Regulatory watch

Tennessee EVV requirements under TennCare

By the LockProof Team · Last updated November 2, 2026

Read this as background, never as legal advice: it gathers what TennCare, Tennessee’s Medicaid agency, has put in writing on EVV. There is no single state system here. Each TennCare health plan chooses an EVV vendor, home health claims failing EVV started to be denied in 2023, and denials for intermittent visits followed in 2024. The memos and contract used are listed below.
Tennessee documents consulted on November 2, 2026, the reading date for all of them:Three CMS letters to Tennessee, from 2020 and 2023, were read for federal context. What any of it means for a particular agency is for that agency’s lawyer, its plans or TennCare to answer.

Tennessee EVV, step by step

Personal care came first; home health arrived in two phases, and its last deadline was moved twice.

StageDateWhat happenedSource
Personal care deadlineJan. 1, 2020.The plan contract’s date for Cures Act EVV in personal care.MCO contract § 2.9.6.14.4
Home health phase 1 denialsJuly 1, 2023.Private duty nursing and hourly nurse and aide visits; grace period to November 2023.Memos, May 2023 and Mar. 2024
Phase 2 goes liveJuly 1, 2023.EVV opens for intermittent home health visits.Memo, Dec. 2023
Phase 2 denialsOct. 1, 2024.Intermittent visit claims without EVV are denied from October 1, 2024, per the TennCare Medicaid memo of March 7, 2024.Memo, Mar. 7, 2024

Phone readers can drag the table left to reveal the Source column; each row links the Tennessee text it rests on, all read November 2, 2026.

TennCare, quoted

The plan contract states the vendor model plainly: “The CONTRACTOR shall select its own electronic visit verification vendor, as applicable.” The TennCare memo of March 7, 2024 closed the door on more delay for intermittent visits: “there will be no further extensions of the deadline.” And in its definitions, Rule 1200-13-01 describes EVV as a system that provider staff and consumer-directed workers “can check-in at the beginning and check-out at the end of each period of service delivery.”

Plan by plan

Federal regulators call Tennessee’s design a managed care plan choice model: CMS used that name when it approved the state’s good-faith exemption for home health in January 2023. In practice the TennCare memo of May 25, 2023 lists two systems, Sandata at BlueCare and CareBridge at Wellpoint and UnitedHealthcare. An agency running its own EVV product sends visits into each plan’s aggregator, and one with members on more than one plan may end up in both.

The six facts on each visit

The TennCare memo of December 29, 2022 lists what each visit carries: the type of service, the person served, the date, where the service was delivered, the person delivering it, and its start and finish times. Section 2.9.17.2 of the plan contract repeats that list. For services outside the home, section 2.9.6.14.8 treats an approved check-in and check-out that reflects where the work happened as the location of record.

GPS in the Tennessee contract

GPS appears in the plan contract; the TennCare memos, the rule and the statute read here make no GPS demand. Section 2.9.6.14.6.2 of the TennCare MCO Statewide Contract, in its July 1, 2026 version, gives a GPS-enabled smart device and IVR as examples of approved ways to log a worker in and out, and the next clause adds check-ins through the member’s phone number. Section 2.9.6.14.6.2.1 of the same version has each plan see that members hold a working GPS device for EVV, and the plans report GPS tablet visits separately from IVR ones. So the GPS clauses bind the plans and offer a tool; they do not make GPS the method for each visit.

Exceptions and payment

Under section 2.9.6.14.5.3 of the plan contract, in its July 1, 2026 version, a plan completes the steps only it can take to clear an EVV exception, such as a changed service authorization, within three business days. Its system also checks that no worker is clocked into two shifts at once. And under section 2.9.6.14.4 a plan does not deny payment for services delivered unless TennCare has directed or approved it in writing.

Outside this reading

TennCare does not appear to keep a standalone EVV web page or FAQ; none was found. A TennCare EVV memo on electronic verification would not load, and the developmental disabilities division’s EVV pages returned errors, so neither is used here. Tenn. Code § 71-5-1415 only lists EVV as one strategy the state may use and sets no dates. When each EVV clause entered the plan contract was not traced.

LockProof and Tennessee EVV

LockProof is not an EVV system. TennCare plans did not pick it, and neither Sandata nor CareBridge takes data from it. Its job is a small one. The caregiver gets a texted link that opens a live camera, takes the photo, and the moment that photo reaches us is logged by our server. The caregiver’s handset supplies any location, and only with their agreement; an agency can also turn on a setting that rejects photos lacking one. Once stored, an altered image, time or location no longer agrees with the record’s SHA-256 fingerprint.

Tennessee visits reach TennCare through each plan’s vendor. A LockProof photo is meant for someone else: a son or daughter checking on a parent’s care, or a client paying the agency without Medicaid. Further reading: running a photo app next to EVV; also the makeup of a caregiver visit photo.

As of this reading

These Tennessee documents were read November 2, 2026; TennCare amends its plan contract regularly, and a later version may say something different. For every state covered so far, see our EVV index of states, and Georgia, Tennessee’s neighbor to the south, has a separate Georgia page.

Common questions

Who chooses Tennessee’s EVV vendor?

Each TennCare health plan. Section 2.9.6.14.6 of the TennCare MCO Statewide Contract has every plan select its own EVV vendor. A TennCare memo of May 25, 2023 named them: Sandata for BlueCare, and CareBridge for Wellpoint and UnitedHealthcare. A home health agency can use the plan’s tool, or a vendor of its own that sends visits into the plan’s aggregator, so an agency serving members of several plans may deal with both systems.

When did Tennessee begin denying home health claims over EVV?

In two phases. A TennCare memo of December 29, 2022 delayed home health denials until July 1, 2023, and a reminder memo of May 25, 2023 confirmed that date for private duty nursing and hourly home health nursing and aide visits; later memos describe a grace period to November 2023, by which time every plan was denying. For intermittent home health visits, the TennCare memo of March 7, 2024 set October 1, 2024 and said there would be no further extensions.

Does Tennessee EVV use GPS?

As one option, yes. Section 2.9.6.14.6.2 of the TennCare MCO Statewide Contract, in its July 1, 2026 version, lists a GPS-enabled smart device and phone calls as examples of approved ways to log arrival and departure, and plans also take check-ins from the member’s phone number. The same contract has each plan see that members have a working GPS device for EVV. No TennCare memo, rule or statute read here makes GPS the only accepted method.

Can a Tennessee visit be confirmed by hand?

Not as the verification itself. The TennCare MCO Statewide Contract, at section 2.9.6.14.3 of its July 1, 2026 version, calls for electronic, not manual, verification of the six visit facts. For exceptions, the plan finishes the steps only it can take within three business days, and under section 2.9.6.14.4 it does not deny payment over EVV without written direction or approval from TennCare.

Is LockProof one of the Tennessee EVV vendors?

It isn’t. LockProof is not an EVV system; TennCare’s plans have not chosen it, and neither Sandata nor CareBridge receives anything from it. What it offers sits outside TennCare billing altogether: a photo of a visit, dated and sealed, that an agency can pass to a worried relative or a privately paying client.

Is this Tennessee summary legal advice?

It is not. What you have is a digest of TennCare texts as they stood on November 2, 2026; a later memo or contract amendment could overtake any of it. No TennCare EVV web page or FAQ turned up in this reading. An agency weighing its own claims should go to its attorney, its health plans or TennCare.

Photos of a visit, kept apart from TennCare billing

No TennCare plan’s vendor hears from LockProof; LockProof is not an EVV system. Our SMS link puts the caregiver straight into a live camera, and the arrival time of each photo is set by our server. Edit the image, that time or a shared location afterwards, and the SHA-256 fingerprint on file stops agreeing. Tennessee has not certified LockProof.