Ohio EVV and GPS: what 2026 actually requires

One statute, three layers, and only one of them is finished

The statute is in effect. The GPS duty inside it lives in standards Ohio Medicaid has not published yet. The rules that decide who is exempt, and when everyone moves, are ones Ohio Medicaid anticipates for July 2027. Almost every write-up about Ohio flattens those three into one.

Status of each layer as at November 2, 2026 — the review date shown at the top of this article.

Read down the Status column and the useful question stops being a yes-or-no question about GPS. It becomes three questions: whose clock-ins, under which standards, and from when. The statute answered the last one on October 6, 2026. For the rules, Ohio Medicaid’s September 28, 2026 deck gives the date it anticipates, July 1, 2027. The first two questions are still being written — the part a vendor pitch is least likely to tell you.

What the statute actually says

It is codified rather than written into the bill documents, and it reads narrower and more precisely than the summaries of it.

Revised Code 5164.42 is titled “Electronic visit verification requirements.” Its page now reads “Effective: October 6, 2026,” and lists its Latest Legislation as Senate Bill 315 of the 136th General Assembly. Since October 6, 2026, division (B)(1) has required 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), in force from October 6, 2026, 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. Since October 6, 2026, division (B)(3)(b) has required 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 is dated, it sits inside standards the department has not yet written, and its carve-out is in the statute rather than left to a rule.

And division (E) is why this page will not tell you what changes for your agency now. 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 were not adopted when this page was reviewed on November 2, 2026. A statute in force with its phase-in schedule unwritten is ordinary in Medicaid administration and awkward to plan against, and anyone telling you exactly how it lands for your agency this year is telling you something the state has not published.

The section also places a duty on the department itself before it acts on a claim. Since October 6, 2026, division (C)(2) has required that, before any denial, suspension, deferral or recoupment under (C)(1), “the department shall provide affected providers with notice, training, technical assistance, and compliance education regarding claim validation requirements established under this section.” That sentence describes what the statute asks of Ohio Medicaid; how the department carries it out is in the rules that are not yet adopted.

One more section took effect 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 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 says today

Ohio Medicaid says its EVV policy has not changed yet. Its current rule makes GPS consent-based, and the consent belongs to the person receiving care.

In its September 28, 2026 EVV stakeholder workgroup deck, Ohio Medicaid gives a slide the title “No Immediate Change in EVV Policy” and says that “Current EVV rules remain in place until the OAC is officially revised.” For the proposed changes, the same deck anticipates “July 1, 2027, as the effective date for Ohio Administrative Code modifications required to implement program changes, including updated live-in-caregiver and GPS requirements.”

The codified rule behind that statement is Ohio Administrative Code 5160-32-02, the EVV data-collection rule, effective October 30, 2025. Its division (E) provides that GPS functionality “may be used only upon obtaining the signed consent of the individual receiving the service,” renewed every year and revocable at any time. Not the provider’s choice, and not the worker’s either: the consent belongs to the person receiving care. As of November 2, 2026, Ohio Medicaid’s October 27, 2026 deck repeats the September slides and says that rule is still in force, and it is the sentence to hold a vendor against when one tells you the state already mandates GPS.

Location is a separate question from GPS. Ohio Medicaid’s EVV page, in the version that loaded on November 2, 2026, treats location at the start and end of a visit as either the individual’s home or the community — a category, not a coordinate trail — and says it outright: “GPS and location are not interchangeable terms.”

The system Ohio already runs

Senate Bill 315 did not start Ohio’s EVV. A state-provided system has run since 2018, and providers may use a certified one of their own instead.

Ohio Medicaid’s EVV page, read on November 2, 2026, says that “Agency Providers and Independent Providers can choose to use the state-provided Sandata system or an Ohio certified alternate EVV system.” Its July 2026 fact sheet names the vendor: “ODM contracts with Sandata Technologies, LLC to provide the EVV system.” Alternate systems feed the same place: the EVV page, in its November 2, 2026 text, describes approved alternate vendors as able to “successfully submit the data to the Sandata Aggregator.” The same page says that, because of the changes Senate Bill 315 brings, processing of all alternate-vendor applications, pending ones included, is “temporarily paused until updated program requirements are established.” That page answers on some visits and not on others; the same arrangement is in documents that open reliably. The fact sheet puts it for agencies, “An agency provider may choose to use an alternate system,” and the department’s EVV FAQ, updated April 28, 2026, refers to providers logging in to the “Sandata Aggregator system.”

The start dates come from the department’s own EVV FAQ of September 2019. Phase 1 “began on January 08, 2018,” for services including state-plan home health aide and nursing, private duty nursing, RN assessments, and the Ohio Home Care Waiver’s nursing, personal care aide and home care attendant. Phase 2 “began on August 05, 2019,” for services including PASSPORT personal care, the developmental-disabilities homemaker/personal care service, and the MyCare waiver’s personal care aide. Ohio Medicaid’s current page puts it in one line: “ODM started its EVV program in 2018.”

What Ohio Medicaid proposes for 2027

Ohio Medicaid has now written down what it intends. It has not adopted it, and the difference is the part worth knowing.

Describing its proposed rules under SB 315, the September 28, 2026 deck says that “GPS capture at the start and end of each visit will be required for all workers providing home- and community-based services (HCBS) unless the individual is eligible for GPS location capture waiver.” It lists three groups who would qualify for that waiver: people enrolled in Ohio’s Address Confidentiality (Safe at Home) Program, people who live with a family member who is also their direct care worker, and people who meet the developmental-disability criteria in RC 5164.42, which enrollment in a DODD waiver program satisfies.

The same deck proposes narrowing the live-in caregiver exemption. Today, it says, any caregiver who lives in the same residence may apply to be exempt from EVV data collection; under SB 315, “Only individuals with a developmental disability, residing with their direct care worker will be eligible for a live in caregiver exemption.” On manual entry it is direct: entry by hand “will remain permitted when a caregiver cannot safely stop providing care,” and providers may keep correcting, or “curing,” records with missed clock-ins and clock-outs.

Hold that beside the statute. The statute’s carve-out takes a family caregiver at the same residence out of GPS specifically, while a validated EVV record remains a condition of payment; the waiver and exemption changes are how Ohio Medicaid proposes to put that into practice, and none of them is adopted yet. Ohio Medicaid’s June 5, 2026 newsletter had described the package more broadly, under the heading “Mandatory GPS for All EVV Systems,” and said the proposed changes “were posted for initial public comment and ODM is reviewing those comments.” The September deck is the department’s later, narrower account. The same newsletter recorded a moratorium on new home-health and hospice enrollments from May 14, 2026, in effect until November 14, 2026 unless CMS authorizes an extension.

The executive order, and why it is not quoted here

Executive Order 2026-01D, dated May 18, 2026, is described two different ways in the sources that could be read. News coverage ties it to GPS; a law-firm summary says it authorizes emergency rules on Medicaid provider revalidation. Its text did not load from the Governor’s website when checked on October 6 and again on November 2, 2026, so on this page it is reported, not verified, and neither account is repeated as fact. For GPS, the account to rely on is Ohio Medicaid’s own, above: proposed, and anticipated for July 1, 2027.

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

Ohio is on our regulatory watch list because agencies working through these changes 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 in force, but the standards and rules that decide how it applies are not adopted, so every sentence here about GPS timing describes text and a proposal rather than practice. The rule status is a snapshot taken on November 2, 2026: rulemaking can move in a week, and Ohio Medicaid’s next deck or 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 statute with a date attached. It is walked through in the note on manual-edit percentages. The other states, and which ones we have covered so far, are on the EVV requirements by state page. On the other axis entirely — telling workers they are monitored at all — the reference is the state-by-state notice rules.