Regulatory watch

Missouri EVV requirements and claim denials

By the LockProof Team · Last updated October 9, 2026

Missouri writes its EVV requirements into a state rule, 13 CSR 70-3.320, and carries them out through MO HealthNet bulletins. MO HealthNet Bulletin 48-52 reports a soft launch of claims matching, initiated on January 7, 2026, and schedules denials from April 1, 2026 for personal care and related services that have no matching visit in the state’s aggregator. Bulletin 48-59 scheduled home health from June 1, 2026. The state runs an open vendor model, and GPS is one of several ways a system may record a visit. This page reads the rule and the bulletins and links each one; it gives no legal advice.

Ten Missouri sources stand behind this page, each read on October 9, 2026: the EVV rule in the Code of State Regulations and the sanctions rule beside it, the statute on visit tracking, MO HealthNet’s EVV program page, the Department of Social Services’ setup and vendor pages, a March 2026 hot tip, two MO HealthNet provider bulletins, and the state’s Medicaid audit unit’s provider posts. What a given agency owes, or how to answer a denied claim, is outside this page; the department and counsel are where those go.

A rule on the books, denials arriving in phases

Missouri’s rule has been in force since 2021. What changed in 2026 is that claims began to be matched against the visits the rule asks agencies to record.

Piece	Where it stands	In short	Source
The state rule	13 CSR 70-3.320 — in force. First effective January 30, 2021; latest amendment effective November 30, 2024.	Which services use EVV, how visits are collected and corrected, and what a system keeps.	13 CSR 70-3 (PDF)
Soft launch	Claims matching, soft launch — from January 7, 2026. Alerts only.	Remittance advice carried a generic alert, code N363, where a claim found no matching visit.	Bulletin 48-52
Phase one	Phase one denials — scheduled April 1, 2026. Provider types 26 and 28.	Personal care, advanced personal care, consumer-directed, homemaker, chore and respite claims authorized by the Division of Senior and Disability Services.	Bulletin 48-52; hot tip of March 23, 2026
Phase two	Phase two denials — scheduled June 1, 2026. Provider type 58.	Home health claims that lack a matching visit.	Bulletin 48-59
Phase three	Phase three — no date published. Provider type 85.	Developmental-disabilities services and Brain Injury Waiver personal care.	Bulletin 48-59

Missouri’s sources as read on October 9, 2026, this article’s review date.

The phase dates are the bulletins’ own schedule. None of the ten sources reports that a phase went live, so this page gives them as scheduled dates rather than events. The rule itself is a different kind of thing: its statement of purpose, as amended through November 30, 2024, warns that falling short of it “may result in claim denial or termination of contract”.

The rule in its own words

On scope, the Department of Social Services’ EVV program page, read October 9, 2026: “In Missouri, an Electronic Visit Verification (EVV) system must be used to document the delivery of personal care or home health care services under the Medicaid program.”
On location, 13 CSR 70-3.320 (linked from the Department of Social Services’ EVV page), as amended effective November 30, 2024: a system that is neither a designated landline nor a fixed object in the participant’s home “must use location technologies to record the location of the direct care worker at the start and stop of service delivery.”
On participants, the same rule as amended effective November 30, 2024, which the Department of Social Services’ EVV page links: those who “refuse to utilize an electronic system shall no longer be eligible to receive Medicaid funded services” covered by it, with the exceptions it lists.
On live-in caregivers, the Department of Social Services’ setup page: “No exclusions for live-in caregivers.”

An open model, with Sandata as the hub

Missouri does not hand agencies a single system. Its setup page describes an open model in which any EVV vendor may serve an agency once it connects to the EVV Aggregator Solution, which Sandata Technologies hosts. The department keeps a list of vendors that have passed Sandata’s testing and are sending data, and states that it does not endorse any of them. Agencies are told to log in to the aggregator at least weekly to check that their visits are arriving and are accurate.

Where GPS sits in Missouri

The rule names five ways an approved system may collect a visit: location technology, with GPS given as an example; a call from an established landline in the participant’s residence; a fixed device in the home that produces a one-time code; biometric recognition; or another technology that meets the rule. A landline or fixed device stands in for a location reading. Any other method records the worker’s location at the start and at the stop of the visit. GPS is therefore one option among several, which is how the department’s setup page lists it too.

Manual entries and corrections

Missouri treats a hand-entered visit as the exception. The rule reserves it for a system outage, for exigent circumstances the agency documents, and for correcting a human error the agency justifies. It asks for the date, time, reason and author of every manual entry or adjustment, and says a supervisor or administrator, not the worker or participant behind the original visit, should make a manual call-in or call-out. The aggregator receives each such visit with a manual-entry marker and a reason code. The rule also has the system keep the data for at least six years, and makes the system’s reports open to state and federal audit.

What the sources settle, and what they leave open

Settled by the sources: the rule’s text and dates, the open model and the Sandata-hosted aggregator, the soft launch from January 7, 2026, and the phase schedule for provider types 26, 28 and 58. Left open: a date for phase three, and any account of how the scheduled phases have run since. Missouri also has a statute on visit tracking that predates the rule. Under section 660.023 of the Revised Statutes, effective August 28, 2010, every in-home services provider agency was required to use a telephone tracking system by July 1, 2015, recording the exact date and the exact begin and end times of services, and the statute lets the Department of Health and Senior Services allow a more advanced tracking system that meets the same requirements. The rule cites two other statutes as its general authority, and this page does not characterise them.

LockProof, and what it is not

LockProof is not an EVV system. Missouri has not approved it as an EVV system, it is not on the state’s vendor list, and no MO HealthNet claim is matched against anything it holds. What it does: a caregiver opens a link we send by text message and photographs the visit, live, through it. Our server notes the time the photo comes in, the caregiver’s phone supplies the location only if the caregiver opts to share it, and the record is sealed under a fingerprint that makes a later edit detectable. The agency keeps that photo in its own file; it plays no part in Missouri’s EVV process.

Missouri’s aggregator tells MO HealthNet whether a claim has a verified visit behind it. A sealed photo is something else: what the caregiver’s camera captured at the visit, in a record whose later edits would show. Running the two side by side is the subject of photo apps kept alongside EVV, and how a single capture works is shown step by step.

The edges of this page

The rule PDF we read is the Secretary of State’s copy dated October 31, 2024, and the bulletins are the ones posted through May 2026; a later bulletin could move a date we report. Nothing here has been checked against any agency’s waivers, authorizations or managed care contracts, which is work for counsel. Missouri sits with the other states we cover on the state-by-state EVV hub, beside Pennsylvania’s EVV layers.

Common questions

How does GPS fit Missouri’s EVV rule?

As one option among five. Missouri’s rule, 13 CSR 70-3.320, as amended effective November 30, 2024, lets an approved system collect visits by location technology such as GPS, by a landline in the participant’s home, by a fixed device in the home, by biometric recognition, or by another approved technology. When a system uses anything other than that landline or fixed device, the rule has it record where the worker was when the visit began and when it ended.

When do Missouri EVV claim denials start?

MO HealthNet Bulletin 48-52, posted March 19, 2026, scheduled the first phase for April 1, 2026: claims for services authorized by the Division of Senior and Disability Services, provider types 26 and 28, that have no matching visit in the EVV Aggregator Solution will be denied. Bulletin 48-59, posted May 12, 2026, set home health, type 58, for June 1, 2026, and gave the developmental-disabilities phase, type 85, no date yet.

Can a Missouri agency choose any EVV vendor?

It can. The Department of Social Services describes an open model on its setup page: an agency may run any EVV system whose vendor connects to the EVV Aggregator Solution that Sandata Technologies hosts for the state. The department publishes a list of vendors that have passed Sandata’s testing, and says it endorses none of them.

When may a Missouri agency enter a visit by hand?

In set cases, under 13 CSR 70-3.320 as amended effective November 30, 2024: when the EVV system is unavailable, when documented exigent circumstances make using it impossible or impractical, or to correct a human error the agency justifies. The agency records why, when and who; the rule says a supervisor or administrator should make a manual call-in or call-out, not the worker or participant behind the visit; and the entry reaches the aggregator flagged as manual.

Does LockProof count toward Missouri’s EVV rule?

Not at all. LockProof is not an EVV system: nothing it records travels to the EVV Aggregator Solution, it appears on no state vendor list, and no claim is matched against it. Some agencies keep it next to their existing EVV setup, as a separate photo file for when a relative or a payer raises a question with the agency itself.

Is anything here legal advice?

No. This page sets out the content of ten Missouri sources, each read on October 9, 2026, with a link to each. Whether a service, a provider type or a phase reaches a given agency, and what that agency should do about a denied claim, are for counsel, or the Department of Social Services, to answer.