New to Minnesota compliance? Start with the Minnesota overview — 245D, 144G, CFSS and EVV in one place.
The 80% threshold has been live since July 1, 2026
Minnesota's EVV requirements moved to their second phase on July 1, 2026. Providers must now reach at least 80% compliance on all visits billed, up from the 50% threshold that took effect on January 1, 2026.
The awareness-only period is over. DHS reviewed data without consequence from October through December 2025. Formal corrective action notices began in April 2026, and the escalation path from there runs through claim recoupment to payment suspension.
If you have not looked at your own compliance percentage in the last month, that is the single most useful thing you can do today. DHS expects providers to monitor their own rate and correct problems before the state has to intervene — the responsibility sits with you, not with them.
The Minnesota EVV timeline
| September 1, 2024 | EVV compliance enforcement begins in Minnesota |
| October 1, 2024 | Transition from PCA billing codes to CFSS codes |
| Oct–Dec 2025 | DHS reviews provider data for awareness only — no consequences |
| January 1, 2026 | 50% compliance threshold on all visits billed; HHAeXchange enrollment required |
| April 2026 | DHS begins issuing formal corrective action notices |
| July 1, 2026 | 80% compliance threshold — current requirement |
Which services require EVV in Minnesota
The mandate is broader than most providers assume, and it cuts across service lines that agencies often run on different systems.
Personal care services. PCA services and CFSS under both the agency and budget options, billed under T1019 and its modifiers. The PCA-to-CFSS code transition took effect October 1, 2024.
Home health services. Skilled nursing visits, physical therapy, occupational therapy, speech therapy, respiratory therapy, and home health aide visits.
Waiver services. Crisis respite, homemaker services, community living supports, night supervision, and individualized home supports across the various staffing ratios.
If you run more than one of these — a 245D group home alongside personal care, say — every one of them is inside the mandate, and your compliance percentage is calculated on all visits billed.
The six data elements every visit must capture
Federal requirements under the 21st Century Cures Act define what a verified visit has to record. All six, every time:
1. The type of service performed · 2. The individual receiving the service · 3. The individual providing the service · 4. The date of service · 5. The location of service delivery · 6. The time the service begins and ends
Miss any one and the visit does not count as verified. In practice, the two that fail most often are location — a caregiver clocking in from the car park or from home — and end time, when someone forgets to clock out and the visit stays open.
Minnesota runs an open model — and the free option has a real catch
Minnesota gives providers a choice. You can use the free HHAeXchange system the state sponsors, which includes a mobile app in several languages, telephony in English and Spanish, scheduling and compliance tools at no cost. Or you can use a third-party EVV system that meets state requirements and integrates with HHAeXchange, where the cost is yours.
For an agency that only does personal care, the free system is a genuinely reasonable answer, and we will tell you so.
The catch appears when EVV is not the only thing you document. A 245D group home needs eMAR, ISP progress notes, incident and behavior reporting, DSP scheduling and training records. None of that lives in the free EVV tool. So you run the free system for visits, something else for medications, a spreadsheet for training, and a shared drive for incidents — and then you reconcile between them, by hand, forever.
The cost of the free option is not zero. It is paid in the hours somebody spends keeping four systems agreeing with each other, and in the gaps that appear when they stop agreeing.
Getting enrolled
Enrollment with HHAeXchange is required regardless of which system you use and regardless of who pays your claims. The process runs roughly like this:
1. Complete the Minnesota Provider Enrollment Form. 2. Choose HHAeXchange or a third-party system. 3. If third-party, submit the API configuration ticket so your system can feed the aggregator. 4. Get your LMS credentials and work through the training material. 5. Make sure your agency has an MN-ITS mailbox, because that is where DHS sends things.
The step providers most often skip is the last one. DHS communications — including corrective action notices — go to MN-ITS. An unmonitored mailbox is how a fixable compliance problem becomes a payment suspension.
If you are below 80% right now
First, find out the actual number. It is available in HHAeXchange, and guessing is worse than a bad number you can act on.
Then look at why visits are failing rather than how many. The failure reasons cluster tightly — in most agencies, two causes account for the large majority of rejected visits, and they are usually location capture and unclosed visits. Fixing one workflow habit often moves the percentage more than any amount of general effort.
Submit everything, including the failures. A visit you never submitted cannot be corrected later, and DHS is looking for complete data.
Clear the exception backlog and then give someone ownership of keeping it clear. A weekly thirty-minute pass is enough at most agency sizes; the problem is that when it belongs to nobody it happens never.
And if a corrective action notice has already arrived, respond to it. DHS escalation is a process, not a switch — providers who engage and show a remediation plan are in a very different position from providers who go quiet.
CFSS changed the ground under personal care providers
Community First Services and Supports, governed by Minnesota Statutes § 256B.85, replaced the Personal Care Assistance program and consumer support grants. The billing codes moved from PCA to CFSS on October 1, 2024, and EVV followed the services across.
CFSS is jointly funded — roughly 51% federal Medical Assistance money, the balance from state general funds — and it runs in two models. Under the agency-provider model, the agency employs the support workers, which is where most licensed providers operate. Under the budget model, the participant directs their own services and budget within the CFSS service delivery plan. Both are inside the EVV mandate; the difference is who employs the worker, not whether the visit needs verifying.
Eligibility runs through Medical Assistance enrollment, alternative care participation, or one of the MA waivers, and requires assistance with at least one activity of daily living. Covered services stretch further than people expect: ADLs, instrumental activities like meal preparation and shopping, health-related procedures taught by a licensed professional, assistive technology, worker training and development, and behavior observation and redirection.
That breadth matters for EVV because the same worker may deliver several service types in one visit. If your system records the visit but not the service type, you have failed the first of the six required data elements without noticing.
Which waiver programs are in scope
Providers often think of EVV as a personal care obligation and miss that waiver services carry it too. The Minnesota waivers that route people into EVV-covered services include CADI (Community Access for Disability Inclusion), BI (Brain Injury), EW (Elderly Waiver), DD (Developmental Disabilities), CAC (Community Alternative Care), and the Alternative Care program.
Under those waivers, the services carrying EVV requirements include crisis respite, homemaker services, community living supports, night supervision, and individualized home supports across the staffing ratios.
If you hold a 245D license and deliver individualized home supports or community living supports under CADI or BI, those visits count toward the same compliance percentage as your personal care work. Agencies running both frequently discover this the wrong way — by finding the waiver visits were never being submitted at all.
Three licenses, three regulators, one compliance percentage
Minnesota splits oversight in a way that catches multi-line providers. 144A home care licensure and 144G assisted living both sit with the Department of Health. 245D home and community-based services sits with the Department of Human Services. EVV compliance is measured by DHS across all visits billed regardless of which license the service falls under.
So an operator holding a 144G assisted living license and a 245D license answers to MDH for one survey, DHS for another, and DHS again for a single EVV percentage that spans both. Three sets of expectations, one number.
This is the practical argument against running EVV in one system and everything else in another. When your visit data lives apart from your service documentation, nobody can answer the question a licensor actually asks — show me that this service was delivered, by this person, to this resident, on this date, and that it matched the plan.
What DHS expects you to be doing between now and the next threshold
The compliance percentages have moved once a year so far, and there is no reason to assume 80% is the end of it. Federal rules push states toward full verification, and Minnesota has escalated on schedule each time. Planning around 80% as a permanent ceiling is a bet against the pattern.
What that means practically is that the agencies who will be fine are the ones whose EVV is a by-product of how they already work, rather than a separate task somebody performs. If a caregiver has to remember to open a second app, the compliance rate will always sit a few points below where it should — not because anyone is careless, but because a separate step is a step that gets skipped on a bad day.
The providers who struggle share a pattern: EVV is somebody's job rather than part of the visit. Somebody chases exceptions. Somebody checks the percentage. Somebody remembers to submit. When that person is on leave, the numbers drift, and nobody notices until a notice arrives.
Ask a simpler question than "are we compliant": if the person who currently owns EVV left tomorrow, what would happen to your percentage over the following month? If the answer is that it would quietly fall, the problem is process, not software — and software that makes verification automatic is the only durable fix.
Why agencies fall below the threshold
Clocking in from the wrong place
GPS captures where the caregiver actually was. Clocking in from the car outside, or from home before setting off, produces a visit that fails location verification even though the care happened.
Visits that never get closed
Someone forgets to clock out. The visit stays open, the end time is missing, and the record fails on the sixth data element.
Dead zones and no-signal homes
Rural Minnesota has plenty of places with no mobile data. If your EVV app can't capture offline and sync later, those visits are simply lost.
Exceptions nobody clears
Failed visits pile up in a queue. If clearing them is a manual job nobody owns, the backlog grows quietly until the percentage drops.
Withholding the messy visits
Some agencies hold back non-compliant visits hoping to protect their rate. DHS wants every visit submitted. Holding them back creates a gap, not a better number.
Nobody watching the number
The compliance percentage is knowable at any moment. Most agencies discover theirs when a notice arrives, which is the most expensive time to find out.
What Sothcare does about it
EVV is built into the platform rather than sold as a module. Visits are captured at the point of care with GPS, all six required elements recorded, and submitted to HHAeXchange — including visits that fail compliance rules, because DHS wants complete data.
The Exception Center auto-resubmits what can be fixed automatically and lets you bulk-filter and clear the rest, so one person can work through a week of exceptions in an afternoon instead of reworking each rejection individually.
Your running compliance percentage is on the dashboard, measured against the current state threshold. You see a shortfall forming while there is still time to do something about it.
And because the same system holds your eMAR, ISP notes, DSP scheduling, training records and incident reports, the visit and the documentation are one record rather than four systems you reconcile.
Pricing
Flat monthly fees with unlimited staff accounts. $199 for Group Home / 245D AFC or Assisted Living, $399 for Non-Medical Personal Care, $519 for Skilled Home Health. Running more than one service line? Each additional one is 15% off, under a single login.
EVV is included in all of them. There is no per-visit charge, no per-caregiver fee and no annual contract.
Implementation runs about a week to go live and 30 days to fully transition, in parallel with whatever you use now.
See full pricing →By service line
Common questions
What is the current Minnesota EVV compliance threshold?
As of July 1, 2026, providers must reach at least 80% EVV compliance on all visits billed. That followed a 50% threshold effective January 1, 2026. DHS began issuing formal corrective action notices in April 2026, and escalation can include claim recoupment and payment suspension.
Which Minnesota services require EVV?
Personal care services (PCA and CFSS agency and budget options under T1019 and its modifiers), home health services including skilled nursing visits, physical, occupational, speech and respiratory therapy and home health aide visits, and waiver services including crisis respite, homemaker, community living supports, night supervision and individualized home supports.
Do I have to use HHAeXchange?
You must be enrolled with HHAeXchange as the state aggregator, but Minnesota runs an open model. You can either use the free state-sponsored HHAeXchange system, or use a third-party EVV system that meets state requirements and integrates with HHAeXchange. Costs for a third-party system are the provider's responsibility.
If the state system is free, why would I pay for anything else?
Because the free system does EVV and nothing else. If you also need eMAR, ISP documentation, DSP scheduling, training records and incident reporting, you end up running the free EVV tool alongside two or three other systems and reconciling between them. A third-party system that includes EVV means the visit, the documentation and the schedule are one record.
What are the six required EVV data elements?
Federal rules under the 21st Century Cures Act require every verified visit to capture the type of service performed, the individual receiving the service, the individual providing the service, the date of service, the location of service delivery, and the time the service begins and ends.
Should we withhold visits that fail compliance rules?
No. DHS expects complete data for every visit, including non-compliant ones. Withholding messy visits does not protect your percentage — it leaves a gap in the record, which is worse.
How much does Sothcare cost?
Flat monthly fees with unlimited staff accounts: $199 for Group Home or Assisted Living, $399 for Non-Medical Personal Care, $519 for Skilled Home Health. EVV is included, not an add-on module. No per-visit or per-caregiver charges.
See your real compliance number
20-minute, founder-led demo. Bring your current EVV setup and we will look at where visits are actually failing.
Book my 20-min demoRegulatory details on this page reflect Minnesota DHS and MDH guidance current as of August 2026. Requirements change — confirm current rules with your licensor before relying on this summary. Sothcare is documentation and workflow software; it supports your compliance program but does not replace your licensing, policies, or clinical judgment.