EVV in Self-Directed Care: Program Integrity, Not Punishment

Electronic Visit Verification (EVV) is often framed as a surveillance tool. It isn’t. It’s an early-warning system to identify issues, collaboratively correct them, and protect the health of the program.

People outside of self-directed care (SDC) programs often view SDC as being rife with fraud. After all, on the surface, it’s easy to imagine participants colluding with friends or family members to tweak a couple of timesheets here and there (which ignores the fact that doing so would mean fewer service hours for the participant).  

Add EVV ​requirements into the mix and it can seem like program administrators think the same thing. This misconception was one of the topics discussed by a panel at the ​2025 HCBS conference in Baltimore. 

That assumption is at the core of why EVV is often incorrectly seen as a surveillance tool designed to catch people doing something wrong. 

States and MCOs can learn how to choose an EVV vendor and why the decision matters for everyone involved.

The key to making EVV a first-line program integrity ​(PI) ​defense is to think beyond “this entry was an overlap, we need to deny this timesheet.” That ​thinking ​fosters an adversarial relationship with your participants and their care workers, and wastes valuable opportunities to make your program stronger throughout. 

In Pennsylvania’s Office of Long Term Living program, workers were originally allowed up to 50% of their timesheet entries to be entered manually before it would trigger an audit. However, at the beginning of 2025, the state tightened that threshold to 15% for manual entries.  

It’s understandable that this change could feel like a crackdown, but it wasn’t. Especially with EVV applications often being easier (and quicker) to use for workers to log time versus a manual entry. This change was simply a mature program using data ​​effectively and continuously so that lower threshold could be supported. 

Because the tightening certainly could ​have ​look​ed​ like a restraint, clear and consistent communication with participants and their employees ​was ​​​essential​ for program administrators​. 

As we get calls on what issues [people] are having, maybe it’s EVV compliance: time for a webinar. Maybe it’s about what it means when you’re doing a lot of manual entry. We’re able to nail down more of what we need to educate on.

– Tami Rogers

It’s on us to ​educate stakeholders on the real purpose of EVV. ​​It’s not ​​a leash — it’s a guardrail supporting freedom of choice and ensuring that freedom is available in the future.

Read more: Program Integrity Is a Team Sport.

A common complaint about EVV is that it tethers the participant and worker to the home. That’s impractical. 

Program administrators in Arkansas’ Independent Choices program are making changes to reflect this. 

Now, instead of automatically treating location mismatches as noncompliance, Arkansas is adjusting EVV policies to reflect real life. 

That’s not cracking down — it’s using data to understand how people in the program behave and making changes to accommodate that behavior. 

During the HCBS panel, a recurring theme emerged: single audit events don’t make for robust program integrity. 

We have a lot of reports because it also helps us capture mistakes that occur [throughout] the program. It has been extremely, extremely beneficial.

– Tami Rogers

When EVV data is continuously reviewed as part of regular operations:

• Manual timesheet entries beyond the threshold can become educational opportunities. 
• Overlapping shifts can trigger a conversation to understand causes and educate. 
• Unusual utilization patterns can prompt outreach for clarification and targeted case reviews. 

To help with these conversations, states like Pennsylvania are pulling their service coordinators into EVV review sessions: 

Looking at EVV more like a signal than an alarm — and acting accordingly — improves relationships between stakeholders and enhances program integrity.​​​ 

And, importantly, PI executed this way scales smoothly as self-direction programs grow. Relying solely on post-payment audits doesn’t. 

When EVV is treated as surveillance, it creates friction. When it’s treated as an early warning sign, and integrated with payroll rules, utilization monitoring, and eligibility validation, it becomes part of everyday integrity. 

Financial management service (FMS) providers are uniquely positioned at the intersection of payroll, EVV, eligibility, and budget data​, making them a critical player in the everyday integrity process​.​     ​ 

HCBS conference panelists repeatedly emphasized that integrity isn’t owned by one entity.  

We are all working together — it’s not just one person’s responsibility. We have to connect and work together to keep integrity in the program, but it’s not just one entity, it’s all of us.

– Tami Rogers

An FMS partner that uses EVV data to inform training, clarify expectations, and surface trends early becomes a cornerstone of that shared integrity model. 

Not a watchdog. A facilitator. 

In a mature program, EVV isn’t punishment. It’s program integrity at work​.

This is the third in a series of four stories about program integrity within self-directed care.

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• How Strong Fiscal Intermediaries Protect Self-Directed Care Programs
• Protection by Design: How Self-Directed Care Programs Control Fraud, Waste, and Abuse
• How a Single Fiscal Intermediary Strengthens Program Integrity in Self-Directed Care