EVV Compliance for Home Care Agencies
Atlas monitors and manages EVV data so your agency stays compliant with the 21st Century Cures Act and avoids audit failures.
Read moreTexas EVV exception types, correction workflows, and documentation requirements for Sandata and HHAeXchange — a reference guide for home care agencies.
By Atlas Care Team·Updated July 8, 2026
Talk to UsYou can have a fully trained caregiver, a signed care plan, and a completed visit — and still lose the claim if the EVV data doesn't hold up. That's the reality of electronic visit verification in Texas: the technology captures the visit, but a person has to make sure the data is correct. When it isn't, you have an exception. When exceptions aren't resolved properly, you have denied claims, audit exposure, and eventually MCO scrutiny.
This guide covers what each exception type means, how Sandata and HHAeXchange categorize them, what the correction process looks like in each system, and what documentation you need to keep your agency audit-ready.
An EVV exception is any visit record where the required verification data is missing, incomplete, or doesn't match what was authorized. Texas requires six data points for every Medicaid-funded personal care visit:
When any of these six elements is absent or conflicts with what's on file, the visit generates an exception. The exception has to be reviewed, and in most cases corrected, before the claim can move forward cleanly.
Exceptions aren't automatically claim denials. They're flags that require human attention. The problem is volume — agencies with 20, 50, or 100+ caregivers generate dozens of exceptions every week, and each one requires individual review. Without a defined workflow, they pile up.
The caregiver arrived at the client's home and provided care but never opened the EVV app to start the visit. This is the most common exception in every Texas agency we work with. The visit happened — but there's no electronic record of it starting.
Resolution: A manual entry is required. You need the caregiver's confirmation of the actual start time, a documented reason for the missed clock-in, and a supervisor authorization before the visit can be entered.
The caregiver clocked in but didn't close the visit at end of shift. The system either records an open visit (which blocks the next day's clock-in for that client) or — worse — records an artificially long visit if the system auto-closes at midnight.
Resolution: Same manual correction process as missed clock-in, but you're correcting the end time specifically. Check for downstream errors: if the auto-close created a visit duration outside the authorized range, that triggers a second exception.
The caregiver clocked in using the app, but the GPS coordinates at clock-in or clock-out fall outside the verified radius of the client's service address. This happens when the caregiver clocks in from the car instead of inside the home, when apartment buildings create GPS drift, or when the client's address on file doesn't match the actual GPS coordinates of their unit.
Resolution: If the service was delivered at the correct location, you need documentation confirming it: a note from the caregiver explaining the discrepancy, confirmation from the client or a supervisor, and a corrected entry with the explanation documented in the exception record. If the client's address on file is wrong, update it — and audit any prior exceptions that may have been flagged for the same reason.
The visit was clocked in and out, but the total duration is outside the range specified in the authorization. This could be shorter than the minimum authorized duration (suggesting the caregiver left early) or longer than authorized (suggesting unauthorized additional hours were worked).
Resolution: Short visits require confirmation that all authorized tasks were completed. If the visit was legitimately shorter, the claim should reflect the actual time, not the authorized time. Long visits require authorization verification — was an extension approved? If not, the claim should be limited to authorized hours, and the excess time documented.
The EVV record shows a different service type than what was authorized for that visit. This often happens when a caregiver is scheduled for multiple service types across different clients and selects the wrong service when clocking in.
Resolution: Correct the service code in the EVV system to match the actual service delivered, confirm it matches the client's active authorization, and document the reason for the correction. Do not bill for a service that wasn't authorized even if the caregiver delivered it.
The visit was clocked in under a different caregiver than the one scheduled and authorized for that client. This happens with last-minute shift swaps where the schedule wasn't updated, or when a caregiver logs into another caregiver's profile.
Resolution: Verify which caregiver actually delivered the service. If it was an authorized substitute, update the EVV record to reflect the actual caregiver and document the schedule change. If the substitute was not authorized for that client, there may be a broader authorization issue to address.
A manual entry occurs any time someone at the office enters visit data instead of the caregiver using the app or telephony system. Manual entries are allowed — but they are the most scrutinized exception type in any audit. Every manual entry tells an auditor "someone at the office decided what time this visit started and ended," and that requires a high standard of supporting documentation.
Texas uses Sandata as its EVV aggregator through TMHP (Texas Medicaid & Healthcare Partnership, administered by Gainwell Technologies). Agencies that use Sandata Mobile Connect as their EVV app interact with exceptions directly in the Sandata portal. Agencies using a third-party EVV system (HHAeXchange, AxisCare, etc.) transmit visit data to the Sandata aggregator, and exceptions may surface in either the agency's system or the Sandata portal, depending on where the data mismatch is detected.
In the Sandata portal:
Key Sandata correction rules for Texas:
HHAeXchange is the most widely used agency management system in Texas Medicaid home care. It has its own internal exception tracking layer that sits between your agency's scheduling data and the Sandata aggregator.
How HHAeXchange categorizes EVV exceptions:
The correction workflow in HHAeXchange:
Transmission rejections are the most operationally disruptive exceptions because they affect claims directly. If a visit transmits to Sandata and gets rejected, the claim for that visit cannot process through TMHP until the rejection is resolved at the aggregator level. Some transmission rejections can be corrected at the HHAeXchange level and re-transmitted; others require intervention directly in the Sandata portal.
Whether you're working in Sandata, HHAeXchange, or another EVV platform, the correction process for a billable exception follows the same structure:
Step 1: Identify the exception within 24 hours. Pull exception reports every morning before 10am. Every day you wait makes corrections harder and documentation thinner.
Step 2: Classify the exception. Is this a GPS issue? A missed clock-in? A duration problem? Classification determines the documentation required.
Step 3: Contact the caregiver if needed. For any exception where the actual service data is in question, get caregiver confirmation before correcting. For clock-in/out exceptions, confirm the actual start and end times. For location exceptions, confirm where service was delivered.
Step 4: Collect caregiver attestation. For manual entries and any exception where you're correcting time or location data, document the caregiver's confirmation in writing — even a text message screenshot can serve as supporting evidence. A formal attestation form is better.
Step 5: Enter the correction with a specific reason code. "System error" is not a reason code. "Caregiver forgot to clock in — confirmed via attestation attached" is a reason code. Specificity matters in audits.
Step 6: Obtain supervisor authorization. Every manual correction should be authorized by a supervisor, not just the scheduler or EVV coordinator. This creates a separation of duties that auditors look for.
Step 7: Confirm transmission. If your EVV system feeds into the Sandata aggregator, verify that the corrected record transmitted successfully before closing the exception.
Step 8: Log the resolution. Keep a running exception log — date of visit, exception type, date identified, date resolved, who corrected it, and resolution method. This log is what you produce when a payer or state auditor asks for your EVV compliance history.
The most common audit finding isn't that agencies delivered services that didn't happen. It's that agencies can't prove the services they did deliver were compliant with EVV requirements. Documentation is the difference.
For every manual entry, keep:
Texas TMHP and MCO auditors will specifically examine:
Retention: Keep EVV exception records and supporting documentation for at least six years. TMHP's standard audit lookback is five years, and MCOs may have their own retention requirements. Six years provides margin.
A few Texas rules that affect exception management specifically:
TMHP billing window: Claims submitted to TMHP for Medicaid-funded personal care services must be submitted within 95 days of the service date. EVV exceptions that aren't resolved before billing cutoff can cause claims to miss this window permanently.
MCO EVV compliance thresholds: Texas STAR+PLUS managed care organizations — Superior Health Plan, Molina Healthcare, UnitedHealthcare Community Plan, and Aetna Better Health — each monitor provider EVV compliance rates. While specific thresholds vary by contract, most agencies report that rates below 95% attract MCO attention. Rates below 90% risk corrective action notices that require documented improvement plans.
Telephony as an alternative: When an agency client doesn't have reliable GPS signal (common in rural Texas and some apartment buildings), telephony via the client's landline is an acceptable alternative verification method. If your agency uses telephony, the call record itself serves as the EVV record — document the method used consistently so the verification type on record matches the actual method.
Supplemental Nutrition Assistance and CFC services: Texas Community First Choice (CFC) services have additional documentation requirements on top of standard EVV. If your agency provides CFC services, confirm that your EVV system captures any CFC-specific data elements required by your MCO contracts.
EVV exception management requires consistent daily attention from someone who understands both the EVV system and the billing rules downstream. In agencies without a dedicated person, this work typically falls to the owner — who ends up reviewing exception reports at 7pm instead of growing the business.
The alternative is a back-office team that handles exception review as a defined daily function: pulling reports every morning, contacting caregivers for attestations, entering corrections with proper documentation, and maintaining the exception log for audit readiness.
See how Atlas home care virtual assistants manage EVV exceptions for Texas agencies →
For a broader overview of EVV compliance requirements in Texas — including what the 21st Century Cures Act mandates and how payers enforce compliance — see our EVV Compliance guide for home care agencies.
Tell us about your agency and we'll scope exactly what you need, no commitment required.
Talk to Us →Atlas monitors and manages EVV data so your agency stays compliant with the 21st Century Cures Act and avoids audit failures.
Read moreThe Atlas billing team manages claims, tracks denials, and chases down reimbursements — so your cash flow doesn't depend on your follow-up.
Read moreThe Atlas compliance operations team tracks training deadlines, maintains documentation, and flags issues before they become survey findings.
Read moreAn EVV exception is any visit record where the electronic verification data is incomplete, mismatched, or missing. Common examples include a caregiver who forgot to clock out, a GPS location that doesn't match the client's service address, a visit duration that falls outside the authorized range, or a visit entered manually because the app wasn't used. Every exception requires review and — if the visit was legitimate — a documented correction before the claim can be submitted.
Texas Medicaid through TMHP requires claims to be submitted within 95 days of the service date. That's the hard deadline — but waiting that long is operationally dangerous. Best practice is to resolve EVV exceptions within 24 hours of the visit. The longer you wait, the harder corrections become: caregivers forget exact times, documentation gaps widen, and a batch of old exceptions looks far worse in an audit than the same exceptions resolved same-day.
A defensible manual EVV entry in Texas requires four things: (1) a specific documented reason for the manual correction — not just 'caregiver error' but the actual cause (app crash, telephony outage, verified GPS failure); (2) a signed caregiver attestation confirming the service time, client name, and service type; (3) supervisor authorization on the correction; and (4) any supporting records such as telephony call logs, system outage confirmations, or prior authorization documents. TMHP auditors and MCO reviewers expect to see all four components when they pull a manual entry.
Yes. EVV exception management is one of the most common tasks handled by trained home care back-office specialists. The work happens entirely inside your existing EVV system — HHAeXchange, Sandata Mobile Connect, AxisCare, or whichever platform your agency uses. A remote team can pull daily exception reports, contact caregivers for attestations, enter corrections with documented reasons, and maintain the audit log — without being on-site. Most Texas agencies that use a dedicated back-office team report same-day exception resolution as a consistent standard.