Beginning January 1, 2026, Minnesota Department of Human Services moved to full electronic visit verification (EVV) enforcement to ensure every agency meets federal and state requirements in documentation of services billed to the state. DHS will review provider EVV data against billing compliance standards on a set schedule and issue corrective actions when performance does not meet required levels. Enforcement applies to all providers, including FMS and MCOs. Please note that Hospice Services are exempt and PCA Supervision will no longer require EVV. Live‑in caregivers must enter EVV data once per day, not in real time. The timeline below outlines what DHS will review, what providers must do to remain compliant, and when enforcement actions will occur.
The Minnesota EVV system will verify:
- Type of service performed
- Who received the service
- Date of service
- Location of service delivery
- Who provided the service
- When the service begins and ends
Monitor compliance for all tax IDs and NPI/UMPI numbers, review reports regularly, correct issues, and check MN-ITS for DHS notices. Providers must ensure third‑party systems connect to HHAX and meet state requirements. DHS does not oversee third-party devices.
Focusing on the fundamentals is paramount in compliance. EVV is no different and providers that master documentation, enrollment, and maintain clean data should be well positioned when 80% EVV enforcement begins in October 2026.
Monthly reports are issued on the 25th. DHS reviews each report and sends corrective actions when needed. Providers may be required to submit improvement plans or meet with DHS. Enforcement may escalate if issues are not resolved.
The state-selected EVV system, HHAeXchange (HHAX), offers two verification methods: the mobile application and Interactive Voice Response. Provider agencies using a third-party system may explore other methods to verify EVV that capture the required data. HHAX billing is currently optional, and providers are not required to set up billing through HHAX now. Providers may continue billing through their existing processes if they choose not to use HHAX's billing system.
Keep up with these deadlines and feel free to download the one-pager. Remember to review Minnesota's Department of Human Services (MN DHS) official update page which is linked under sources.
Please note the resource is for quick reference. Always review the authoritative source when evaluating compliance and regulatory requirements. In the case of this EVV update, it'd be MN DHS.
Minnesota Department of Human Services
Electronic visit verification
The federal government will soon require some providers to use electronic visit verification systems to document that people are receiving the services that are billed to the state. Providers of personal care, including personal care assistance (PCA) and some waiver services (beginning in 2020) and home health care providers (beginning in 2023) will use electronic visit verification to be eligible for full federal Medicaid matching dollars.
Disclaimer: The materials, summaries, and resources provided through the Fraud Prevention & Internal Control Series are for general informational and educational purposes only. They are not legal, regulatory, or compliance advice, and they should not be relied upon as a substitute for professional guidance specific to your organization. Regulations and agency requirements may change, and interpretations may vary based on individual circumstances. Hassan CPA, PLLC (dba Hassan.CPA) does not assume responsibility for actions taken based on these materials, and users remain solely responsible for verifying requirements with the appropriate state or federal agencies. Use of these resources does not create a CPA–client relationship.
Published 1/28/2026 | By: Ameera Hassan