Regulatory watch
Pennsylvania EVV requirements, layer by layer
Five layers, all of them already published
Unlike a state waiting on new rules, Pennsylvania has nothing pending on the EVV pages we read. What it has is a stack: a federal floor, a payment link, a percentage, an alert schedule and a location policy.
| Layer | Standing | Effect | Read in |
|---|---|---|---|
| Federal floor | Federal floor — in place. Personal care since January 1, 2020; home health care since January 1, 2023. | Cures Act section 12006 is why Pennsylvania runs EVV for Medicaid personal care and home health visits at all, and it lists the six items each visit record carries. | DHS EVV program page; dates from the DHS EVV FAQ |
| Payment link | Payment link — in place for personal care. Since July 1, 2020. | Per the DHS EVV FAQ, DHS turns down a personal care claim with no matching visit in its EVV Aggregator. | DHS EVV FAQ |
| Manual-edit floor | 85% floor — in place. Visits dated January 1, 2025 or later. | At least 85% of EVV records for verified visits carry no manual edit, counted each quarter and in each program. | MA Bulletin 05-24-01 |
| Alerts | Quarterly alerts — scheduled from January 2026. The bulletin set the first for that month. | An alert above 15% manual entry. Fee-for-service: two quarters in a row bring a plan to fix it, under a formal notice; managed care goes through the MCO. | MA Bulletin 05-25-03 |
| Location | Location — one method of four. As listed on October 8, 2026. | A GPS phone app, a landline, a fixed VOIP line, or a cell phone with an in-home device. DHS says it does not currently check location for billing. | DHS EVV FAQ |
Pennsylvania’s sources as they stood on October 8, 2026, when this page was reviewed.
The table answers the question most agencies arrive with, which is whether anything changes soon. On the sources read for this page, no change is announced. The percentage is set, the second bulletin put the alerts on a quarterly cycle from January 2026, and the location policy is the one the FAQ describes. What varies is which layer a given agency meets first, and that turns on whether it bills fee-for-service or through a managed care organization.
What Pennsylvania says, quoted
Five short passages carry most of the state’s position.
- On the system model, the DHS EVV program page: “Pennsylvania is using an open EVV system model.”
- On payment, the DHS EVV FAQ: as of July 1, 2020, “providers are required to use EVV to receive payment for any claim for PCS visits.”
- On manual edits, MA Bulletin 05-24-01, for dates of service on and after January 1, 2025: providers “must achieve 85% of EVV records for verified visits without manual edits.”
- On location, the DHS EVV FAQ: “PA-DHS is not currently validating against the location for billing purposes.”
- On corrections, the same FAQ: “For any manual entries, however, supporting hard copy documentation should be kept.”
The open model and the Aggregator
Pennsylvania lets an agency choose its own EVV software. The DHS program page names Gainwell Technologies and Sandata as the companies DHS is working with on a state system tied to PROMISe, the state’s Medicaid claims system, and says an agency may use a different vendor so long as the system captures the six federal items and can feed the DHS Aggregator. The FAQ describes the Aggregator as the single platform where the state system’s visits and those from outside systems meet, sent in Sandata’s standard data format.
The free state system has a boundary worth knowing. Its own page limits it to fee-for-service visits, and says it does not support visits submitted to a managed care organization. For agencies billing managed care, the FAQ says visit data held in HHAeXchange goes to the managed care organization and on to the DHS Aggregator as well.
Location, and where GPS fits
Location of service is one of the six federal items, and the DHS EVV FAQ, as read on October 8, 2026, lists four ways to record it: a phone app that reads GPS, a landline call, a fixed VOIP line, or a cell phone used together with an in-home device. A GPS app is therefore one option, not the rule. For agencies on the free state app, the FAQ adds that it reads location when the caregiver checks in and again at check-out, and the free system’s page says there is no tracking in between.
The FAQ is also plain about what happens to that reading. The state app sets a quarter-mile perimeter for service locations, and a reading outside it does not raise an exception. DHS says it is not currently matching location against claims for billing, and that it would tell providers if that changed.
Manual edits: the floor and the follow-up
MA Bulletin 05-24-01, issued August 23, 2024, sets the 85% floor and defines a manual visit as one entered or changed after the point of service. The follow-up bulletin, 05-25-03, dated August 29, 2025, sets out the alerts: from January 2026, it says, DHS issues them to providers whose manual entry ran above 15% in the previous quarter. For a fee-for-service provider, two such quarters in a row lead to a corrective action plan, under a formal notice that ODP, OLTL or OMAP issues. Managed care providers hear from their managed care organization instead. The full sequence, including what DHS weighs after a plan runs its course, is set out in Pennsylvania’s EVV manual-edit threshold.
Documented, and not documented
What the five sources establish: the open model, the payment link for personal care since July 1, 2020, the four location methods, the 85% floor and the alert schedule. What they leave open is just as useful to know. None of the five sources names a Pennsylvania statute on EVV; they rest the program on the federal Cures Act and on DHS’s own bulletins and pages. The FAQ gives two personal care dates that sit awkwardly together: payment tied to EVV from July 1, 2020, and a soft launch, without effect on claims, that ended December 31, 2021. We report both as the FAQ writes them, and it gives no home health date for the payment link in the same terms. And none of the DHS pages read for this article carries a proposal or a pending rule, so any write-up describing a coming change should be asked for its bulletin number.
Where LockProof stands
The two records answer different questions. Pennsylvania’s Aggregator holds whether a visit met the state’s six items; a sealed photo holds what the caregiver’s camera captured there, and a later change to that record would show. For running a photo file next to a state system, see photo-proof apps used beside EVV; for how one capture works, see the caregiver visit proof page.
What this page cannot tell you
We read each source once, on October 8, 2026, and DHS updates its pages without notice. Parts of the FAQ are older than others: its soft-launch answers still speak of 2022 in the future tense, and we report them as the page states them. Nothing here has been measured against any agency’s programs, waivers or managed care contracts. That reading belongs to counsel, not to a software company. For other states, our state-by-state EVV hub sets Pennsylvania beside Ohio’s new EVV statute.
Common questions
Is GPS the rule for EVV in Pennsylvania?
No. On October 8, 2026, the DHS EVV FAQ listed four ways to record where a visit happened, of which a GPS phone app is just one; the others use a landline, a fixed VOIP line, or a cell phone paired with an in-home device. The same FAQ says the free state app reads location only at check-in and check-out, and that DHS is not currently checking location against claims for billing.
What is the 85% manual-edit rule in Pennsylvania?
MA Bulletin 05-24-01 says that, for dates of service on and after January 1, 2025, providers must achieve 85% of EVV records for verified visits without manual edits, counted each federal fiscal year quarter and separately in each program. A manual visit is one typed in or changed after the point of service. How DHS follows up sits in a second bulletin, 05-25-03, which has a page of its own here.
When did Pennsylvania start denying claims without an EVV visit?
For personal care, the DHS EVV FAQ says that from July 1, 2020, providers were required to use EVV to be paid, and that DHS began turning down personal care claims with no matching visit in its EVV Aggregator. The same FAQ also dates a personal care soft launch, without effect on claims, that ended December 31, 2021, and a home health one from August 10 to December 31, 2022.
Can a Pennsylvania agency use its own EVV vendor?
Yes. The DHS EVV program page describes an open model: an agency may run its own system if that system captures the six items the Cures Act lists and can send them to the DHS Aggregator, which takes them in Sandata’s data format. Fee-for-service agencies may use the free DHS system, built with Sandata, instead. That free system does not handle visits billed to a managed care organization.
Does LockProof count toward Pennsylvania’s EVV rules?
Not in any way. LockProof is not an EVV system, so it sends nothing to the DHS Aggregator, no state certifies it, and its records leave a provider’s manual-edit percentage exactly where it was. Some agencies keep it beside the EVV system they already run, as a photo record for when a family member or a payer brings a question to the agency itself.
Can I treat this page as legal advice?
You should not. It reports what five Pennsylvania Department of Human Services sources say, as read on October 8, 2026, and it links each one. Whether a bulletin reaches a particular agency, and how that agency should answer an alert, are questions for counsel or for the agency’s DHS program contact.