Pennsylvania's 85% EVV Standard: What the 2026 Alerts Mean

If you run a personal care agency in Pennsylvania, EVV stopped being a setup project years ago. Since January 2021, Community HealthChoices claims without a matching verified visit have been denied. What changed recently is a second test. Agencies now have to watch two related numbers: whether visits are verified, and how often verified visits needed a manual edit afterward.

That standard has been in force since January 1, 2025. Since January 2026, agencies that miss it get alerts: from the Department of Human Services (DHS) for fee-for-service, and follow-up from their MCO for managed care. This guide explains the 85% threshold, how quarterly monitoring works, and a routine for reviewing exceptions before billing.

This is general information, not legal or billing advice. Check the bulletins linked below and your MCO provider agreement for the rules that apply to your agency.

The rule in one sentence

From dates of service on and after January 1, 2025, Pennsylvania providers must have at least 85% of EVV records for verified visits without manual edits, for Personal Care Services (PCS) and Home Health Care Services (HHCS). That comes from Medical Assistance Bulletin 05-24-01, published August 23, 2024.

Put the other way around: no more than 15% of your visits can be manually edited.

Two details in the bulletin matter more than they seem.

It is measured per program. The bulletin says that providers serving people "across multiple programs must achieve 85% of records without manual edits in each program to be considered fully compliant." A strong rate in one program does not cover a weak one in another.

"Manual edit" is defined broadly. In the bulletin's words: "If a provider has to manipulate data or add missing data or change data in any way after the service is delivered, even if a visit was originally captured using a visit modality that captures in real-time; this is deemed a manual edit."

So a visit that started correctly on the caregiver's phone, but needed a missing clock-out added the next morning, counts as a manual edit. A visit can be completely legitimate and still need a manual correction; the rate counts the correction, not the quality of the care.

What changed in 2026: alerts, then corrective action

MA Bulletin 05-25-03, published August 29, 2025, put enforcement on a calendar:

• Providers self-monitor. "Providers are responsible for self-verifying their EVV manual entry percentage on an ongoing basis." The DHS EVV Aggregator includes an "EVV Compliance" report for this.
• Alerts started in January 2026. For fee-for-service, DHS began issuing alerts to providers whose manual entry percentage exceeded 15% for the previous quarter. The first alerts, in January 2026, were based on the October to December 2025 quarter. Managed care providers are followed up by their MCO.
• Two consecutive quarters above 15% (fee-for-service) result in "a formal notice of noncompliance" and a required corrective action plan (CAP). If the problem continues, the bulletin describes sanctions that weigh the extent of the problem, its trajectory, the CAP status and whether it keeps repeating.
• Managed care. For agencies billing a Community HealthChoices MCO, "the MCO will initiate corrective action with the provider and submit documentation of those actions to the Department."

The 2026 Community HealthChoices Agreement, effective January 1, 2026, backs this up from the MCO side. Each CHC-MCO must monitor that no provider exceeds the manual edit threshold for more than one quarter, and if a provider exceeds it "for two or more consecutive quarters, the CHC-MCO shall impose progressive corrective action requirements or penalties upon the Provider until the non-compliance is ameliorated."

The practical takeaway: one quarter above 15% brings an alert from DHS (fee-for-service) or follow-up from your MCO. Two in a row starts a formal process either way.

The older rule still applies: no verified visit, no payment

The 85% standard sits on top of the original EVV rule, which has not gone away.

• MA Bulletin 07-20-04 (September 2020): "As of January 1, 2021, the Department will deny all PCS visit claims and CHC-MCO PCS encounters that do not have corresponding visit verifications recorded in the Department's EVV Aggregator."
• The CHC Agreement requires MCOs to "validate that visit data submissions support claims submissions as part of the adjudication process."
• Keystone First CHC's provider manual (April 2026): "If you submit a claim without the EVV transaction, the claim will be denied."

At the state level, these show up as Error Status Codes. MA Bulletin 05-21-04 lists ESC 928, "No Matching EVV PCS Visit Found," and ESC 927, "PCS Units Billed Exceed Units Verified in EVV," which denies the units billed above what was verified in EVV. Note that ESC 927 compares billed units with EVV-verified units. It is not the authorization check: a visit can be verified and still exceed the authorization, or be authorized and still lack enough EVV data. Review the two separately.

This creates the trap most agencies feel. An unverified visit gets denied. Correcting it afterward can get it paid, but the correction generally counts as a manual edit, and manual edits are what the 85% standard measures.

Where corrections happen, and how they count

The DHS EVV FAQ is clear that corrections are made in the EVV system where the visit was captured, "not the PA-DHS Aggregator." For most CHC agencies that means HHAeXchange; for others, their certified alternate EVV system. The corrected visit then flows back to the aggregator.

Three consequences follow:

1. Post-service changes generally count as manual edits. That is the general rule under DHS guidance. Some plans publish specific exceptions, such as PA Health & Wellness's guidance for qualifying midnight-shift corrections. Check your plan's current instructions, record the reason for each change and confirm how it appears in your compliance report.
2. Keep the paper trail. The FAQ says that "for any manual entries, however, supporting hard copy documentation should be kept."
3. Paper is not a workaround. Keystone First's manual says "hard copy timesheets must be kept to a minimum and should not be used as the primary source for documenting time," and that the plan "will only accept timesheets that have ALL the data elements listed" in the manual.

Correcting the record and protecting your rate are two separate jobs. The rate improves when fewer exceptions happen at the time of the visit, and when the ones that do happen are caught while they are still easy to document.

Why community-setting visits fail

Personal assistance does not always happen at home. Participants go to appointments, run errands and spend time in the community, and their caregivers go with them. EVV was not built for that.

The Pennsylvania Homecare Association described the problem in testimony in April 2024: community-based care "frequently is not at a pre-determined location. As a result, the system captures GPS coordinates, but they do not correlate to an 'approved' location." The DHS FAQ describes a location perimeter of one quarter mile.

In its July 2026 response to the state's Community HealthChoices RFI, the association added that "providers are increasingly required to defend valid claims simply because services were delivered in an allowable community setting rather than the participant's residence." It also noted that "documentation requirements for Manual Edits are different per provider, making it challenging to operationalize" (2024 testimony).

None of this changes the rule. It does tell you where to look first: participants whose service plans include regular time outside the home are where location exceptions tend to come from.

A practical playbook for staying above 85%

None of the steps below needs new software. They need someone to do them every day, consistently.

1. Review exceptions every day, not at billing time

Pull the previous day's EVV exceptions each morning: missed clock-ins, missed clock-outs, location mismatches, visits without a matching schedule. A visit flagged the next morning can still be confirmed with the caregiver and documented while everyone remembers it. A visit discovered two weeks later at billing is a manual edit with a thin paper trail and a delayed claim.

2. Rank caregivers by exceptions

In many agencies, a small group of caregivers produces most of the exceptions. Rank them weekly by number and type of exception, then look at what is behind each pattern: an app setting that closes the app in the background, missed clock-outs, uncertainty about how to document a community visit. Follow up with those caregivers individually where it helps, instead of re-training the whole staff.

3. Match the schedule to the authorization before the visit

Exceptions are not only about clocking. A visit scheduled outside the authorization creates its own problem. The PHA's 2026 RFI response notes that "many software do not allow for EVV without an active service authorization," and in HHAeXchange, visits that go beyond the authorized units are held in prebilling. That is an authorization check. It is separate from ESC 927, which compares billed units with units verified in EVV. Review both before billing.

Check the following week's schedule against each participant's active authorization before it goes out: hours, dates and expiration. An expiring authorization caught a week early is a phone call to the service coordinator. Caught after the visit, it can mean a held or denied claim for time you already paid the caregiver for. Whether a corrected or retroactive authorization resolves it depends on the payer. Our hours and authorization utilization service is built around this weekly check.

4. Watch new caregivers closely in their first month

New hires are still learning the app, the participant's routine and what to do when the phone does not cooperate. Review their visits daily for the first few weeks, call them after the first exception rather than the fifth, and make sure they know who to contact when something goes wrong during a visit, including after hours.

5. Track your rate weekly, not quarterly

The state measures by quarter, but a quarter is too long to find out you are behind. Each week, count verified visits and manually edited visits by program and calculate the rate. If the quarter is half over and you are at 82%, you still have time to recover. If you find out from the alert, you have already used up one of your two quarters.

To see where you stand right now, our free EVV Score Check takes your visit and manual edit counts, shows your current rate against the 85% line and how many more edited visits you can absorb at your current visit total. It runs in your browser.

6. Know your margin in visits, not percentages

Percentages hide the real numbers. As an illustration: an agency with 1,200 verified visits in a quarter can manually edit up to 180 of them and stay at 85%. Spread over 13 weeks, that is roughly 14 edits a week. If you are already editing 25 a week at that visit volume, you will cross the line well before the quarter ends. Run your own numbers in the EVV Score Check and set a weekly limit your team can see.

A daily routine at a glance

When	What	Why it matters
Every morning	Review yesterday's EVV exceptions and contact the caregivers involved	Exceptions get confirmed and documented while they are fresh
Every week	Rank caregivers by exceptions; coach the top few	Most exceptions usually come from a small group
Every week	Compare next week's schedule with active authorizations	Prevents authorization holds in prebilling
Every week	Calculate the manual edit rate by program	The 85% applies to each program separately
First month of each new hire	Daily review of their visits	Builds correct habits before they become exceptions
End of each quarter	Check the aggregator's EVV Compliance report	Confirms your numbers match what DHS sees

The bottom line

The 85% standard is not new, but 2026 is the year it started to have consequences. Alerts and MCO follow-up come quarter by quarter, and two quarters above 15% move an agency into corrective action with DHS or its MCO. Software helps, but the rate is decided day to day: exceptions reviewed regularly, corrections documented, and the manual-edit rate tracked by program and quarter. Confirm your numbers in the official compliance report and follow your payer's current instructions.

How Concepts Central Support helps

Our team reviews EVV exceptions daily inside HHAeXchange and your EVV system, follows up with caregivers while visits can still be documented, and reports your manual edit rate by program every week. Learn more about our EVV monitoring service, or start with the free EVV Score Check.

Sources

• PA DHS, MA Bulletin 05-24-01 et al., "Updated EVV Manual Edits Compliance Percentage Requirements" (August 23, 2024)
• PA DHS, MA Bulletin 05-25-03 et al., "EVV Manual Edits Noncompliance" (August 29, 2025)
• PA DHS, OLTL/ODP Bulletin 07-20-04 et al., "EVV for Personal Care Services" (September 10, 2020)
• PA DHS, MA Bulletin 05-21-04 et al., "Updated ESC Descriptions for PCS Subject to EVV" (October 22, 2021)
• PA DHS, 2026 Community HealthChoices Agreement (effective January 1, 2026)
• PA DHS, EVV FAQ
• PA DHS, EVV for Personal Care Services
• Keystone First CHC, Provider Manual (April 2026)
• HHAeXchange, Enterprise Process Guide: Prebilling
• Pennsylvania Homecare Association, testimony to the House Human Services Committee (April 8, 2024)
• Pennsylvania Homecare Association, response to the Community HealthChoices RFI (July 14, 2026)
• PA Health & Wellness, Electronic Visit Verification (EVV), including Midnight Shifts
• PA Health & Wellness, 2026 CHC Provider Manual