Electronic Visit Verification Fraud: When the Visit Record Was Entered or Changed

Electronic visit verification fraud uses knowingly false visit records to support Medicaid billing for care that did not happen as claimed. If you administer electronic visit verification, approve exceptions or prepare claims, you may see the difference between the visit that occurred and the visit the billing record describes. A worker changes, an address fills itself in, or a supervisor tells staff to approve hours that were never worked. The important connection is between that decision and the claim Medicaid paid. When an agency bills for care nobody provided, the beneficiary goes without that care and taxpayers pay for it.

What Electronic Visit Verification Records

Electronic visit verification records the service, the recipient, the worker, and where and when the visit happened. The 21st Century Cures Act’s visit verification requirement specifies six elements:

• The type of service performed.
• The person receiving it.
• The service date.
• The location of service delivery.
• The person providing it.
• The time the service begins and ends.

The visit record can carry the attendant’s name while the personnel file leaves the agency unable to show that required screening happened. Colorado’s auditors called for providers to maintain documentation that each attendant’s background screening was completed.

The care behind the claim is help with bathing, dressing, preparing meals and light housework. A fabricated visit turns that daily help into a bill for work left undone. In its December 2017 personal-care issue brief, the HHS Office of Inspector General describes agency-directed care, where an agency hires and trains attendants, and self-directed care, where the beneficiary hires and supervises them. That changes who knows the worker, who can describe the care and where the supporting records sit.

In its December 2016 guidance, the Centers for Medicare & Medicaid Services placed responsibility for the truthfulness, accuracy and completeness of agency-directed claims on the agency that signed the provider agreement. That puts the agency’s billing decisions in the picture even when an individual attendant entered the visit. We examine who supplied the information and who chose to use it for payment.

When EVV Became Required

The 21st Century Cures Act established the mandate on December 13, 2016. Congress originally set January 1, 2019 for personal care services, then moved that date to January 1, 2020. Home health care services had a separate compliance date of January 1, 2023. The federal enforcement mechanism reduces a noncompliant state’s federal Medicaid matching funds.

Manual Entries, Live-In Caregivers and Web Timesheets

Colorado’s EVV system accepted manually entered visits. The useful question for an administrator is what supports the entered information: who supplied the time and location, what the attendant actually did, and how the entry reached billing.

The HHS Office of Inspector General’s July 2026 Colorado audit found an enrollee whose entire year of EVV records consisted of manual entries: 185 records. A full year, typed in by hand. The original timesheets, reasons for manual entry and supporting service records become central to understanding it.

Coverage also depends on the arrangement. The Centers for Medicare & Medicaid Services’ August 2019 guidance said the federal EVV requirements do not apply when the caregiver and beneficiary live together. Its earlier guidance excluded personal care in congregate residential settings with round-the-clock service and treated the Program of All-Inclusive Care for the Elderly as outside the mandate.

Web-based timesheets present a different issue. The same agency explained that a caregiver entering time and location, followed by the beneficiary authenticating it, leaves the state without auditable confirmation of what was entered. Those web timesheets alone do not satisfy the federal requirement.

Does EVV Track Your Location?

EVV includes the location of service delivery. The Centers for Medicare & Medicaid Services’ August 2019 guidance described systems using GPS or landlines to capture location. For a particular visit, we examine how that location was obtained and whether it describes where the service actually occurred.

An address supplied by software, a location typed by an employee and a location captured during the visit answer different questions about how the record was created.

How an Electronic Visit Verification Edit Reaches a Medicaid Claim

An EVV manual correction audit trail connects the original entry, the change, the person making it, the explanation and the resulting claim. We work through that sequence with the employee who understands the system and the care it records.

A visit entered after the service date raises a concrete question about billing evidence: what information existed when the care was said to have occurred, and what information appeared later? We compare the first entry with the amended record, the edit time, the reason given and any supervisor approval. The accompanying timesheet and service documentation explain what the editor had to work from.

The comparison then reaches the claim. Which visit and attendant does it represent? Do the billed units match the authorized care and the hours supported by the timesheet? What did the agency submit, and what did Medicaid pay? Colorado’s auditors recommended checks connecting paid units to approved care plans, rates to state-approved rates, and EVV attendant names to signed timesheets.

The employee’s account supplies the decision behind the data. If you saw instructions to enter time that had not been worked, we examine those instructions with you alongside the original record and the claim that used the added time. A screen showing the final value tells only part of that story. The history can show how the value got there and who chose it.

Location Data Can Conceal the Missing Information

Colorado’s audit found location information appearing in visit data even when the underlying EVV records did not specify where the services occurred. For 55 claim lines, the displayed address had been auto-populated. The address looked complete while the supporting record left the service location missing.

The audit also described a reason note that should contain the address where the attendant provided care, but accepted any text. For an insider, the content of that note matters more than the fact that someone filled the box. A completed field can still leave the central question unanswered: where was the attendant?

GPS exceptions had a similar problem. The system flagged them, but the state did not require anyone to correct or address them before a visit could be verified. We think that defeats the point of the check. The flag existed. Resolving it was optional.

The HHS Office of Inspector General’s published recommendations for Colorado addressed the underlying controls: capture the actual service location, require review and correction of GPS exceptions, and monitor whether providers use reason codes appropriately. For a whistleblower case, we connect those fields to the employee’s account of the visit and the payment they supported.

The Timesheet, the Worker and the Hours Billed

An overlapping timesheet becomes useful evidence when it identifies the same attendant claiming to work in different places at the same time. Other records can show where the person actually was.

The HHS Office of Inspector General’s Medicaid Fraud Control Units Fiscal Year 2014 Annual Report, published in 2015, describes the Nebraska Medicaid Fraud Control Unit’s investigations in particularly plain terms:

That comparison reaches beyond the visit record the agency wants paid. It tests the claimed hours against another account of the same worker’s time. The agency’s personal-care issue brief also reports that fraud units recommended cross-checking both the attendant’s and the beneficiary’s locations.

The HHS Office of Inspector General’s 2017 issue brief also records why finding the same attendant across providers can be difficult: some states did not enroll or register attendants or assign them individual provider identifiers. Fraud units told the agency that this made it harder to monitor an attendant’s billing. A scheduler who recognizes the person across assignments may know a connection the claims leave out.

In its account of a personal-care aide’s criminal guilty plea in the District of Columbia, the Justice Department described false personal-care timesheets contradicted by law-school attendance, key-card records and telephone-location records. The records of her activities supplied a comparison outside the home-care paperwork.

The Justice Department’s account of another District of Columbia criminal case ending in a guilty plea described false timesheets across twelve agencies, overlapping hours, foreign travel and a hospitalized beneficiary. For someone reviewing EVV, the parallel is the underlying service claim: which person could have provided this care, to this recipient, during these hours?

Payroll supplies another comparison. In November 2025, residential group-home operator Sola paid $2 million to resolve allegations of $641,396 in Medicaid overbilling. The government alleged that nursing units billed exceeded the hours nurses actually worked, as shown by payroll and time records. The Justice Department’s Sola announcement shows why hours claimed and hours worked belong together. We use that same comparison when examining what a changed visit record caused an agency to bill.

State EVV Attestations and the Colorado Audit

The Centers for Medicare & Medicaid Services assesses state EVV compliance using a survey through which states report their own implementation progress. Colorado received federal acceptance in January 2021, yet the HHS Office of Inspector General later estimated that 52 percent of claim lines did not comply with EVV requirements in the 2024 state fiscal year. We think that is a substantial gap between accepting a state’s assurance and checking the visits behind its claims.

In its July 17, 2026 audit, the HHS Office of Inspector General recommended that Colorado refund $8,072,870 in estimated federal overpayments. It also set aside $45,688,080 in federal payments for Colorado and CMS to determine whether they met payment requirements. Colorado disagreed with most of the findings and recommendations.

The audit also called for completed service plans for people receiving consumer-directed care and enough timesheet detail to show that the work followed those plans. A verified visit still needs records of the care it represents.

Kansas supplied a related finding. After accepting that state’s compliance attestation, federal auditors found in August 2024 that its EVV system had no procedure to prevent claims being submitted outside it. Kansas had a verification system. It lacked a check to keep claims from going around it.

We follow that connection down to the service. A statewide attestation describes the state’s implementation. An agency’s records show what it billed for a particular attendant and recipient. The insider who knows how exceptions reached billing can explain the part that a statewide form never describes.

What an EVV Administrator Can Bring to a Whistleblower Case

An EVV administrator can connect the system’s history to the people who entered, changed and approved the visits. The original visit record, later versions, reason notes, supervisor approvals and corresponding claims are the materials we work through together. Timesheets, schedules, payroll and approved care plans let us test that history against the work the agency says it performed.

The care itself stays central. The HHS Office of Inspector General’s personal-care issue brief describes how claims can omit the attendant’s identity, the hours worked each day or the time of day the services occurred. The visit and employment records can restore those details. They let us ask whether the claimed worker could have provided the claimed service, and whether the claim reflects the information the agency actually had.

The False Claims Act reaches knowingly false claims for government money, including billing for services never provided. We connect what you know about false visits and internal decisions to the claims, then bring in Medicaid fraud whistleblower lawyers who understand home healthcare billing. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

When You Know Why the Visit Changed

If you know who changed the visits, what the agency billed and why the care records tell a different story, speak with our whistleblower experts about the EVV records you work with. We build your strongest Medicaid whistleblower case around that knowledge, match it with whistleblower lawyers experienced in personal-care claims, and stay beside you through the case.