Regulatory watch

Wisconsin EVV requirements: Sandata or alternate

By the LockProof Team · Last updated November 3, 2026

Read this as a digest, not legal advice: it reports what the Wisconsin Department of Health Services and the Wisconsin Administrative Code set out for electronic visit verification. Agencies record visits in the free Sandata system DHS provides or in a certified alternate that feeds the Sandata aggregator. Hard launch reached personal care on May 1, 2023 and home health on October 1, 2024. The texts used are listed below.
Wisconsin texts behind this summary, each read November 3, 2026:Also read: the DHS forum deck of June 11, 2024, DHS publication P-02663 on alternate systems, the Sandata addendum DHS posts for alternate vendors, and the Medicaid.gov EVV page on the federal Cures Act rule. Which services one particular agency puts through EVV is for its counsel or DHS to answer.

Wisconsin EVV launch dates

Two waves, each with a soft launch first and a hard launch later.

PointDateWhat it marksWisconsin text
Personal care soft launchNov. 2, 2020.EVV opens for personal care and supportive home care.DHS EVV home page
Personal care hard launchMay 1, 2023.Missing visit data starts to carry consequences.DHS What’s New page
Home health and 99509 soft launchJan. 1, 2024.Home health joins EVV, with 99509, a personal care code.DHS EVV home page
Code amendmentsFeb. 1, 2024.Chapters DHS 101, 105, 106 and 107 gain their EVV record and claim text.Admin. Code history notes
Home health and 99509 hard launchOct. 1, 2024.Payers deny claims that lack EVV data for these services.DHS What’s New page

Narrow screens: swipe sideways to reach the Wisconsin text column. Each date above matches its DHS or code text as of November 3, 2026.

What Wisconsin’s texts say

The DHS EVV home page puts the choice in one line: “You can opt for either the DHS-provided EVV system, Sandata, or an alternate EVV system.” The providers page adds that paper records of care “may continue but do not fulfill EVV requirements.” And publication P-02614 sets a limit on location: “EVV does not track locations throughout a visit.”

One aggregator, two ways in

DHS provides a Sandata system at no charge that any agency may use, so, per the DHS EVV page for providers, revised March 31, 2026, an agency does not need to buy an EVV system. One that prefers its own vendor goes through Sandata’s alternate EVV certification, which the Alternate EVV page warns can take up to three months, and DHS covers none of that cost. Either way, visit data passes through the Sandata aggregator, and only visits in a verified status move on to the payer.

Location, GPS and claims

The DHS EVV FAQ, revised October 19, 2026, has every EVV system take a location as a visit opens and as it closes, and then says in the next breath that DHS will not deny a claim because of GPS information, though the DHS Office of the Inspector General has access to that location data. The same DHS FAQ, as read November 3, 2026, says the Sandata mobile app needs location services on to record a visit, yet a worker may also log a visit by a member’s landline or a small fixed device, and the DHS payers page says the geofence features in Sandata’s training do not apply in Wisconsin. No Wisconsin text read here makes satellite positioning a condition of payment.

Exceptions and manual corrections

Publication P-03646 lists seven Sandata exceptions, from an unknown client or employee to a visit without a clock-out, and the publication describes exceptions as mistakes or incomplete information that keep a visit from reaching verified status. The quarter-mile GPS flag in the DHS FAQ is not one of the seven; the FAQ says it does not stop a visit from reaching verified status. Edits leave a history; the FAQ says supporting documentation goes with every change, that verified visits cannot be deleted, and that the DHS Office of the Inspector General watches manual corrections.

Live-in workers

The 2021 policy decisions left live-in workers out of EVV altogether. The DHS EVV page listing service codes, revised September 23, 2025, narrows that exemption: live-in workers record EVV for home health codes and the 99509 supervisory visit, though not for the four personal care and supportive home care codes, and MCOs, HMOs and provider agencies may each require live-in workers to use EVV on their own.

What this reading could not cover

The ForwardHealth site, home of the numbered ForwardHealth Updates and the Online Handbook, was blocked by the filter on the network used for this reading; updates such as 2024-24 are known here only by title. That is a gap in the reading, not a sign the texts are missing. No Wisconsin statute on EVV was confirmed or ruled out, and the Sandata addendum DHS posts for alternate vendors carries no date.

Where LockProof stands in Wisconsin

LockProof is not an EVV system. Wisconsin has never certified it as an alternate, and neither the Sandata aggregator nor any Wisconsin payer gets data from it. What it handles is narrower. From a texted link the caregiver reaches a camera that only shoots live, and the server on our side fixes when the photo came in. A position rides along only if the caregiver’s phone shares it; an agency that wants one every time can have LockProof reject photos that arrive without it. Any later edit to the photo, the stamp or that position leaves the SHA-256 fingerprint unmatched.

Sandata or the agency’s certified alternate carries the Wisconsin visit record. A LockProof photo is for people the EVV system never reaches, such as a daughter in another city or a family paying for care out of pocket. More on that split: visit-proof apps beside a state EVV system, and what a LockProof caregiver photo contains.

Reading date

Every Wisconsin text above was read November 3, 2026, and DHS revises its EVV pages several times a year. Other states are collected on the EVV requirements by state hub; for Minnesota, across the St. Croix, see the Minnesota EVV page.

Common questions

Who provides the EVV system in Wisconsin?

The Wisconsin Department of Health Services offers Sandata to agencies at no charge, and its Alternate EVV page, revised June 8, 2026, lets an agency run a different system instead once that system has been certified and connected to the Sandata aggregator. The aggregator is what hands visit data on to DHS; the payers page calls it view only. An agency that goes the alternate route carries any cost of implementing that system or training for it, the same page says.

When did EVV start for Wisconsin personal care?

Soft launch for personal care and supportive home care opened on November 2, 2020, according to the DHS EVV page, revised October 20, 2026. Hard launch followed on May 1, 2023, and from that date DHS began imposing consequences when visit data was missing for service codes T1019, T1020, S5125 and S5126. Home health, along with the nurse supervisory visit that DHS lists as personal care code 99509, came later, with soft launch on January 1, 2024 and hard launch on October 1, 2024.

Does Wisconsin EVV use GPS?

Wisconsin takes one position reading when a visit opens and one when it closes, with no tracking in between, per DHS policy decisions publication P-02614 of January 2021. The DHS EVV FAQ, revised October 19, 2026, says GPS data in the Sandata portal is informational only, that a claim is not denied over it, and that a visit more than a quarter mile from a known service location raises an exception without blocking verification. The same FAQ adds that the DHS Office of the Inspector General has access to GPS location. Landline and fixed-device visits remain available.

What happens to a Wisconsin claim with no EVV record?

Under section 106.03 of the Wisconsin Administrative Code, as amended effective February 1, 2024, a claim that is not matched to an EVV record may be denied. For fee-for-service claims, the DHS claims guidance in publication P-03124, of February 2024 and read November 3, 2026, says that when no matching EVV record is found on first processing the claim is suspended for a two-day recycle, and if EVV data is still not found the claim detail will be denied; it can be resubmitted once the visit is verified. P-03124 adds that the HMOs and Family Care plans have the authority to deny, and will likely deny, claims with no matching EVV record.

Can LockProof stand in for Sandata in Wisconsin?

Not for EVV purposes. LockProof is not an EVV system. DHS has never certified it as a Wisconsin alternate, no link to the Sandata aggregator exists, and it sends nothing to DHS or to any payer. Wisconsin visits belong in Sandata or a certified alternate. LockProof makes a separate thing: a time-stamped visit photo whose SHA-256 fingerprint exposes a later edit to the image, its time or a shared position, which an agency can show to a family or a private-pay client.

Is this Wisconsin EVV summary legal advice?

No. It restates Wisconsin Department of Health Services pages, DHS publications and administrative code text as read on November 3, 2026. ForwardHealth Updates could not be opened from this network, so their wording is not reflected here, and DHS revises its EVV pages often. Questions about one agency’s claims or certification belong with its lawyer, DHS or the ForwardHealth provider line.

A photo record for Wisconsin families, outside Sandata

LockProof is not an EVV system. Wisconsin's Sandata aggregator receives nothing from it. The texted link goes straight to a live camera on the caregiver's phone, and each photo's arrival time is written by our server. Should the photo, its timestamp or any position the phone shared be altered afterwards, its SHA-256 fingerprint breaks. DHS has not certified it.