Pennsylvania's EVV manual-edit threshold

The rule, in three numbers

• 85% — the share of a provider’s EVV visit records that must be verified without manual edits. Set by MA Bulletin 05-24-01 (PDF, pa.gov) — issued August 23, 2024, for dates of service on or after January 1, 2025.
• 15% — the manual-entry percentage above which DHS issues a quarterly alert. Those alerts began in January 2026. This is the same line as the 85% floor, stated from the other side: among the bulletin’s escalation factors is “the percentage of EVV records requiring manual edits during the review period, which reflects the magnitude of deviation from the 15% threshold.”
• Two — consecutive noncompliant quarters. For a fee-for-service provider that means a formal notice of noncompliance from the program office and a corrective action plan. For a provider in managed care it is the MCO, not the program office, that initiates corrective action.

What MA Bulletin 05-25-03 covers

The bulletin was issued and took effect on August 29, 2025. It reaches personal care services and home health care services across the ODP, OLTL, and OMAP programs. Providers in managed care are addressed through their MCOs rather than by DHS directly.

Beyond the alert and the corrective action plan, the bulletin describes escalation for continued noncompliance, weighed against a list of objective factors it sets out. The list is in the text, and reading it is the point of linking the text: MA Bulletin 05-25-03 (PDF, pa.gov).

A manual-edit threshold is not a no-match-no-pay edit

Two different enforcement designs are circulating in home care right now, and they are easy to collapse into one. A claim edit regime checks each claim at adjudication against the state aggregator and denies the ones with no matching verified visit — a per-claim, pay-or-deny mechanism. A threshold regime, which is what Pennsylvania’s bulletin describes, measures a percentage across a provider’s records over a quarter and responds with alerts, notices, and plans.

The practical difference is what a single bad visit record costs. Under a claim edit it can cost that claim. Under a threshold it costs a fraction of a percentage point, and only the accumulated fraction is enforced against. Secondary write-ups describing Pennsylvania as having moved to real-time claim rejection in mid-2026 are not supported by the bulletin, so they are not repeated here — if you have seen that claim, ask its author for the primary document.

Where LockProof sits, and where it does not

Agencies running EVV are the readers this page is for, which is why the bulletin sits in our regulatory watch — the last-updated date above shows this page’s most recent review. The separation above is not a disclaimer bolted onto the end — it is the whole relationship between the two systems. An EVV record answers a payer’s question about whether a visit was electronically verified. A sealed photo answers a different question: what the visit looked like, in a record whose later alteration would be detectable. Two questions, two systems, two files. If you want the second one on its own merits, it is described on our caregiver visit proof app page, and the surrounding field is laid out in visit-proof apps that work alongside EVV.

What this page does not claim

A reference page earns trust by marking its own edges. Three of them here. First, the 85% figure and the January 2025 date come from MA Bulletin 05-24-01, a separate document from the one this page walks — both are linked above, and the requirement is worth reading in its own words. Second, what escalation actually produces in a given case is not something this page reports; read the bulletin for its own account of that. Third, nothing on this page has been checked against a provider’s actual programs or contracts, because it cannot be — that is the gap a lawyer or a DHS program contact fills, and it is not a gap any software closes.

Pennsylvania is one of several states that changed EVV enforcement in this window, each with a different mechanism. A different kind of rule, tracked the same way, is our state-by-state guide to employee monitoring notice laws.