Electronic Visit Verification is not new — but Texas EVV requirements keep evolving, and the agencies that stay ahead of them don't have compliance surprises. The ones that fall behind are dealing with claim denials, payment holds, and audit requests.

This guide covers what Texas home care agencies need to know about EVV compliance as of June 2026: which services require it, which programs it applies to, how the Texas aggregator model works, and what the ongoing alternative device phase-out means for your operations.

The Federal Foundation: Why EVV Exists

Electronic Visit Verification was mandated at the federal level by the 21st Century Cures Act (2016), which required all states to implement EVV for Medicaid-funded personal care services and home health care. The law requires EVV systems to capture six specific data points for every qualifying visit:

Type of service performed
Individual receiving the service
Date of the service
Location of service delivery
Individual providing the service
Time the service begins and ends

States that failed to implement EVV were subject to reduced federal matching funds. Every state now has an EVV program in place. Texas chose to go further than the federal minimum on several dimensions — both in program scope and enforcement rigor.

Texas EVV Effective Dates

Texas has implemented EVV in two phases aligned with federal deadlines:

January 1, 2021 — Personal care services EVV became required for all Medicaid personal care services delivered in a client's home. This covered the broad category of hands-on assistance with daily living activities.

January 1, 2024 — Home health care services EVV was extended to home health care services requiring in-home visits — including occupational therapy, physical therapy, and nursing services delivered at a client's residence.

As of June 2026, both categories are fully enforced. The policy framework governing both is the EVV Policy Handbook, most recently updated in Revision 26-1 (effective January 30, 2026).

Which Texas Programs Require EVV

EVV is required across a broad range of Texas Medicaid programs and service types. If your agency receives reimbursement through any of the following, EVV applies:

Medicaid managed care programs:

STAR+PLUS (the primary managed long-term services and supports program for adults with disabilities and seniors)
STAR Kids (for children with disabilities)
STAR Health (for children and young adults in foster care)

Fee-for-service (FFS) Medicaid

Specific service types requiring EVV (across these programs):

Community First Choice (CFC) Personal Assistance Services / Habilitation (PAS/HAB)
Personal Assistance Services (PAS)
Primary Home Care (PHC)
Community Attendant Services (CAS)
In-home respite services
Flexible family support services
Protective supervision
Home health aide services
Nursing services in the home
Occupational therapy in the home (as of Jan 1, 2024)
Physical therapy in the home (as of Jan 1, 2024)

Private pay services are not subject to federal EVV mandates. If your agency operates exclusively on private pay — no Medicaid, no Medicaid waiver — EVV is not a federal compliance requirement. That said, GPS-verified visit records provide operational value (payroll accuracy, dispute documentation) even when compliance is not the driver.

If your agency is licensed as an HCSSA in the Personal Attendant Services category and serves any Medicaid clients, EVV applies to those clients' visits.

The Texas EVV Aggregator: HHAeXchange

Texas operates an open EVV model — meaning agencies can use either the state-provided system or an approved proprietary system. Both paths route through the same state aggregator.

The Texas EVV aggregator is HHAeXchange.

CMS certified HHAeXchange as the EVV aggregator for Texas. HHAeXchange became fully operational as the Texas aggregator on October 1, 2023. All EVV visit data — regardless of which system captured it — must be transmitted to HHAeXchange to be considered compliant.

There are two ways to be connected to the aggregator:

Option 1: Use the state-provided HHAeXchange system (free)

HHSC provides access to the HHAeXchange EVV system at no cost to program providers, Financial Management Services Agencies (FMSAs), and Consumer Directed Services (CDS) employers. If your agency does not already have an EVV system in place, this is the free baseline option.

The tradeoff: HHAeXchange is a standalone EVV tool. It does not include full scheduling, billing, or caregiver management. You may end up managing visits in one system and the rest of your operations in another.

Option 2: Use an approved EVV Proprietary System Operator (PSO)

If your home care software includes native EVV functionality, it can be approved as a Proprietary System Operator (PSO) — meaning it captures the required data elements and transmits them to the HHAeXchange aggregator automatically. This is how integrated home care platforms handle Texas EVV compliance: the caregiver clocks in through the scheduling app, the visit data is captured, and the system handles aggregator submission in the background.

For agencies that want one system rather than two, the PSO path is the better operational model. The key question when evaluating software: "Are you a certified PSO for Texas, and does your system transmit directly to HHAeXchange?"

The Alternative Device Phase-Out: What It Means for Your Agency

The biggest EVV compliance news for Texas home care agencies in 2025–2026 is the phased reduction of alternative device usage.

Background: "Alternative devices" in Texas EVV terminology refers to methods other than the standard mobile app or landline clock-in — typically, entering visit data manually or having a scheduler complete clock-ins on a caregiver's behalf. HHSC identified alternative devices as the primary source of EVV data entry manipulation and the highest fraud vulnerability in the visit verification system.

The phase-out schedule:

September 1, 2025: Phase-out begins. New limits on alternative device usage take effect.
September 1, 2028: Full phase-out complete. By this date, alternative devices may be used for a maximum of 5% of total visit transactions per provider.
HHSC began tracking alternative device usage rates in the EVV Portal starting November 1, 2025, giving agencies visibility into their current percentage.

What this means in practice:

If your caregivers are regularly using workarounds — clocking in from the office, having a coordinator enter visit data retroactively, using a shared tablet that isn't GPS-enabled at the visit location — those practices are now being tracked and will become non-compliant on a defined timeline.

The compliance path is straightforward: caregivers need to clock in and out using the mobile app at the client's location. That requires:

A smartphone (either caregiver-owned or agency-provided)
A mobile EVV app that works in the field
Caregiver training on why the clock-in matters and how to handle common exceptions (low signal, client in a care facility, etc.)

Agencies with high alternative device usage rates should treat this as an urgent operational priority. HHSC and managed care organizations conduct EVV compliance reviews — your usage rate is visible to them.

EVV Data Requirements: What Must Be Captured

Texas requires all six federal data elements for every EVV visit transaction:

Data element	How it's typically captured
Service type	Set at scheduling; linked to service code in the EVV system
Client identity	Linked to the scheduled visit record
Date of service	Captured at clock-in
Service location	GPS coordinates at clock-in — must be at or near the client's address
Caregiver identity	Tied to caregiver's login / device
Start and end time	Captured at clock-in and clock-out

For exceptions — visits where the caregiver could not complete a standard GPS clock-in (e.g., a rural client with no cell signal) — Texas requires documented exception workflows that still capture the required data elements through an approved alternative method.

Your EVV system should have a defined exception process, not just a workaround.

EVV Compliance Reviews and Consequences

HHSC and managed care organizations (MCOs) actively review EVV compliance. What they look for:

Compliance rate. What percentage of your EVV-required visits have valid, complete visit records? Gaps in compliance are flagged.

Alternative device usage rate. As discussed above, this is now tracked explicitly and phased limits are in effect.

Data quality. Are GPS coordinates plausible? Are there patterns suggesting clock-ins that don't match visit locations? Are there visit records without matching scheduling data?

Consequences of non-compliance:

Claim denials — visits without valid EVV records can be denied reimbursement. This can be retroactive.
Payment holds — HHSC can suspend payments for agencies that fall below EVV compliance thresholds.
Audit requests — agencies with compliance gaps may be required to produce documentation for past visits.
Contract risk — sustained non-compliance puts Medicaid contracts at risk.

The cost of non-compliance at scale is substantially higher than the cost of building EVV into your operations correctly.

What to Look for in Texas-Compatible EVV Software

If you're evaluating home care software for a Texas agency, here's the EVV-specific checklist:

Is the vendor a certified Texas PSO? This means they have been approved by HHSC to operate as a Proprietary System Operator and transmit data to the HHAeXchange aggregator. Without this, your software cannot handle Medicaid EVV compliance end-to-end.

Is the EVV native or bolted on? Native means the GPS clock-in, data capture, and aggregator transmission are all part of the same system your caregivers use for scheduling. Bolted on means you're managing two separate tools. Native is better for caregiver adoption and compliance rates.

Does the mobile app work for your caregiver population? Texas caregivers are working in clients' homes across urban neighborhoods, suburban developments, and rural areas. Your EVV app needs to handle low-signal environments with offline capture that syncs when connectivity returns.

Does it address the alternative device reduction? Any software that relies heavily on manual data entry or coordinator-side clock-ins is already out of compliance with the spirit of the 2025–2028 phase-out and will create problems as limits tighten. Ask specifically how the vendor handles exception documentation.

Is there real-time compliance reporting? You should be able to see your EVV compliance rate before your MCO does. Proactive monitoring is far cheaper than retroactive remediation.

Texas EVV and HCSSA Licensing

EVV requirements apply to agencies operating under an HCSSA license in Texas. The HCSSA license categories that typically intersect with EVV requirements are:

Licensed Home Health Services
Licensed and Certified Home Health Services
Personal Attendant Services (PAS)

Agencies in the planning or early licensing stage should be building EVV compliance into their operations from day one — not as an afterthought after the first Medicaid contract. The agencies that have the hardest time with EVV are the ones that used a manual workaround to get through launch and then had to retrofit a system onto an established caregiver workforce.

Summary: Texas EVV Compliance Checklist for 2026

EVV required if serving Medicaid clients through STAR+PLUS, STAR Kids, STAR Health, FFS, CFC, PAS, PHC, CAS, in-home respite, or home health programs
HHAeXchange is the Texas state aggregator — all visit data must transmit to it
Two paths to compliance: state-provided HHAeXchange system (free) or a certified PSO software vendor
Six data elements must be captured for every EVV visit
Alternative device phase-out in progress: Sept 1, 2025–Sept 1, 2028; max 5% alt-device visits by 2028
Monitor your alternative device usage rate via the EVV Portal (available since Nov 1, 2025)
HHSC and MCO compliance reviews are ongoing — your compliance rate is visible to payers

Questions About Texas EVV for Your Agency?

Understanding the compliance requirements is one piece. Finding software that handles them automatically — without adding complexity to your caregivers' daily workflow — is the other.

Atlas Care Software EVV for Texas Agencies →

For context on how different home care platforms handle Texas EVV, see our comparisons:

AtlasCare vs AxisCare — both Texas companies; EVV approach compared
AtlasCare vs WellSky Personal Care — national platform vs. Texas-focused alternative

And for the foundational EVV overview that applies in every state, see EVV Compliance Made Easy.

Texas EVV Requirements 2026: A Plain-English Guide for Home Care Agencies