Pennsylvania EVV Requirements: The 15% Manual Edit Rule

What Are Pennsylvania's EVV Requirements?

Sagar Kumar, COO and Co-Founder, Verveware

Pennsylvania lets homecare agencies choose their EVV system, but every EVV claim line is checked against the DHS Aggregator. DHS is also now enforcing a limit on manual edits, with quarterly alerts and corrective action plans for agencies that stay over 15%. Here's what Pennsylvania requires as of October 31, 2026, and how to stay under the line.

Pennsylvania EVV requirements apply to Medical Assistance personal care services (PCS) and home health care services (HHCS) that require an in-home visit. Each visit must capture the six Cures Act data points and reach the DHS Aggregator before you bill, and at least 85% of verified visits each quarter must have no manual edits. Pennsylvania uses an open model: fee-for-service providers can use the state-sponsored DHS EVV system (Sandata) or an alternate EVV system that meets DHS technical specifications.

Community HealthChoices providers can use the MCOs' EVV system, HHAeXchange, or work with each contracted MCO so their own system sends data to HHAeXchange. The DHS EVV system doesn't support visits billed to an MCO. Live-in caregivers aren't exempt (see our EVV live-in caregiver exemption guide for other states).

How Claims Are Checked Against the DHS Aggregator

When a claim line includes an EVV service, PROMISe looks for a matching record in the DHS Aggregator. ESC 925 or 935 means the line passed. ESC 928 or 938 means no matching visit was found, and ESC 927 or 937 means the units billed exceed the units verified in EVV.

A "no matching visit" denial usually means the visit reached the Aggregator after the claim, the record is still incomplete, or the claim and record don't match on date of service, 10-digit Recipient ID, procedure code and modifier, or 9-digit provider ID (MPI). A common one is sending the 9-digit MA ID instead of the 10-digit Recipient ID. The Aggregator is view only, so you fix the visit in your EVV system, resend it, and then resubmit the claim.

The 15% Manual Edit Rule and What Counts

For dates of service on and after January 1, 2025, at least 85% of your verified visits each quarter must have no manual edits, for both PCS and HHCS. If you serve clients in more than one program, you need 85% in each program.

• Manual entry. A visit entered into your EVV system after the point of service.

• Manual edit. Any change after the service is delivered, including adding missing data, even if the visit was first captured in real time.

• Reason codes. Each change carries a reason code from DHS's list, such as Direct Care Worker Error, Mobile Device Issue or Telephony Issue. Participant Refusal and Other also need a note.

• Documentation. Keep the reason for each manual correction where you can produce it as a hard copy during an on-site audit. Paper timesheets aren't required.

• No schedule matching. DHS says visits shouldn't be edited to match a schedule. Visits with incorrect or missing information may be edited.

To check your rate, log in to the Aggregator and go to Reports, then Date Range Reports, then EVV Compliance. You can filter by account, client or employee, and the last page shows your compliance percentages.

What Happens If You Go Over 15%

MA Bulletin 05-25-03 (August 29, 2025) says DHS would begin issuing alerts in January 2026, based on October through December 2025, and then every quarter.

• Fee-for-service. DHS sends the alert, with your manual entry percentage, to your agency. Two consecutive quarters over 15% brings a formal notice of noncompliance from ODP, OLTL or OMAP and a corrective action plan, such as staff training, internal monitoring and process changes.

• Managed care. DHS sends the list to your Community HealthChoices or Physical HealthChoices MCO. After two consecutive quarters over 15%, the MCO starts corrective action and reports it to DHS.

• After the plan. If you're still over, DHS weighs how far over you are, whether you're improving, whether you followed your plan, and how many quarters in a row you've missed before deciding on sanctions.

In participant-directed services, the common law employer is responsible, and continued noncompliance can lead to removal from the participant-directed model.

A Quarter-End Checklist for Pennsylvania Agencies

1. Run the EVV Compliance report for each program, not just your agency overall.

2. Sort manual edits by reason code and caregiver to find the top causes.

3. Coach caregivers who miss clock-ins or clock-outs, and give them a backup method such as telephony.

4. Fix incomplete and rejected records in your EVV system before you bill.

5. Confirm every client record carries the 10-digit Recipient ID.

6. Keep a printable reason for every manual correction.

7. If you use an alternate EVV system, confirm your vendor's certification with the Sandata Alternate EVV team and that it's working from the current Alternate EVV Technical Specifications (v1.5, October 2026). Ask each MCO how it reviews edits.

How Verveware Helps You Keep Edits Down

Verveware EVV connects to state EVV aggregators and works in any state's EVV setup. It captures all six data points at the moment of care, by GPS or by telephony IVR with caller ID matched to the client record. Early clock-ins, late clock-outs, missed clock-outs and geofence exceptions are color-coded on the schedule, and coordinators clear them with reason and action memo codes. If there's no signal at clock-in, the Vervecare caregiver app stores the clock-in on the phone and syncs it later with the original timestamp.

With AI Auto Punch, scheduled, actual and punch times are all stored, and none overwrites another, so a corrected visit still shows what the caregiver clocked. The Aggregator Dashboard shows every submission's status, the exact reason text the aggregator returned for a failure, and your EVV compliance percentage per payer.

This post isn't legal advice. Check DHS's EVV pages, current bulletins and your MCO contracts before you change your process.

Frequently Asked Questions

What Is the EVV Manual Edit Threshold in Pennsylvania?

No more than 15% of your verified visits can have manual entries or edits each quarter, which means at least 85% must be captured without them. The rule applies to PCS and HHCS, separately in each program you serve.

Can I Use My Own EVV System in Pennsylvania?

Yes. Pennsylvania uses an open model, so you can use an alternate EVV system that meets DHS technical specifications and sends data to the DHS Aggregator. The state-sponsored DHS EVV system covers fee-for-service visits only.

Does Pennsylvania Require GPS for EVV?

Location is required, but GPS isn't the only option. Landline telephony, fixed VOIP, or a cell phone paired with an in-home fixed device also meet the requirement. DHS says it isn't currently validating location for billing.

What Does ESC 928 Mean?

ESC 928 means PROMISe found no matching PCS EVV visit in the DHS Aggregator (ESC 938 is the HHCS version). Send or fix the visit in your EVV system, make sure it's verified in the Aggregator, and resubmit the claim.

What Happens If I Go Over 15% Manual Edits?

DHS or your MCO will flag it. Two consecutive quarters over 15% leads to a formal notice and a corrective action plan, and continued noncompliance can lead to sanctions.

Get Ahead of Your Next EVV Compliance Report

Schedule a Verveware demo to see exceptions, reason codes and aggregator status for every visit.