The state of Pennsylvania has had an 85% EVV compliance rate requirement for home health care services and personal care services since January 1, 2025. But in 2026, oversight is ramping up as the Pennsylvania Department of Human Services (DHS) establishes clearer monitoring, alerting, and corrective action processes tied to manual EVV edit thresholds.
DHS issued an EVV enforcement bulletin outlining how compliance with EVV manual edit percentages will be monitored and addressed across both managed care and Fee-for-Service (FFS) delivery systems.
While enforcement language can sound intimidating, the intent of this update is straightforward: strengthen EVV data integrity, encourage accurate visit capture at the point of care, and create more consistency across the state.
Pennsylvania has been gradually tightening EVV expectations over the past few years.
Effective January 1, 2025, DHS increased the EVV compliance threshold, so providers must ensure at least 85% of visits are verified without manual edits, meaning no more than 15% of visits can include manual corrections. This requirement was communicated through DHS Medical Assistance Bulletins and reinforced through managed care organization (MCO) provider guidance.
The 2026 enforcement memo builds on this existing standard by introducing clearer monitoring and enforcement tied directly to that 15% threshold.
Effective January 2026, DHS will now issue alerts for providers whose manual EVV edit percentage exceeds 15% for the previous quarter.
If providers exceed the 15% manual edit threshold for two consecutive quarters, it will result in the issuance of a formal notice of noncompliance. This notice will be issued by the appropriate program office (ODP, OLTL, or OMAP) and will require the provider to submit a corrective action plan (CAP). If they continue to be noncompliant, they may face sanctions.
DHS expects MCOs to initiate corrective action when providers exceed the threshold for two consecutive quarters and submit documentation of corrective actions to DHS.
The individual receiving services (or their designated representative), known as the Common Law Employer (CLE), is responsible for ensuring EVV compliance. If their manual edit rate exceeds the threshold, corrective action will be initiated. Continued noncompliance may result in involuntary termination from the participant-directed services model.
These changes mark the start of structured, statewide monitoring tied to the manual edit threshold.
It’s important to note that manual edits can still be appropriate in certain situations, such as documented technology failures or connectivity issues. However, consistently high rates of manual adjustments may signal underlying workflow, training, or technology gaps that need to be addressed.
The terminology surrounding EVV compliance can be confusing, especially since different programs and systems may use slightly different language. You may hear terms like soft edits, hard edits, manual edits, or thresholds, sometimes used interchangeably.
For the purposes of this DHS bulletin, “manual edits” refer specifically to changes made in the EVV system after a visit has occurred, rather than visits that were verified in real time at clock-in and clock-out
Manual edits generally include:
These examples are reflected in Pennsylvania MCO EVV guidance and provider education materials.
Occasional corrections are expected. Manual changes above the 15% threshold are what trigger concern.
At the heart of EVV is the goal of validating that care was delivered when, where, and to whom it was supposed to be delivered. High volumes of manual edits make it harder for payers and regulators to verify that the information provided is an accurate, real-time record of service delivery.
High manual edit rates can:
According to DHS, these policies are intended to ensure EVV is being used as designed—capturing visits accurately and in real time whenever possible, rather than relying on after-the-fact corrections.
1. Know Your Numbers
Review EVV reports regularly to understand your current EVV percentage to see how it’s trending. You can also filter your report at the account level to see if certain caregivers are struggling and intervene as needed.
2. Reinforce Caregiver Expectations
Provide clear guidance to your caregivers around when and how to clock in and out, and what to do when issues arise. This can significantly reduce manual edits.
3. Reduce Workflow Friction
Look for recurring issues like connectivity challenges, device problems, or unclear processes that may drive after-the-fact corrections.
4. Review EVV Data Proactively
Routine monitoring can help your team address issues early, before quarterly reviews or MCO outreach.
5. Pair Technology With Process
EVV tools are most effective when paired with documented workflows, caregiver education, and consistent follow-up.
Pennsylvania’s 2026 EVV enforcement update isn’t a sudden shift—it’s the next step in a longer effort to strengthen EVV accuracy statewide.
Agencies that focus on accurate EVV data, caregiver support, and proactive monitoring will be well-positioned to meet expectations without adding unnecessary administrative burden.
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