California EVV: Requirements, Live-In Exemption, and Penalties

If you bill Medi-Cal for personal care or home health visits, California’s Electronic Visit Verification requirements mean every visit has to be captured electronically through CalEVV or an approved alternate vendor, with six specific data elements recorded in real time. Both Medi-Cal personal care services (PCS) and home health care services (HHCS) deadlines have already passed, so compliance is not optional: you should be registered, trained, and submitting EVV data on every claim. Skipping it or submitting incomplete records can get your claims denied and expose agency providers to sanctions from the Department of Health Care Services (DHCS).

Who Has to Use CalEVV

The obligation follows the service code on the claim, not the size of your operation. If the service you’re billing is classified as Medi-Cal PCS or HHCS and involves an in-home visit, EVV applies. California’s rollout covers a broad set of programs:¹

In-Home Supportive Services (IHSS), both self-directed and agency-model
Waiver Personal Care Services (WPCS)
Home and Community-Based Alternatives (HCBA) Waiver
Multipurpose Senior Services Program (MSSP) under the 1915(c) and 1115 waivers
Department of Developmental Services (DDS) 1915(c) waivers and the Self-Determination Program
AIDS Medi-Cal Waiver
Home health care services billed to Medi-Cal

Both agencies and independent caregivers fall under EVV. Individual IHSS providers generally use the state-provided tools; agencies can choose CalEVV or a certified third-party vendor. The agency-versus-individual distinction matters most for enforcement, covered further down.

The Six Data Elements Every Visit Must Capture

Federal law sets a floor of six data points for every EVV record. Whichever system you use, each visit has to include all six to count as compliant:²

Type of service performed, matching the authorized care plan
Individual receiving the service
Individual providing the service
Date of service
Location of service delivery, captured by GPS at check-in and check-out
Start and end time, recorded in real time at check-in and check-out

One point of confusion worth clearing up: check-in and check-out times verify the visit, they don’t necessarily set your pay. IHSS providers are paid based on reported hours worked, not the raw span between the two timestamps.³ Clocking in a few minutes early while you wait to start doesn’t pad your paycheck.

Location data collection is limited to those two moments. The state does not track provider movement in between or at any other time.⁴

How to Submit Visit Data

California runs an open-model system. You can use the state-provided CalEVV platform at no cost or an approved alternate vendor. Either way, all data lands in the CalEVV Aggregator operated by Sandata, the state’s central repository.⁵

Using the State System

IHSS and WPCS providers have three free options: the Electronic Services Portal (ESP), the IHSS EVV Mobile App, and the Telephone Timesheet System (TTS) using the recipient’s landline. Non-live-in providers check in when the visit starts and check out when it ends, selecting whether services were delivered in the home or in the community. That data flows automatically into the electronic timesheet.³

Agency providers using CalEVV can enter visit records through the web portal, use Sandata’s on-demand entry, or upload records in bulk.

Using an Alternate Vendor

If your agency already uses a third-party scheduling or visit verification platform, you can keep it, provided it’s certified to interface with the Sandata Aggregator. The sequence is: self-register in CalEVV and identify your vendor, the vendor contacts Sandata for certification testing, and Sandata issues production credentials once testing passes. Your vendor is then responsible for sending all six data elements to the Aggregator in the required format.² Corrections cannot be made directly in the Aggregator; they have to be fixed in your source system and resubmitted.

The Live-In Provider Exemption

If you live in the same home as the recipient you serve, you are not required to perform real-time check-in and check-out verification. The federal statute limits EVV to services “requiring an in-home visit,” and a live-in caregiver is already there. In the IHSS program, live-in providers self-certify their living arrangement by filing a completed SOC 2298. Once that form is on file, you still submit timesheets electronically through the ESP, TTS, or Mobile App, but you skip the GPS-based location verification that non-live-in providers must complete.³

Registration and Training

DHCS requires every impacted provider to be registered, trained, and actively using CalEVV or an alternate system.⁶ Several free resources are available:

The Training Road Show 2.0, in-person sessions held across the state on CalEVV tools and compliance
Weekly virtual drop-in hours every Friday from 1:30 to 2:30 PM PST, launched in January 2026, for live technical help
On-demand training videos under 20 minutes each, covering data entry, visit capture, visit maintenance, and group visits
Quick reference guides for self-registration, provider identifiers, and multi-factor authentication

Alternate EVV vendors have separate user guides and specification documents. If you’re switching between the state system and a third-party vendor, plan a transition so data flows correctly to the Aggregator from day one of the change.

What Happens If You Don’t Comply

Consequences depend on what kind of provider you are. California’s enforcement framework splits agency-based providers from independent IHSS and WPCS providers.

Agency Providers

Under Welfare and Institutions Code section 14043.51, DHCS can take escalating action against agencies that fail to meet EVV requirements:⁷

Technical assistance from DHCS or its partners
A required corrective action plan
Overpayment recovery for services billed without proper EVV verification
Enrollment or monetary sanctions
Other remedial action DHCS deems appropriate

The practical consequence at the claim level is simpler: a claim submitted without a compliant EVV record can be denied outright. No verification, no reimbursement.

Individual IHSS and WPCS Providers

Section 14043.51 explicitly carves out individual IHSS and WPCS providers who are not employed by an agency. They are not subject to the sanctions listed above. They fall instead under Welfare and Institutions Code sections 10836, 12305.82, and 12305.83, which govern EVV for self-directed care programs.⁷ The legislature drew that line because individual IHSS providers are typically family members or close contacts of the recipient.

If a Claim Gets Denied for an EVV Problem

Check the record in CalEVV or the Aggregator first. Missing or mismatched data elements are the most common cause of denials. If you used an alternate vendor, confirm the visit transmitted correctly, and remember that corrections must be made in your source system and resubmitted, not in the Aggregator directly.²

For Medi-Cal fee-for-service claims, use the standard Medi-Cal provider dispute resolution process. Managed care plan claims go through each plan’s own dispute procedures. Either way, gather documentation that the visit occurred as billed, including system logs, screenshots, or error reports from your EVV platform, before filing. The CalEVV team’s Friday drop-in sessions are a practical place to troubleshoot data issues before they turn into formal disputes.

1
California Office of Systems Integration. EVV Phase II
2
California Department of Health Care Services. CalEVV User Guide for Alternate EVV Providers
3
California Department of Social Services. Electronic Visit Verification Help – IHSS
4
California Department of Social Services. EVV Mobile App Privacy Policy
5
California Department of Health Care Services. CalEVV User Guide for Alternate EVV Providers
6
California Department of Health Care Services. About California Electronic Visit Verification
7
California Legislative Information. California Welfare and Institutions Code WIC 14043.51