Regulatory watch
Virginia EVV requirements and the live-in change
- The DMAS EVV page, its FAQ revised August 28, 2026 plus the one-pager on the October 1, 2026 change
- The 2023 DMAS EVV FAQs (revised November 16, 2023)
- 12VAC30-60-65, the EVV section of the Virginia Administrative Code
- DMAS bulletins effective August 14, 2020 and November 16, 2023
- The CCC Plus Waiver manual, chapter IV (revised September 2, 2026), plus chapters IV and V of the Home Health manual
Six Virginia EVV dates
Personal care went first in 2019, home health followed in 2023, and DMAS closed the live-in carve-out in 2026.
| Step | Date | What happened | Virginia text |
|---|---|---|---|
| Claims denied without EVV | Sept. 1, 2020. | Personal care, respite and companion claims with EVV errors stop being paid. | Bulletin, Aug. 14, 2020 |
| Live-in exemption | Jan. 1, 2021. | Caregivers living with the member are left out, per the 2020 Appropriation Act. | Bulletin 20388 |
| Rule in the code | Aug. 18, 2021. | 12VAC30-60-65 takes effect for personal care, respite and companion services. | 12VAC30-60-65 |
| Home health begins | July 1, 2023. | Soft edits only, under a federal Good Faith Extension. | EVV page; bulletin, Nov. 16, 2023 |
| Home health denials | Jan. 1, 2024. | Denials begin for claims missing EVV data, after a Dec. 1, 2023 start was dropped. | Bulletin, Nov. 16, 2023 |
| Live-in exemption ends | Oct. 1, 2026. | Every shift goes through an approved method; for consumer-directed attendants, no compliance penalties before Jan. 1, 2027. | EVV page; one-pager |
Each row names the Virginia text it comes from, every one opened on October 29, 2026.
What Virginia says, word for word
On who chooses the software, the 2023 DMAS EVV FAQs put it simply: “Virginia is a provider choice state for Agency Directed services.” On the newest change, the EVV page of DMAS, Virginia’s Medicaid agency, reads: “Effective October 1, 2026, all agency-directed aides and consumer-directed personal care attendants regardless of live in status, will be required to use an approved Electronic Visit Verification (EVV) method to submit all shifts.” And on place, 12VAC30-60-65 says of the start and end location that “EVV systems shall not restrict locations where individuals may receive services.”
Two lanes: agency-directed and consumer-directed
12VAC30-60-65, effective August 18, 2021, covers personal care, respite and companion services. An agency chooses its own EVV system; for consumer direction, the fiscal employer agent selects and operates one. The DMAS EVV page links the two agents, Consumer Direct Care Network Virginia and PPL. There is no state aggregator in the usual sense: the 2023 FAQs say the EVV fields travel on the claim into the Medicaid Enterprise System, and that DMAS does not and will not approve vendor systems. Health plans collect the same claim fields for their own members.
The live-in change, and the texts that still differ
Bulletin 20388 carried out an exemption for live-in caregivers from January 1, 2021, under Item 313.HHH.1 of the 2020 Appropriation Act. The DMAS EVV page and its FAQ revised August 28, 2026 reverse it from October 1, 2026. For consumer-directed attendants, the one-pager says no compliance penalties apply before January 1, 2027; no text read gives agency-directed shifts a grace period. Three Virginia texts read the same day still read differently. 12VAC30-60-65 still lists live-in caregivers among its exemptions. The CCC Plus Waiver manual’s chapter IV, revised September 2, 2026, still exempts a consumer-directed attendant with a confirmed live-in status, and its chapter V, revised December 5, 2025, still lets an agency with live-in aides skip EVV data under modifier UB. No 2026 Medicaid memo or bulletin on the change turned up. Where they disagree, this page reports both and settles nothing.
Home health under EVV
DMAS bulletin effective November 16, 2023 records that home health EVV began July 1, 2023 and moved the start of claim denials for missing data from December 1, 2023 to January 1, 2024. The 2023 fact sheet lists ten revenue codes, and chapter V of the Home Health manual, revised December 5, 2025, keeps EVV to Medicaid-only members on the 837I claim, with the visit’s street address as its location. Chapter IV of that manual, revised August 28, 2024, still gives the older November 30, 2023 end of soft edits.
Location, clock-ins and corrections
Asked whether GPS tracking is required, the Virginia Medicaid EVV FAQ document revised November 16, 2023 answered no, and asked for a physical address instead. The same FAQs said a call from a cell phone with no fixed in-home device falls short for agency telephony. On the Virginia Medicaid EVV page, read October 29, 2026, a consumer-directed attendant who uses the mobile app has to keep GPS location on or the shift fails DMAS’s rules, while the landline phone call stays approved and the web portal is not. The 2026 FAQ adds that the location is taken only at the start and end, and not only at the home. Each consumer-directed correction carries one of three reasons, a rule DMAS set in that August 28, 2026 FAQ. The 2023 FAQs set no ceiling on manual adjustments.
Reported, not confirmed
WHRO reported on September 25, 2026 that a member of the House of Delegates asked the Governor to push the live-in start back to January 1, 2027. That is a news report, not a DMAS text, and the DMAS EVV page read on October 29, 2026 still gives October 1, 2026. This page could not confirm any delay.
Gaps in this reading
The VA-23-0012 state plan amendment would not open (medicaid.gov returned an error). The health plans’ own EVV manuals and the claim companion guides were left unread, as was the Appropriation Act text behind the 2021 exemption. No Code of Virginia section on EVV was found.
Where LockProof sits beside Virginia EVV
Virginia’s shifts reach DMAS through the vendors and agents above. A LockProof photo goes somewhere else: to a relative, or to a private-pay client, checking that someone actually came. See photo tools that sit beside EVV, plus what goes into a caregiver photo record.
Date of this reading
The Virginia texts above were read on October 29, 2026, and a later DMAS memo could move any of it. The rest of the states sit on the state-by-state EVV page, and Virginia’s southern neighbor is on the North Carolina EVV page.
Common questions
Who picks the EVV system in Virginia?
For agencies, no state-picked vendor. The 2023 DMAS EVV FAQs call Virginia a provider choice state for agency-directed services, and add that DMAS does not and will not approve vendor systems. For consumer direction, 12VAC30-60-65 gives the choice to the fiscal employer agent, which runs the app or phone line its attendants use. Visit data reaches DMAS on the claim itself; the FAQs say Virginia does not use the word aggregator.
What changed for live-in caregivers on October 1, 2026?
Since January 1, 2021, under bulletin 20388, a caregiver living with the member could skip EVV. The DMAS EVV page and its FAQ revised August 28, 2026 end that: from October 1, 2026, agency aides and consumer-directed attendants use an approved method for every shift, live-in or not. For consumer-directed attendants, a DMAS one-pager adds that no compliance penalties apply before January 1, 2027; no text read gives agency-directed shifts that grace period.
Is GPS part of Virginia EVV?
Yes, as one accepted method among several, and in one place as a condition. The Virginia Medicaid EVV FAQ document revised November 16, 2023 answers “Is GPS tracking required?” with no, then says the aide must be shown to be in proximity with the individual, by landline, a fixed in-home device such as a fob, GPS, or member biometrics. The condition sits on the EVV page of DMAS, Virginia’s Medicaid agency, read October 29, 2026: a consumer-directed attendant using the mobile app keeps GPS location on, while the landline call stays approved.
When did home health join Virginia EVV?
With a federal Good Faith Extension in hand, DMAS started home health EVV on July 1, 2023, with soft edits first. A DMAS bulletin effective November 16, 2023 then pushed the start of claim denials for missing EVV data from December 1, 2023 to January 1, 2024. Ten revenue codes are covered, billed on the 837I claim only, and only Medicaid-only members are in scope.
Does LockProof meet Virginia EVV rules?
No, and it does not try to. Here too LockProof is not an EVV system; instead a fiscal employer agent or a provider-choice vendor is what carries a Virginia shift into a claim. Nothing goes from LockProof to DMAS or a Cardinal Care plan. Its use is elsewhere, in a timestamped visit photo an agency can pass to relatives or to someone paying out of pocket.
Can a Virginia agency take this page to be legal advice?
Not at all. What it sets out are the DMAS and Virginia Administrative Code texts as they stood on October 29, 2026, and some of those texts disagree with each other on live-in caregivers. A rule, a manual or the EVV page could change after that day. A single agency’s decision belongs with counsel, its plan, its fiscal employer agent or DMAS.