Ohio EVV and GPS: what 2026 actually requires

One statute, three layers, and only two of them are finished

The statute is written and dated. The GPS duty inside it is real but lives in standards the agency must still publish. The rules that decide who is exempt and who goes first are not adopted. Almost every write-up about Ohio flattens those three into one.

Status of each layer as at September 25, 2026 — the review date shown at the top of this article.

Read down the Status column and the useful question stops being “is GPS required in Ohio” and becomes “required of whom, under which standards, and starting when.” The last answer is October 6, 2026. The first two are still being written, which is the part a vendor pitch is least likely to tell you.

What the statute actually says

It was not in the bill documents. It is codified, and it reads narrower and more precisely than the summaries of it.

Revised Code 5164.42 is titled “Electronic visit verification requirements.” It carries the banner “Section 5164.42 is not yet in effect. It takes effect October 6, 2026,” and lists its Latest Legislation as Senate Bill 315 of the 136th General Assembly. Division (B)(1) requires the department of medicaid to make every claim for an EVV-covered service “supported by a validated electronic visit verification record as a condition of payment.” Division (B)(3)(a) requires the standards to have providers clock in and out “when physically present at the location where services are being provided.”

Then the sentence everything else is built on. Division (B)(3)(b) requires the standards to “[e]xcept for in-home care services provided by a family caregiver that resides at the same residence as the individual receiving services, utilize GPS-based verification to track when a provider clocks in and clocks out.” Division (A)(2) defines GPS-based verification as “real-time satellite location data that can be used to confirm the physical presence of a person or device in a specified location.” So the duty is real, it arrives on a date, it sits inside standards the department has to write, and it has a carve-out written into the statute rather than left to a rule.

And division (E) is why this page will not tell you what to do on the 6th. It directs the medicaid director to adopt rules under section 5164.02 to implement the section, including “[g]ood-cause exemptions” and “[p]hased implementation schedules by provider type or service category.” Those rules did not exist when this was written. A statute that takes effect with its phase-in schedule still unwritten is a normal thing in Medicaid administration and an abnormal thing to plan against, and anyone telling you exactly how it lands for your agency in October is telling you something the state has not published.

One more section arrives the same day. Revised Code 5164.421 builds a separate layer for providers the department classifies as high-risk — on criteria including repeated check-in mismatches, impossible travel times, claims overlapping a recipient’s hospital stay, and billing outliers — who must then verify through “fingerprint scanning, facial recognition, vocal recognition, a secure personal identification number, or other approved verification method.” It also forbids the department from selling or distributing EVV data. There is no consent provision in it, and no GPS provision either.

What Ohio Medicaid requires today, before the 6th

GPS is optional and consent-based, and the consent belongs to the person receiving care. Location is required and is not the same thing.

The agency’s electronic visit verification page lists six required elements: the type of service performed, the individual receiving the service, the date of the service, the location of service delivery, the direct care worker providing the service, and the time the service begins and ends. Those mirror the federal Cures Act elements. Location, on that page, is recorded at the start and end of the visit and reported as either the individual’s home or the community — a category, not a coordinate trail. The page says it outright: “GPS and location are not interchangeable terms.”

The codified rule behind that page is blunter still. Ohio Administrative Code 5160-32-02 — the EVV data-collection rule, effective October 30, 2025 — provides that GPS functionality “may be used only upon obtaining the signed consent of the individual receiving the service.” Not the provider’s choice, and not the worker’s either: the consent belongs to the person receiving care. That rule has not been withdrawn, and division (E) of the new statute is what would eventually replace it. Until then, it is the rule in force, and it is the sentence to hold a vendor against when one tells you the state already mandates GPS.

The proposed rules, and the order nobody has produced

A separate rule package has been sitting in comment since spring. It overlaps the statute without matching it, and the difference is the part worth knowing.

Ohio Medicaid’s June 5, 2026 EVV newsletter describes “Global Positioning System (GPS) location capture for every provider using EVV,” and says live-in and family caregivers “previously exempt from EVV, will now be required to log all homecare services through EVV.” Per-diem services — structured family caregiving, shared living, and respite delivered outside an institution — would come under EVV as well. The newsletter’s own framing is the part that matters: the changes “were posted for initial public comment and ODM is reviewing those comments.” Proposed is not adopted, and no adoption instrument turned up when we looked on September 25, 2026.

Now hold that beside the statute, because they are not the same instrument doing the same thing. The proposal reaches whether live-in and family caregivers must use EVV at all. The statute’s carve-out is narrower and points the other way: family caregivers at the same residence are excepted from GPS specifically, while a validated EVV record remains a condition of payment. A reader who merges those two ends up believing either that family caregivers are about to lose every exemption, or that they have one they do not have. The same newsletter records an enrollment moratorium on new home-health and hospice providers, May 14 through November 14, 2026 unless extended. A provision that would have withdrawn Medicaid payment from people caring for family members at home was reported as removed from SB 315 before passage.

There is also a May executive order, reported to expand EVV and mandate GPS. Its text has not been located, in this session or the one before it, so it stays here as reported rather than verified. Ohio Medicaid’s page does carry a dated May 13, 2026 note that the Governor announced fraud-prevention initiatives and that alternate-EVV vendor applications are paused, which corroborates that something was announced without evidencing what it said.

What we are, and what we are not, in one paragraph

Ohio is on our regulatory watch list because agencies with October 6 on the calendar are the people who read us; the review date sits at the top. Keeping the two things apart is not modesty, it is the whole point. Ohio wants machine confirmation that a visit happened when it was claimed to have happened, and a certified system answers that. Nobody asks a photograph that question. What a photograph can settle is narrower and sometimes more useful: what the room looked like, on a record that cannot be quietly revised afterwards. How a second file is supposed to sit next to a certified one rather than elbow it aside is worked through in the companion piece on running one alongside EVV; the mechanics are set out under caregiver visit proof.

The limits of what is written here

Three limits, stated plainly. The statute is quoted here from the codified future version and it is not yet in effect, so every sentence about October 6 describes text rather than practice — and division (E)’s implementing rules, which are where exemptions and phase-in actually get decided, did not exist on the review date. The rule status is a snapshot taken on September 25, 2026: rulemaking can finish in a week, so a package described here as pending may have been adopted by the time you read this, and ODM’s next newsletter is where you would find out. And no part of this has been measured against a specific provider’s waivers, programs or contracts. It could not be. That reading is what counsel is for, and no vendor — us included — can stand in for it.

Pennsylvania picked a different instrument for the same worry, and the comparison is worth ten minutes: a percentage threshold policed through quarterly alerts, rather than a fresh verification mandate with a date attached. It is walked through in the note on manual-edit percentages. On the other axis entirely — telling workers they are monitored at all — the reference is the state-by-state notice rules.