Regulatory watch

Illinois EVV requirements, program by program

By the LockProof Team · Last updated October 20, 2026

This is a reading of Illinois’ published EVV texts, not legal advice. Illinois runs a hybrid model: an agency can use the state’s HHAeXchange system at no cost or its own qualified system, provided the visit data ends up in HHAeXchange. For State Plan home health, a Department of Healthcare and Family Services notice of February 10, 2026 makes the 75 percent line, required by September 30, 2025, a quarter-by-quarter count and adds a mobile app that records GPS as each visit opens and closes, both from April 1, 2026. The texts are linked below.
Illinois Department of Healthcare and Family Services (HFS) texts behind this page, read October 20, 2026:They make GPS a duty for State Plan home health only. Agency-specific questions are for counsel, a health plan, HFS or the program’s operating agency.

Illinois EVV, step by step

The program paying for a visit decides which Illinois EVV texts apply to it.

LayerDateWhat it setSource
VendorMarch 2022.HHAeXchange chosen as the state’s EVV vendor and aggregator.HFS EVV page
DD waiversSept. 1, 2023.Personal care under the two developmental disabilities waivers starts on EVV.HFS EVV page
Home healthDec. 31, 2023.Medicaid home health agencies go onto HHAeXchange or send it data from their own system.HFS EVV page; HCBS-EVV-24-02
Aging and DRSMar. 2, 2026.Department on Aging and Division of Rehabilitation Services providers join HHAeXchange.HFS EVV page
75 percent lineSept. 30, 2025.State Plan home health agencies are due to reach 75 percent of visits with no hand entry or later adjustment.HCBS-EVV-24-02
State Plan home healthApr. 1, 2026.For State Plan home health: a GPS-capable mobile app, the 75 percent line counted quarter by quarter, and a three-step response to misses.HCBS-EVV-24-02

Dates are the ones each HFS text gives for itself; the texts were all opened on October 20, 2026.

In the Department’s words

On the model, the Department of Healthcare and Family Services’ EVV page, published October 7, 2026, says, “Illinois is a hybrid state where agencies can use any qualified EVV vendor, but EVV information must still be submitted to HHAeXchange.” On location, the Department of Healthcare and Family Services’ notice of February 10, 2026 tells State Plan home health agencies they are required, from April 1, 2026, to use a mobile app that records GPS location as service delivery begins and ends, and adds, “Capturing location of service delivery is both a State and Federal requirement.” On exceptions, the policy behind that notice is blunt: “HFS does not have any exemptions to this policy.”

State Plan home health from April 1, 2026

The policy, HCBS-EVV-24-02, covers home health agencies billing fee-for-service Medicaid, HealthChoice Illinois managed care plans or FIDE SNP plans; home health here means nursing and physical, occupational and speech therapy given in the home. Under the Department of Healthcare and Family Services’ notice of February 10, 2026, from April 1, 2026 those agencies must use HHAeXchange’s mobile app or a third-party vendor’s, and the app must capture GPS location when a visit starts and when it ends. The policy also points back to two earlier dates: agencies were to be on HHAeXchange or sending it data by December 31, 2023, and to carry each caregiver’s full Social Security number in that data by October 17, 2024.

The 75 percent line, quarter by quarter

The policy counts a visit toward the line only when it was recorded through EVV with no manual entry and no adjustment afterward, and a claim billed with no visit data behind it counts against the agency. The Department of Healthcare and Family Services’ home health EVV guidance, policy HCBS-EVV-24-02, says State Plan home health agencies were required to reach and maintain 75 percent by September 30, 2025. What changes on April 1, 2026 is the count: under the Department of Healthcare and Family Services’ notice of February 10, 2026, State Plan home health agencies must reach at least 75 percent in every state fiscal quarter, and a quarter does not carry over into the next. HFS’s December 9, 2025 update describes the switch as quarterly rather than year-to-date percentages. HHAeXchange sends agency administrators a “Know Your Numbers” report on the 15th of each month. One quarter below the line brings training modules within 30 days; a second in a row brings an action plan due within 10 business days and carried out within 20 business days of HFS approving it; a third brings a referral to the HFS Office of Inspector General. HFS’s December 9, 2025 update says letters of that kind went out in late October and early November 2025 to agencies serving home health or personal care and billing HFS, DDD or DSCC that fell under 75 percent for July to September 2025, or that billed EVV services without using EVV.

Personal care and the other programs

Personal care follows the program that pays for it. The HFS EVV page dates EVV for the two developmental disabilities waivers to September 1, 2023, and puts Department on Aging and Division of Rehabilitation Services providers into HHAeXchange on March 2, 2026. The Department of Healthcare and Family Services’ notice of February 10, 2026 says updated EVV policies for DSCC, DDD, DRS and the Department on Aging are forthcoming from each of those agencies, without a date. Managed care plans have a duty of their own: under the Department of Healthcare and Family Services’ listserv notice of April 9, 2026, Illinois plans must make sure their service authorizations reach HHAeXchange.

Live-in caregivers and claims

In a notice of May 10, 2023, HFS reversed an earlier decision and allowed a live-in exemption for the two DDD waivers; the HFS EVV FAQ adds that a caregiver applies for it and renews it each year, and that DDD is the only program offering one. On payment, the December 9, 2025 update answers that, for now, claims “are managed independently” of the EVV aggregation, so HHAeXchange does not currently produce them. The HFS texts read here describe training, action plans and referrals when an agency falls short, not an automatic claim denial; a managed care plan’s own rules were not read.

Documented and reported

Everything above comes from HFS’s own pages, policy, notices and listserv messages. The FAQ page mixes answers from 2022 to 2025, so this page uses it only where nothing newer speaks; its 2024 answer that the state did not then expect hard claims penalties is older than the 2026 policy and is not treated as current. HHAeXchange’s own Illinois pages were not used.

What this page does not cover

This page did not read any Illinois statute or administrative rule on EVV. The updated policies from DSCC, DDD, DRS and the Department on Aging were not yet published, and HFS’s April 16, 2026 message says that month’s Know Your Numbers figures for State Plan home health may not be accurate. Plan contracts and HHAeXchange’s technical specifications were not read.

What LockProof is to an Illinois agency

LockProof is not an EVV system. HHAeXchange and the systems linked to it are separate from LockProof, it sends no visit data to the state aggregator, and none of its photos count toward a State Plan home health agency’s 75 percent. Its job is narrower. From a link in a text, the caregiver’s phone opens its camera for a live photo, and our server logs the time the upload lands. The phone sends coordinates when the caregiver chooses to share location, and a company setting can refuse a photo that comes without a location reading; that reading is not the start-and-end GPS capture Illinois sets for a State Plan home health EVV app. Any later change to the record leaves its SHA-256 fingerprint mismatched.

EVV data flows to HHAeXchange for HFS and the plans. LockProof photos go to family members and private-pay clients who ask to see a visit. More on the difference: visit-photo tools used beside EVV, and the contents of a caregiver photo record.

How far this summary goes

The HFS texts listed above date from the October 20, 2026 reading, and the FAQ page is undated, so a newer HFS notice may not be reflected. Other states are listed in the EVV requirements index by state, among them New York and its Choice Model.

Common questions

Does Illinois require GPS for EVV?

For one group of agencies. The Department of Healthcare and Family Services’ notice of February 10, 2026 says State Plan home health agencies, the ones billing fee-for-service Medicaid, HealthChoice Illinois plans or FIDE SNP plans, are required to use a mobile EVV app that records GPS location when service delivery begins and again when it ends, starting April 1, 2026. Among the Illinois texts behind this page, none makes GPS a duty for personal care, or for services run by DSCC, DDD, DRS or the Department on Aging.

Which EVV system does an Illinois agency use?

HHAeXchange or a system that feeds it. HHAeXchange is the state’s EVV vendor and aggregator and costs agencies nothing, and the Department of Healthcare and Family Services’ EVV page calls Illinois a hybrid state: an agency may keep any qualified system so long as the visit data reaches HHAeXchange, and the HFS EVV FAQ says the agency pays for that system itself. Under the State Plan home health policy effective April 1, 2026, an agency whose third-party system cannot connect falls back on the free HHAeXchange option.

What is the 75 percent EVV line in Illinois?

A floor for State Plan home health agencies: at least 75 percent of visits, counting only visits recorded through EVV with no manual entry and no later adjustment, as policy HCBS-EVV-24-02 defines them. The Department of Healthcare and Family Services’ home health EVV guidance, that policy, says agencies were required to reach the line by September 30, 2025; per the Department of Healthcare and Family Services’ notice of February 10, 2026, it is counted each state fiscal quarter from April 1, 2026, and a quarter does not carry over. A quarter under the line brings training modules, a second one an action plan, and a third a referral to the HFS Office of Inspector General.

Can an Illinois live-in caregiver skip EVV?

Only in the developmental disabilities waivers. A Department of Healthcare and Family Services notice of May 10, 2023 opened a live-in exemption for the two DDD waivers, and the HFS EVV FAQ says the caregiver applies for it and renews it every year; until it is approved, EVV applies. The State Plan home health policy effective April 1, 2026 states that it has no exemptions at all.

Is LockProof an EVV system for Illinois agencies?

No. In Illinois, LockProof is not an EVV system: it is neither HHAeXchange nor a system linked to it, it sends nothing to HHAeXchange or HFS, and its location reading is not the start-and-end GPS capture Illinois sets for a State Plan home health EVV app. Agencies use it for a separate purpose, a visit photo that family or a private-pay client can open.

Is this page a source of legal advice for Illinois agencies?

No. It reports what Illinois HFS had published as of the October 20, 2026 reading. How a rule lands on one agency, waiver or plan member is for a lawyer, the plan, HFS or the operating agency to say, and the updated DSCC, DDD, DRS and Department on Aging policies that HFS calls forthcoming may change parts of it.

Visit photos for families, apart from the state system

LockProof is not an EVV system; HHAeXchange and Illinois HFS never receive these photos. Caregivers open a texted link and shoot a live photo, our server records when it arrives, and a SHA-256 fingerprint shows if the record changes later. Illinois certifies none of them.