PCA timesheet requirements in Minnesota are written into statute, and so are the matching rules for Community First Services and Supports (CFSS). Minn. Stat. § 256B.0659, subd. 12 requires every Personal Care Assistance (PCA) service to be documented daily by the personal care assistant on a time sheet with ten required elements, and § 256B.85, subd. 15 requires the same of every CFSS support worker. The elements are nearly identical: who worked, for whom, on what dates, from what time to what time, doing what, with the signatures of both the worker and the person served.
Electronic visit verification (EVV) has changed how most agencies capture that record, but not what it must contain. An EVV visit is a time sheet in a different container.
This guide covers the required fields, EVV, matching tasks to the plan, signatures, retention, pre-payment review, common failures, and a template outline, as of September 2026.
What the PCA and CFSS statutes require on a time sheet
The two statutes are laid side by side below. Where the CFSS clause differs, the difference is in bold.
| Element | PCA: § 256B.0659, subd. 12(c) | CFSS: § 256B.85, subd. 15(c) |
|---|---|---|
| Worker | Full name and individual provider number | Full name and individual provider number |
| Agency | Provider name and telephone numbers | Agency-provider's name and telephone numbers, when responsible for the service delivery plan |
| Person served | Full name and either the MA identification number or date of birth | Full name |
| Dates and times | Consecutive dates with month, day, and year, and arrival and departure times with a.m. or p.m. notations | Dates within the pay period with month, day, and year, and arrival and departure times with a.m. or p.m. notations |
| Services | Activity documentation that corresponds to the PCA care plan (subd. 12(b)) | The covered services provided on each date of service |
| Person's signature | Signature of the recipient or the responsible party | Signature of the participant or representative and a statement that the signature verifies the time sheet's accuracy |
| Worker's signature | Personal signature of the PCA | Signature of the support worker |
| Shared care | Any shared care provided, if applicable | Any shared care provided, if applicable |
| False-claims statement | Statement that it is a federal crime to provide false information on PCA billings for MA payments | Same statement for CFSS billings |
| Absences | Dates and location of stays in a hospital, care facility, or incarceration | Same, occurring within the pay period |
| Travel | Any travel time, with start and stop times (a.m. or p.m.), origination site, and destination site | Travel documentation under subd. 12c: start and stop times (a.m. or p.m.), origination site, and destination site |
Under PCA subd. 12(a), the time sheet is on a commissioner-approved form, is submitted monthly to the provider, and is kept in the recipient's health record; under subd. 12(b) the qualified professional reviews it against the care plan. Under CFSS subd. 15(a) and (b), the worker submits the time sheet at least once per month to the agency-provider, which keeps a record, gives a copy to the participant, and verifies its accuracy against the participant's assessed needs. In the budget model the participant and the FMS provider receive and verify it instead.
How EVV and the paper time sheet fit together
Both statutes allow electronic records. PCA subd. 12(a) says documentation "may be web-based, electronic, or paper," and CFSS subd. 15(a) says time sheets "may be created, submitted, and maintained electronically." DHS's time and activity documentation page adds that providers may use EVV or the DHS template, CFSS Worker Time and Activity Documentation (DHS-6893C), and that the agency or FMS provider decides the method.
EVV then adds its own compliance layer, described in the Minnesota EVV requirements guide. Since January 1, 2026, every provider must be enrolled with HHAeXchange regardless of the EVV system it uses and must submit data for all visits, including noncompliant ones. At least 50 percent of visits billed after January 1, 2026 and at least 80 percent of visits billed after July 1, 2026 must be EVV compliant. Manually entered or missed visits count as noncompliant, and DHS can escalate from corrective action notices to recoupment and payment suspension.
An EVV visit record should therefore carry every statutory element so that no second document is needed. When a visit must be entered or corrected by hand, the EVV visit corrections and reason codes guide explains how to do it without losing the audit trail; the corrected visit still needs both signatures.
Documenting tasks against the plan
The field that most often separates a paid claim from a recouped one is the services column. PCA subd. 12(b) requires the activity documentation to "correspond to the personal care assistance care plan." CFSS subd. 15(b) requires it to "correspond to the participant's assessed needs within the scope of CFSS covered services," which are the needs and methods written into the CFSS service delivery plan under § 256B.85, subd. 6(c)(4).
A checkbox list of the participant's own plan tasks, filled in per visit, does this. A generic list of every possible ADL does not, because it lets a worker mark tasks the participant was never assessed for. Reviewers also read tasks against times: a two-hour visit whose only documented task is "medication reminder" invites a question about the other 110 minutes.
Audit tip: units are computed from the arrival and departure times, not from the schedule. If a shift was scheduled for four hours and the time sheet shows 1:05 p.m. to 4:20 p.m., the claim is for 13 units, not 16. Let the system compute units from the recorded times so the time sheet and the claim can never disagree.
Signature rules, including electronic signatures
Both statutes require two signatures on every time sheet: the person served (or the responsible party for PCA, or the participant's representative for CFSS) and the worker. The CFSS form must also state that the participant's signature verifies the accuracy of the time sheet. Under § 256B.85, subd. 14a(g), a CFSS participant's representative agrees in writing to "review and sign support worker time sheets after services are provided to verify the provision of services," so a representative who signs a blank sheet at the start of the month is not doing what the agreement requires.
Because the statutes allow electronic time sheets, an electronic signature is acceptable when it identifies the signer, is attached to the specific visit record, and cannot be altered without a trace. A signature captured in the app at clock-out, stored with the visit's times, and locked in an append-only record meets that standard. A typed name added by office staff during billing does not.
Retention: five years
Minn. R. 9505.2190, subp. 1 requires a Minnesota Health Care Programs (MHCP) vendor to "retain all health service and financial records related to a health service for which payment under a program was received or billed for at least five years after the initial date of billing," and it permits electronic storage. For the CFSS budget model, § 256B.85, subd. 13a requires the FMS provider to keep support worker time records for at least five years from the claim date and make them available for audit. Retention includes the signatures and the audit trail.
What a pre-payment reviewer asks for
PCA and CFSS are among the 14 high-risk services on the DHS pre-payment review list as of September 2026. The CFSS billing guide lists what the MHCP and IMCare CFSS manuals expect an agency to have before it submits any claim. For each held claim, expect to produce the signed time and activity documentation for every worker on the claimed dates; the service delivery plan (or PCA care plan) and lead agency addendum; the service authorization letter; the assessment copy; the worker's training, enrollment, and competency records; and the participant agreement, any responsible party or representative form, and the shared services agreement (DHS-6893E) if shared care was billed.
Common documentation failures that cause recoupment
| Failure | Why it fails | Fix |
|---|---|---|
| Missing a.m. or p.m. notation, or a duration instead of clock times | Subd. 12(c)(4) and subd. 15(c)(4) require arrival and departure times with a.m. or p.m. | Capture clock times automatically |
| Participant signature missing, pre-signed, or signed by the worker | Both statutes require the person's own signature verifying the visit | Signature at clock-out, per visit |
| Tasks not in the care plan or service delivery plan | Subd. 12(b) and subd. 15(b) require correspondence to the plan or assessed needs | Task list generated from the plan |
| Overlapping visits for the same worker | A worker cannot serve two participants at once unless shared care is documented | Block overlapping clock-ins; require the DHS-6893E agreement |
| Visits on dates the participant was in a hospital or facility | Both statutes require those dates to be listed, and PCA and CFSS are not covered there | Record admissions and discharges in the participant file |
| Travel billed without start and stop times and sites | Subd. 12(c)(10) and § 256B.85, subd. 12c | Separate travel entry with origin and destination |
| Manually entered EVV visits with no reason code or signature | Counted as noncompliant and unsupported | Reason codes, signatures, and the monthly HHAeXchange report |
| Records unavailable after a vendor change | Five-year retention under Minn. R. 9505.2190 | Export and archive visit detail |
The DHS audit preparation checklist explains how to sample your own time sheets against claims before a reviewer does.
A time sheet template outline
A PCA or CFSS time sheet that satisfies both statutes has five sections. Header: agency name and telephone numbers, worker's full name and provider number (UMPI or NPI), participant's full name (and, for PCA, MA ID or date of birth), and the pay period. Daily rows: date, arrival and departure times with a.m. or p.m., location or GPS confirmation, shared care indicator, and tasks selected from the participant's plan. Exceptions: hospital, care facility, or incarceration dates and locations, and travel entries with times, origination, and destination. Attestations: the federal false-claims statement, the participant's or representative's signature with the accuracy statement, the worker's signature, and both dates. Agency block: the qualified professional review (PCA) or accuracy verification (CFSS), signed and dated, and units computed from the times.
How Trustora helps
Trustora's caregiver app on iOS and Android records each PCA or CFSS visit as a time sheet that carries every element in § 256B.0659, subd. 12 and § 256B.85, subd. 15: the worker's identity and provider number, the participant, GPS clock-in and clock-out times, tasks selected from the participant's care plan or service delivery plan, shared care, and the participant's signature captured at clock-out with the accuracy statement. Visits are sent to the HHAeXchange aggregator, and manual entries require a reason code and are flagged against the EVV compliance rate.
Units are computed from the recorded times, the pre-claim gate holds any T1019 line whose visit lacks a signature or falls outside the authorization, and every record is stored in an append-only audit log with seven-year retention, beyond the five years Minn. R. 9505.2190 requires. The one-click DHS audit binder assembles time sheets, plans, and authorizations for any participant and date range. See the platform overview for the EVV and claims workflow.