Minnesota EVV requirements in 2026: thresholds, HHAeXchange, and deadlines

Minnesota EVV requirements changed in 2026 from a data collection rule into a payment rule. Electronic visit verification (EVV) has been required in Minnesota since the federal deadlines, but until this year the Minnesota Department of Human Services (DHS) did not tie a provider's compliance rate to enforcement. As of January 1, 2026 every in-scope provider must be enrolled with HHAeXchange, the state aggregator, and at least 50 percent of billed visits must be EVV compliant. As of July 1, 2026 that threshold is 80 percent.

The consequences are also new. DHS now sends corrective action notices to providers under the threshold, and the notice can escalate to a written improvement plan, a required meeting, recoupment of paid claims, and suspension of payment. This guide explains where the requirement comes from, what an EVV visit must contain, how the aggregator works, which services are covered, what counts as noncompliant, and the enforcement timeline as of September 2026.

If you already know the rules and need the operating plan, go to the EVV compliance checklist.

Where the requirement comes from: the 21st Century Cures Act

Section 12006 of the 21st Century Cures Act, signed in December 2016, added section 1903(l) to the Social Security Act. It requires every state Medicaid program to use EVV for personal care services and home health care services that require an in-home visit by a provider. The original deadline for personal care services was January 1, 2019; Congress extended it by one year to January 1, 2020. Home health care services followed on January 1, 2023. A state that does not comply loses an increasing share of its federal medical assistance percentage, up to one percent.

The Act does not require a particular EVV system. It requires that whatever system a state uses can electronically verify six things about each visit:

Those six elements are what a Minnesota caregiver app is capturing when a worker clocks in and out. A visit that was written on paper and keyed in later has the same six elements on the screen, but it was not electronically verified at the time of service. That distinction is the whole compliance rule.

Minnesota chose a "provider choice" model with a state aggregator. Providers may use the state's system or their own, and all data flows to one place.

HHAeXchange enrollment is required from January 1, 2026

HHAeXchange is Minnesota's state EVV aggregator. It collects visit data from every EVV system in use in the state, produces the compliance report DHS relies on, and, since September 2025, can optionally generate fee-for-service claims from compliant visits. As of January 1, 2026, providers required to use EVV under the Cures Act must complete HHAeXchange enrollment regardless of their chosen EVV system or payer, and must submit all EVV visit data through HHAeXchange, including visits that are not fully compliant.

Enrollment starts with the Minnesota Provider Enrollment Form on the HHAeXchange Minnesota information hub. Submitting it creates the provider's HHAeXchange portal. Providers then confirm that every NPI and UMPI under which they collect EVV data is present in the portal's office setup, register for an MN-ITS mailbox for DHS communications, and, if they use a third-party system, complete the EDI integration.

Two things follow from mandatory enrollment. First, an agency that captures visits perfectly in its own software but has not enrolled or integrated has a compliance rate of zero on the report DHS reads. Second, the compliance rate covers all tax IDs, NPIs, and UMPIs associated with the agency, so a second office or a legacy identifier that is still billing counts.

State-provided system or third-party system

Minnesota providers choose between two paths, and both end at the aggregator.

State-provided HHAeXchange system. DHS provides the HHAeXchange EVV portal and caregiver app at no cost. Caregivers clock in and out with the mobile app, telephony, or a fixed device, and visits are already in the aggregator. HHAeXchange billing for fee-for-service unit-based programs became available to state-system users in December 2025 and is optional.

Third-party EVV system. A provider may use another vendor's system, at the provider's expense, if it meets DHS's business and technical requirements and integrates with HHAeXchange. The provider opens an API configuration ticket, imports caregiver data, and then sends visits through the Electronic Data Interchange (EDI) process. Rejected imports must be reviewed and resolved; an unresolved rejection is a visit that never reached the aggregator. HHAeXchange has published API specifications for the Minnesota data aggregation, and vendors are expected to conform to them.

Which path is right depends on whether the agency wants scheduling, authorization tracking, and claims in the same system as EVV. The PCA and CFSS agency software guide lists what to check in a third-party system's HHAeXchange integration before signing.

The 50 percent and 80 percent thresholds

The rate is measured from the monthly compliance report HHAeXchange emails to the provider's enrollment contact around the 25th of each month, covering the previous month. DHS receives the same report and uses it to assess overall compliance. Providers are responsible for monitoring their own performance and for acting on it immediately; DHS does not wait for the provider to notice.

A visit is compliant when it was captured electronically at the time of service through an approved clock-in and clock-out method. The following count as noncompliant:

• Manually entered visits. A visit created in the portal or app after the fact, from a paper timesheet or a phone call.
• Manually edited visits. A visit that was captured electronically but whose times, client, or service were changed afterward. Edits are sometimes necessary; the point is that they are subtracted from the compliant count.
• Missed visits. A visit that was billed but has no EVV record at all, including visits where the worker forgot to clock in or the app was never used.

All of these must still be submitted to HHAeXchange. The rule is not "send only good visits"; it is "send everything, and 80 percent of it must be good."

Compliance note: the threshold applies to visits billed after the date, not visits delivered after it. A June visit billed in July is inside the 80 percent window. Agencies with a billing lag should treat July 1, 2026 as having arrived for any service still unbilled on that date.

Which services require EVV in Minnesota

EVV covers Medicaid personal care and home health services with in-home visits. According to the HHAeXchange Minnesota information hub, the in-scope services include:

Adult day services are attendance-based and are not EVV services. The compliance requirements apply to financial management services (FMS) providers and to managed care organizations as well as to fee-for-service agencies. For a CFSS agency, EVV is also a billing precondition on every T1019 line; the CFSS billing guide explains how units are computed from the verified times, and the PCA to CFSS transition guide covers the enrollment record that has to be correct before the visit can be billed at all.

Enforcement timeline

DHS announced the enforcement schedule in its "EVV compliance requirements" eList announcement and repeated it in MHCP provider news in September 2025. As of September 2026 the timeline is:

A notice of corrective action may include any of three requirements: an increase in the compliance rate by a specified deadline, a written plan submitted to DHS describing how compliance will be improved, or a meeting with DHS to review performance and next steps. If the provider does not respond or does not make the required improvements, DHS may take additional enforcement action, which can include recovering payments already issued and withholding future payments until the provider demonstrates compliance.

Two practical notes. The notice arrives in the MN-ITS mailbox, not by email, so an agency that does not check the PRVLTR folder can be in corrective action without knowing it. And EVV enforcement is running in parallel with Minnesota Revalidate 2026 and the enrollment freeze, so a provider in corrective action is also being asked to verify its enrollment record. The Revalidate 2026 guide covers that process.

What a provider should do now

If the July report shows 80 percent or better, the work is to keep it there through worker turnover and schedule changes. If it shows less, the order of operations is: confirm every billing identifier is in the HHAeXchange office setup, resolve every import rejection, find the workers and clients that generate the manual visits, and fix the cause rather than the symptom. The EVV compliance checklist is that plan in detail, including a corrective action plan template you can adapt if a DHS notice arrives.

How Trustora helps

Trustora's caregiver app on iOS and Android captures GPS clock-in and clock-out, the client's signature, and the six Cures Act elements at the time of service, works offline and syncs when a signal returns, and sends every visit, compliant or not, to the HHAeXchange aggregator. Manual entries and edits require a reason code and are routed to a supervisor, so the agency sees its compliance rate by worker and by client during the month rather than on the 25th of the next one.

Because scheduling, EVV, and claims are one record, a visit with no EVV capture cannot become an 837P line without a documented exception, and the compliance engine's gap-day alerts flag scheduled visits with no clock-in the same day. See the features page for the EVV, scheduling, and claims workflow.