this. EVV comes from Section 12006 of the federal 21st Century Cures Act, signed in 2016, which requires every state to use EVV for Medicaid-funded personal care services and home health services that involve an in-home visit. The law fixes six pieces of information that every covered visit has to capture. Any compliant Massachusetts record, no matter which software produced it, must include all six:
- The type of service performed.
- The individual receiving the service.
- The date of the service.
- The location where the service was delivered.
- The individual who provided the service.
- The time the service began and the time it ended.
Who Runs EVV in Massachusetts
The Executive Office of Health and Human Services, or EOHHS, administers MassHealth and oversees EVV across the programs that deliver home and community based services. The requirement reaches programs within both MassHealth and the Executive Office of Aging and Independence.
To operate the program, EOHHS selected Sandata Technologies as the state's EVV vendor for agency-based services and as the EVV data aggregator, the central database that stores every visit record. Sandata has run EVV projects in more than twenty states. MassHealth launched the agency-based EVV system on September 30, 2024. That date is the point where the compliance clock started for many agencies.
Who Has to Comply: The Two Tracks
Massachusetts splits EVV into two tracks, and it matters which one you fall under.
- Agency-based providers cover organizations that employ or contract the caregivers who deliver services, including Home Health Agencies and Group Adult Foster Care providers. MassHealth spells out the rules for these providers in the MassHealth Home Health Agency Bulletin 94 and the Group Adult Foster Care Bulletin 6. If your agency bills MassHealth for covered in-home services, you are almost certainly in this track.
- Consumer-directed programs cover members who direct their own care, including the State Plan Personal Care Attendant program and waivers that include consumer-directed personal care. These programs handle EVV through their fiscal intermediary rather than through an agency's own system.
Not every service is included. MassHealth publishes the full list of services that require EVV by service code, so the first thing any agency should do is confirm which of its billed services actually fall under the mandate.
Your System Options: State Sandata or Alternate EVV
Being required to use EVV does not mean being locked into one product. Like most states, Massachusetts runs an open model with two paths.
You can use the state-sponsored Sandata system at no cost. It records visits and sends them to the aggregator. Or you can use an alternate EVV system, sometimes called a third-party or bring-your-own system, where you keep the software your team prefers and that system transmits the required data to the aggregator in the format the state specifies.
Most established agencies choose the alternate path, because it lets them avoid retraining staff on an unfamiliar tool. One detail is easy to miss: some MassHealth managed care plans and accountable care organizations use HHAeXchange as their EVV aggregator rather than the state system. Agencies that bill those plans, and the EVV vendors that integrate with them, follow the Massachusetts EVV vendor specification that HHAeXchange publishes. The practical takeaway is to confirm which aggregator each of your payers uses before you pick or configure a system.
The Three Phases of Compliance, and Where 2026 Sits
MassHealth is rolling out agency-based EVV in three phases, and knowing them tells you what enforcement looks like today.
The first phase is registration. Providers enroll in the EVV system and get set up to capture and transmit visits. The second phase is visit monitoring, where the state watches whether providers are recording visits and how complete that data is, without yet blocking payment. The third phase is claims edits, the enforcement stage, where the aggregator checks each claim against its EVV record and rejects claims that are missing data or do not match.
By 2026, the program has matured into that third phase for a widening set of services. In practice, an incomplete or mismatched visit record is no longer a warning. It can stop a claim from being paid. The agencies now seeing rejections are usually the ones that treated the earlier phases as optional. MassHealth has also been clear that repeated non-compliance can lead to sanctions, up to and including termination from the provider network.
The Six Data Elements in Daily Practice
On paper the six elements look simple. In daily operation, four of them cause most of the trouble.
- Location is the first. For an in-home visit, the system has to confirm the service happened at the member's residence, usually through GPS or a device fixed at the home. Telehealth and phone-delivered services are handled differently, so an agency that mixes visit types needs a system that records each one correctly.
- Time in and time out come next. A missing end time is one of the most common reasons a claim cannot be validated, because the state cannot confirm the duration. Both timestamps have to be captured during the visit, not entered afterward.
- The individual providing the service has to be the person who actually delivered it, identified the same way everywhere. Nicknames in one system and legal names in another are a frequent source of mismatches.
- Finally, the type of service recorded has to match the service authorized in the member's plan. Even a close but incorrect code will fail the check.
Common Ways Agencies Fall Out of Compliance
- Entering visits manually or after the fact, which produces no verifiable timestamp.
- Logging a start time but not an end time, so the state cannot confirm the duration.
- Recording a service code that does not match the member's authorization.
- Capturing the visit at the agency office instead of the member's home.
- Using inconsistent caregiver identifiers across scheduling, EVV, and billing.
- Ignoring the aggregator's required file format, so clean visits still fail on submission.
What Non-Compliance Actually Costs
The immediate cost is cash flow. When a claim fails an EVV edit, the state rejects it and holds it until the underlying data is corrected and the claim is resubmitted, which commonly adds weeks to payment. Across a full caseload, a low match rate becomes a running backlog of unpaid visits. Beyond the money, MassHealth treats persistent non-compliance as a program integrity issue, with sanctions that can escalate to removal from the network. For an agency whose revenue depends on MassHealth, that is closer to an existential risk than a paperwork problem.
A Massachusetts EVV Compliance Checklist
- Confirm which of your billed services require EVV using the MassHealth service code list.
- Identify your track, agency-based or consumer-directed, and read the bulletin that applies to you: Home Health Agency Bulletin 94 or Group Adult Foster Care Bulletin 6.
- Confirm the aggregator each of your payers uses, whether the state Sandata aggregator or a plan that runs on HHAeXchange.
- Decide between the free state Sandata system and an alternate EVV system that fits your workflow.
- Register in the EVV system and finish setup before you rely on it for live claims.
- Make sure every visit captures all six data elements at the point of care, not later.
- Reconcile caregiver names, employee IDs, and service codes across scheduling, EVV, and billing so they match on submission.
- Track your EVV match rate every month and close gaps before they reach the claims-edit stage.
- Train caregivers and office staff on the exact check-in and check-out process, and keep that documentation current.
How the Right EVV Software Reduces the Burden
None of this requires an agency to rip out the systems it already runs. The Cures Act and MassHealth care about the data reaching the aggregator correctly, not about which brand of software produced it. A focused EVV tool captures the six elements with a simple check-in, validates the record before it becomes a claim, and transmits it in the format the state or plan expects. When verification is that light to use, caregivers do it on every visit, which is what keeps a match rate high. MyVisits was built for this role. It handles verification and sends clean data to the aggregator while working alongside the scheduling, clinical, and billing tools your agency already depends on.
Frequently Asked Questions
- Does Massachusetts require EVV for home health, or only personal care? Both. The Cures Act and MassHealth cover Medicaid-funded in-home personal care services and home health services.
- Do we have to use the state's Sandata system? No. You can use the free state system or an alternate EVV system that transmits the required data to the aggregator.
- What happens if a visit is missing its end time? The claim usually cannot be validated. It will be rejected until the record is corrected and resubmitted.
- Where do the official rules live? On mass.gov under Electronic Visit Verification, and in the MassHealth Home Health Agency Bulletin 94 and Group Adult Foster Care Bulletin 6.
Sources and Official References
- Mass.gov, Electronic Visit Verification (EVV), including Learn about EVV, EVV for Agency-based Providers, and EVV for Consumer-directed Programs.
- Mass.gov, EVV implementation service code table.
- 21st Century Cures Act, Section 12006 (Public Law 114-255).
- MassHealth Home Health Agency Bulletin 94 and Group Adult Foster Care Bulletin 6.
- Sandata Technologies, Massachusetts EVV vendor and data aggregator.
