How do I calculate my agency's EVV compliance rate in Minnesota?

Use the monthly compliance report that HHAeXchange emails to your enrollment contact around the 25th of each month for the previous month. It counts visits captured electronically at clock-in and clock-out as compliant, and visits that were manually entered, edited after the fact, or missing as noncompliant, across all tax IDs, NPIs, and UMPIs tied to your agency. DHS receives the same report, so your internal dashboard should reconcile to it, not replace it.

What are the most common reasons an EVV visit is noncompliant?

In practice, five causes account for most of them: the caregiver forgot to clock in or out, the phone had no signal and the app did not capture the visit offline, the caregiver selected the wrong client or service, the visit did not match a schedule so it was keyed in later, and an office user edited the times or client after the visit. Each has a different fix, which is why root-cause coding on every manual visit matters more than the overall rate.

Should we let office staff manually enter EVV visits?

Only as a documented exception. Manual and edited visits count as noncompliant in Minnesota, and DHS requires that they still be submitted to HHAeXchange. A workable policy is that a manual entry requires a reason code from a short fixed list, a supervisor's approval, and a same-week conversation with the worker. Track manual entries by worker and by reason; a worker with repeated entries needs retraining or a different device, not another exception.

How often should we review EVV compliance?

Weekly, while the month is still open, and daily for missed clock-outs. A weekly review of the previous seven days by worker and by client lets you correct the pattern before the month closes and the HHAeXchange report is generated. Waiting for the monthly report means you learn about a bad month on the 25th of the following month, after those visits have already been billed and counted.

What should be in an EVV corrective action plan?

The baseline rate and the month it came from, the target rate and date, the root causes found with counts by category, the specific actions for each cause with a named owner and due date, the training completed and scheduled, the device or app changes made, the weekly measure you will report and to whom, and how manual entries are approved. Keep it to two pages and update it monthly. If DHS asks for a written plan, this is what you send.

What do I do if DHS sends an EVV corrective action notice?

Read the notice in the PRVLTR folder of your MN-ITS mailbox the day it arrives and note the deadline. The notice may require a stated compliance rate by a date, a written improvement plan, or a meeting with DHS. Respond in writing before the deadline with your baseline, your plan, and your weekly measures, and keep responding on schedule. Not responding, or not improving, is what triggers escalation to recovering paid claims or withholding future payments.

EVV compliance checklist: how Minnesota agencies reach 80% and stay there

Short answer

This EVV compliance checklist is the operating plan for a Minnesota home care agency that must keep at least 80 percent of billed visits electronically verified, the threshold in effect since July 1, 2026. It covers how to measure your rate from the HHAeXchange monthly report, the five root causes behind most manual visits, training and accountability, a device and app policy, offline capture, visit edits and reason codes, a weekly review, a corrective action plan template, and what to do when a DHS notice arrives.

Key takeaways

Measure compliance the way DHS does: from the HHAeXchange monthly report, across every NPI and UMPI, with manual, edited, and missed visits counted as noncompliant.
Most noncompliant visits come from five causes: the caregiver forgot, there was no signal, the wrong client was selected, the schedule did not match the visit, or the office edited the visit afterward.
Make electronic clock-in the only normal path: manual entry requires a reason code, a supervisor, and a follow-up with the worker.
Hold a weekly compliance review by worker and by client while the month is still open; the 25th-of-the-month report is too late to fix that month.
Write the corrective action plan before DHS asks for one, with a baseline, a target date, named owners, and the weekly measures you will report.
A DHS corrective action notice arrives in the PRVLTR folder of the MN-ITS mailbox and can escalate to recoupment and payment suspension if ignored.

An EVV compliance checklist for a Minnesota home care agency has one target number: at least 80 percent of visits billed after July 1, 2026 must be electronically verified. The Minnesota Department of Human Services (DHS) measures that rate from the HHAeXchange monthly report, sends corrective action notices to agencies below it, and can escalate to recoupment and payment suspension. The rule itself is explained in the Minnesota EVV requirements guide; this article is the operating plan.

The plan is built on one observation: the compliance rate is a process problem with a handful of recurring causes, each with a specific fix. An agency that codes every noncompliant visit by cause, reviews the counts weekly, and closes the causes one at a time gets there. An agency that sends a reminder email to all caregivers does not.

Everything below applies as of September 2026 and assumes the agency is enrolled with HHAeXchange, mandatory since January 1, 2026.

Step 1: Measure your rate the way DHS does

Your internal dashboard is not the number DHS sees. The number DHS sees is on the compliance report HHAeXchange emails to your enrollment contact around the 25th of each month, covering the previous month, and DHS receives the same report.

Confirm the email address on your HHAeXchange enrollment is a monitored mailbox, not a former employee's.
Confirm every NPI and UMPI your agency bills under is in the HHAeXchange office setup. The rate is measured across all identifiers, and one legacy number with no visits drags the total down.
Pull the last three monthly reports and record the rate for each. That is your baseline.
Reconcile your own system's visit count to the report. If your system shows more visits than HHAeXchange received, you have unresolved import rejections, and each is a missed visit on the report.
Know the three noncompliant categories: manually entered, manually edited, and missed. All three must still be submitted.

Audit tip: the threshold applies to visits billed after the date, not visits delivered after it. Late billing pulls older visits into the current window. If June visits are billed in August, they are measured against 80 percent.

Step 2: Code every noncompliant visit by root cause

Export the noncompliant visits from the last full month and assign each one a cause. Five categories cover most agencies.

Cause	What it looks like	Typical fix
Caregiver forgot	No clock-in, or clock-in with no clock-out, then a manual entry from a timesheet	Reminders in the app, missed clock-out alerts, accountability conversation
No signal	Visit in a rural area or apartment building where the app could not connect	An app that captures offline and syncs later; confirm the setting is on
Wrong client or service	Clock-in against the wrong participant or service code, corrected later by the office	Show the worker only today's scheduled clients; confirm the name on screen
Schedule mismatch	Visit happened but no shift existed, so nothing to clock into; entered later	Same-day schedule changes handled by the scheduler, not by after-the-fact entry
Office edit	Times or client changed after capture, often to match the authorization or the claim	Edit policy with reason codes; fix the schedule and the authorization, not the visit

Count the visits in each bucket and by worker. The distribution tells you what to do first: an agency whose noncompliant visits are mostly "caregiver forgot" from a handful of workers has a different plan than one whose visits are mostly "no signal" on two routes.

Step 3: Training and accountability

Train every caregiver on the six things the visit must capture (service, client, date, location, worker, start and stop) and why a timesheet keyed in later does not count.
Train on the worker's own phone, and have the worker complete a real clock-in and clock-out before the first shift.
Put EVV clock-in in the job description and the pay policy. State plainly that a visit with no electronic record is reviewed before it is paid and billed.
Give supervisors a weekly list of workers with manual entries, and require a documented conversation for anyone with more than one.
Recognize workers and teams at 100 percent; the rate usually moves faster on recognition than on warnings.

For CFSS agencies, fold EVV into the competency visits already required at 30 days and every 90 days, so the supervising professional watches a real clock-in during the observation. The PCA to CFSS transition guide describes that visit schedule.

Step 4: Device and app policy

Write it down and have every caregiver sign it.

State which devices are acceptable (the worker's own smartphone on iOS or Android, an agency device, or telephony for clients without a smartphone-capable worker) and what the agency provides when a worker has none.
Require location services on for the app and explain why: location is one of the six required elements.
Require the app to stay installed and updated, with notifications on for missed clock-out alerts.
Define what happens when the phone is lost, broken, or dead: who the worker calls, and how the visit is entered as an exception with a reason code.
Prohibit clocking in for another worker or from a location other than the client's, and state the consequence.

The PCA and CFSS agency software guide lists what the app itself has to do; the policy covers what the worker has to do.

Step 5: Offline capture

"No signal" is the cause agencies most often treat as unfixable, and it usually is fixable. An app that captures the clock-in on the device, with the timestamp and GPS reading taken at that moment, and syncs later produces a compliant visit. A worker who enters the visit after getting back in range produces a manual one.

Confirm your app supports offline capture and that the setting is enabled for every worker.
Test it: put a phone in airplane mode, clock in and out, reconnect, and check that the visit reaches HHAeXchange as an electronic visit, not an edit.
Keep telephony as a fallback for clients with a landline, and train the workers who serve them.

Step 6: Visit edits and reason codes

Edits are sometimes necessary. The goal is not zero edits; it is that every edit is an exception with a record.

Use a short fixed list of reason codes (forgot clock-in, forgot clock-out, no signal, wrong client, wrong service, schedule change, device failure, other with note).
Require a supervisor or designated office role to approve each manual entry or edit; the scheduler who created the shift should not be the one who edits the visit.
Never edit a verified visit to match the claim or the authorization. If the visit ran longer than the units left, the claim is reduced, not the visit. Editing visits to fit the authorization is the pattern DHS looks for in pre-payment review.
Submit every manual and edited visit to HHAeXchange. Withholding them does not raise the rate; it creates missed visits.

The CFSS billing guide explains how units are computed from the verified times so that the claim follows the visit and not the other way around.

Step 7: The weekly compliance review

Thirty minutes, same time every week, with the scheduler, a supervisor, and billing.

Rate for the last seven days, agency-wide and by NPI or UMPI.
Import rejections outstanding in HHAeXchange, oldest first, with an owner for each.
Missed clock-outs from the week and whether each was resolved as an edit with a reason code.
Manual entries by worker and by reason code, with the follow-up conversation noted.
Clients or routes with repeated "no signal" causes, and any schedule mismatches.
Month-to-date rate against 80 percent, and the projected rate for the month.

Keep the notes. They are the evidence of a working compliance program if DHS asks, and the raw material for the corrective action plan.

Step 8: Corrective action plan template

Write this before anyone asks for it. Two pages, updated monthly.

1. Baseline. Compliance rate for each of the last three months from the HHAeXchange report, by identifier.

2. Target. The rate you will reach and the month you will reach it. If you are under 80 percent, set an interim monthly target and the date you expect to cross 80.

3. Root causes. Counts of noncompliant visits by cause for the baseline month, and the workers or clients that account for the largest share.

4. Actions. One line per cause: what you are changing, who owns it, when it is done. For example: offline capture enabled and tested for all workers by a date; missed clock-out alerts turned on; retraining completed for named workers.

5. Training. Sessions completed and scheduled, with attendance.

6. Monitoring. The weekly review, who attends, and the measure reported. State that manual entries require a reason code and approval.

7. Reporting. How and when you will report progress to DHS if asked, and who signs.

Step 9: When a DHS notice arrives

A notice of corrective action is delivered to the PRVLTR folder in your MN-ITS mailbox, not by email, so someone must check that folder at least weekly.

Read the notice the day it arrives. Record the deadline and what it requires: a stated rate by a date, a written plan, a meeting, or a combination.
Respond in writing before the deadline, using the plan above with the current month's numbers.
If a meeting is required, bring the weekly review notes and the reason-code report.
Keep reporting on the schedule DHS sets even after the rate crosses 80 percent.
Do not ignore the notice. Not responding, or not making the required improvements, is what allows DHS to recover payments already made and withhold future payments until compliance is demonstrated.

A recoupment for EVV noncompliance is handled like any other overpayment; the MHCP claim denials guide covers the remittance and the appeal packet.

Step 10: Staying at 80 percent

The rate falls when the agency changes: a new scheduler, a wave of new hires, a new client in a dead zone. Build the checks into those events.

Every new hire completes a live clock-in and clock-out before the first billed visit.
Every new client's address is tested for signal on the first visit.
Every new billing identifier is added to the HHAeXchange office setup before it bills.
The corrective action plan is updated monthly even when the rate is fine.

How Trustora helps

Trustora's caregiver app on iOS and Android captures GPS clock-in and clock-out and the client's signature at the time of service, works offline and syncs when a signal returns, and shows the worker only the clients scheduled for that day. Manual entries and edits require a reason code from a fixed list and a supervisor's approval, every visit is sent to the HHAeXchange aggregator, and the compliance engine shows the month-to-date rate by worker, client, and identifier so the weekly review runs from live numbers rather than last month's report.

Gap-day alerts flag scheduled visits with no clock-in the same day, missed clock-outs are queued for the supervisor, and the one-click audit binder produces the reason-code history and weekly review record for any date range if DHS asks how compliance is monitored. See the features page for the EVV and compliance workflow.

Frequently asked questions

How do I calculate my agency's EVV compliance rate in Minnesota?: Use the monthly compliance report that HHAeXchange emails to your enrollment contact around the 25th of each month for the previous month. It counts visits captured electronically at clock-in and clock-out as compliant, and visits that were manually entered, edited after the fact, or missing as noncompliant, across all tax IDs, NPIs, and UMPIs tied to your agency. DHS receives the same report, so your internal dashboard should reconcile to it, not replace it.
What are the most common reasons an EVV visit is noncompliant?: In practice, five causes account for most of them: the caregiver forgot to clock in or out, the phone had no signal and the app did not capture the visit offline, the caregiver selected the wrong client or service, the visit did not match a schedule so it was keyed in later, and an office user edited the times or client after the visit. Each has a different fix, which is why root-cause coding on every manual visit matters more than the overall rate.
Should we let office staff manually enter EVV visits?: Only as a documented exception. Manual and edited visits count as noncompliant in Minnesota, and DHS requires that they still be submitted to HHAeXchange. A workable policy is that a manual entry requires a reason code from a short fixed list, a supervisor's approval, and a same-week conversation with the worker. Track manual entries by worker and by reason; a worker with repeated entries needs retraining or a different device, not another exception.
How often should we review EVV compliance?: Weekly, while the month is still open, and daily for missed clock-outs. A weekly review of the previous seven days by worker and by client lets you correct the pattern before the month closes and the HHAeXchange report is generated. Waiting for the monthly report means you learn about a bad month on the 25th of the following month, after those visits have already been billed and counted.
What should be in an EVV corrective action plan?: The baseline rate and the month it came from, the target rate and date, the root causes found with counts by category, the specific actions for each cause with a named owner and due date, the training completed and scheduled, the device or app changes made, the weekly measure you will report and to whom, and how manual entries are approved. Keep it to two pages and update it monthly. If DHS asks for a written plan, this is what you send.
What do I do if DHS sends an EVV corrective action notice?: Read the notice in the PRVLTR folder of your MN-ITS mailbox the day it arrives and note the deadline. The notice may require a stated compliance rate by a date, a written improvement plan, or a meeting with DHS. Respond in writing before the deadline with your baseline, your plan, and your weekly measures, and keep responding on schedule. Not responding, or not improving, is what triggers escalation to recovering paid claims or withholding future payments.

Sources and further reading

Cite this article

Trustora Editorial Team. (2026, September 1). EVV compliance checklist: how Minnesota agencies reach 80% and stay there. Trustora. https://trustora.com/blog/evv-compliance-checklist-minnesota-home-care-agencies

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This article is general information for Minnesota agencies, not legal, clinical, or billing advice. Minnesota DHS policy changes often. Confirm current requirements in the MHCP Provider Manual, the Minnesota Statutes, and DHS provider notices before acting on anything here.