Who is responsible for EVV compliance is the question that surfaces the moment something goes wrong with a visit record: a week of manual entries, an exception nobody cleared, a caregiver whose clock-ins never reached the state. For Medi-Cal personal care and home health agencies across the San Francisco Bay Area, the answer is short and the details behind it are not. The agency is responsible. Below are the questions agencies ask most often about what that means, what DHCS expects of the EVV administrator, and where the EVV vendor and the IT provider stop. This FAQ sits under our broader guide to IT for home care agencies.
1. Who is responsible for EVV compliance at a home care agency?
The provider agency is responsible for EVV compliance. Under California’s EVV program, any provider rendering Medi-Cal services subject to EVV must comply with the requirements DHCS and its partners establish for electronically verifying those services. That duty attaches to the agency’s enrollment, not to any vendor it hires.
A vendor contract can divide support duties. It cannot move the obligation. DHCS directs its requirements, and its remedies for noncompliance, at the provider agency, so an agreement that says the vendor “handles EVV” describes who runs the software, not who answers for the data.
2. What are the EVV administrator’s responsibilities under DHCS?
EVV administrator responsibilities under DHCS come down to four things: logging visit data consistently and completely, reviewing it for accuracy, correcting existing records, and entering manual visits when a compliant visit cannot be captured any other way. The administrator is the named person inside the agency who owns the record.
For agencies using an Alternate EVV system rather than CalEVV, DHCS adds a specific duty: the provider agency’s EVV administrator is responsible for ensuring the required EVV data elements are entered correctly into the third-party system before it forwards them to the state. All providers are also expected to monitor their visit data for correctness on an ongoing basis, which in practice means someone looks at the exception report every day, not at audit time.
3. Is the EVV vendor responsible for EVV compliance?
No. The EVV vendor is responsible for its system working and, for an Alternate EVV vendor, for completing Sandata’s certification process so the system can send data to the state. It is not responsible for the accuracy of what agency staff enter into it.
DHCS’s Alternate EVV user guide puts the remaining duty back on the agency: providers using Alternate EVV systems are responsible for ensuring their vendor sends client, employee, and visit data to the CalEVV Aggregator and that the data captured in their system is correct. The vendor builds the pipe. The agency is accountable for what flows through it.
4. Is the IT provider responsible for EVV compliance?
No. An IT provider supports the devices, connectivity, and accounts EVV depends on. It does not enter, review, or correct visit data, and it has no standing with DHCS. When a caregiver’s phone will not run the app or the office network drops during scheduling, that is the IT provider’s problem; whether the visit record that resulted is accurate is not.
This is the same line drawn in the blog on EVV vendor and IT provider support. The IT provider keeps the surrounding technology working so that fewer visits end up as manual entries. It cannot make a wrong record right.
5. What does the CalEVV Aggregator do, and does data reaching it shift accountability?
The CalEVV Aggregator is the read-only repository where jurisdictional entities review and verify the EVV data providers submit through CalEVV or an Alternate EVV system. DHCS, managed care plans, waiver agencies, and regional centers use it to confirm registered providers are submitting compliant visit data. Data reaching the Aggregator does not shift accuracy off the agency.
Visit information in the Aggregator cannot be edited there. A correction has to be made in the agency’s own EVV system and resubmitted. So an exception that shows in the Aggregator is still the agency’s exception, waiting on the agency’s administrator to resolve it at the source.
6. When did EVV become required, federally and in California?
Federally, the 21st Century Cures Act originally required states to adopt EVV for personal care services by January 1, 2019. P.L. 115-222 delayed that to January 1, 2020, and home health EVV was required by January 1, 2023. Those obligations fall on states, which faced federal funding reductions for missing them.
In California, PCS was implemented on January 1, 2022, and HHCS on January 1, 2023. Every EVV-impacted provider must be registered, trained, and using either CalEVV or a certified Alternate EVV system. An agency that met those dates still has a live question about who supports the technology behind them, which is where EVV IT support comes in.
7. Which services are subject to EVV in California, and which are excluded?
EVV covers Medi-Cal-funded personal care services and home health care services that require an in-home visit. DHCS publishes a provider types and codes document that identifies exactly which services are in scope. Several categories are excluded outright:
- Hospice services: not subject to EVV requirements.
- Live-in caregivers: a caregiver who regularly remains in the recipient’s home for more than 24 hours at a time is exempt, with an exemption form to complete.
- Medi-Medi plans: PCS and HHCS for dual-eligible members primarily paid by Medicare or other health coverage are not impacted.
- Self-directed IHSS and WPCS providers: individual providers paid directly by the state use CDSS’s IHSS EVV tools, not CalEVV. WPCS providers employed by a PCS agency do use CalEVV.
Home health agencies that are Medicare-only and see no Medi-Cal recipients are also outside the requirement.
8. Does California set a minimum electronic-capture rate for EVV?
No. DHCS’s CalEVV FAQ, updated May 2026, states that California has not set threshold compliance percentages. The same answer adds that whenever possible, and excluding emergencies, the state expects visits to be captured electronically rather than manually entered.
Manual entry is acceptable for one purpose: making sure a compliant visit is recorded when electronic capture failed. It is not a routine method. An agency whose manual-entry rate is climbing has a technology or routing problem upstream of the record, and the absence of a numeric threshold does not make that pattern invisible to a reviewer.
9. What can DHCS do if an agency is out of EVV compliance?
Under Welfare and Institutions Code section 14043.51(d), DHCS can respond to a provider’s EVV noncompliance with any of the following:
- Technical assistance on compliance
- A required, approved corrective action plan
- Recovery of associated overpayments
- Enrollment or monetary sanctions
- Any other remedial action DHCS deems appropriate
The scale of what unverified visits can represent is visible in HHS-OIG’s audit of Colorado’s Medicaid personal care EVV program, issued July 17, 2026. OIG estimated that 682,947 of 1,301,307 personal care claim lines in its sampling frame, or 52 percent, did not comply with federal and state EVV requirements, and recommended Colorado refund $8.0 million in federal share. That is Colorado, not California; the findings are directed at the state agency rather than at providers; and Colorado disputed most of them. The mechanism still applies here: EVV data that cannot be verified becomes a payment question.
10. Who does the EVV administrator call when a caregiver’s app fails?
The routing depends on the cause. A platform failure goes to the EVV vendor’s support desk, whether that is Sandata for CalEVV or, for the agencies we work with, the support team at HHAeXchange, AxisCare, Axxess, or WellSky. A device, connectivity, or email-account failure goes to the IT provider. A visit that happened but was recorded wrong goes nowhere; the administrator corrects it.
Picture a director of nursing reviewing EVV exception reports from a home network on a Sunday evening and finding a week of manual entries for one caregiver. Correcting those records is the EVV administrator’s job. Finding out why the app failed all week is a routing question, and our guide to escalating EVV issues at a home care agency walks through it step by step.
“We get asked to ‘take over EVV’ fairly often, and the honest answer is that nobody can. We can make sure the phone works and the caregiver can log in. We can also be the person you turn to when something it wrong and you don’t know who the right person is to fix it. What we cannot do is tell you whether that visit record is right. We consistently see that the most important step is ensuring that a problem gets routed to the right vendor with the right details so the problem is fixed as fast as possible. Doing so means ensuring caregivers don’t make manual entries a norm and less manual entries for your team to work around.”
Brendan Duebner, President of IT Total Care
Does working with an IT provider change who is responsible for EVV compliance?
No. Accountability stays with the agency. What IT Total Care takes on for home care and home health agencies across the Peninsula and the South Bay is the devices, connectivity, and accounts EVV depends on, not the EVV platform and not the visit data. The aim is to keep phone and network problems from forcing manual entries in the first place, so the EVV administrator spends the morning reviewing real exceptions rather than reconstructing visits that should have captured on their own.
Contact Us to talk through what your agency’s EVV administrator needs from the technology around them.
