Does EVV Apply to NEMT? Electronic Visit Verification and Trip Checks in 2027

EVV and NEMT trip checks answer the same question: did the service happen the way it was billed? They come from different rules, though. EVV is a federal requirement for home care visits. The checks on your rides come from your state Medicaid program and your broker contracts, and in some places they already ask for more than EVV does.

What EVV is and where the rule comes from

Electronic visit verification, or EVV, comes from section 12006 of the 21st Century Cures Act, signed December 13, 2016. It added section 1903(l) to the Social Security Act (42 U.S.C. 1396b(l)). States had to require EVV for Medicaid personal care services by January 1, 2020, and for home health care services by January 1, 2023.

The penalty falls on the state, not on you. A state that does not require EVV loses part of its federal match on those services. The cut grows in steps until it reaches 1 percentage point: in 2023 for personal care, and in 2027 for home health care.

An EVV system must electronically verify six facts about each visit:

1. The type of service performed
2. The person receiving the service
3. The date of the service
4. The location where it was delivered
5. The person providing the service
6. The time the service begins and ends

CMS leaves the method to each state. Its May 16, 2018 FAQ says the law does not require GPS or tracking a caregiver as they move through the community. Capturing where the service starts and stops is enough, and a phone check-in from the home, by landline or cell phone, is a common alternative to GPS. Its August 8, 2019 guidance adds that web timesheets typed in by the caregiver and approved by the member do not count as EVV. They give the state no auditable confirmation of the data.

Why federal EVV does not cover NEMT rides

The statute covers two benefits only: personal care services and home health care services “requiring an in-home visit by a provider.” It reaches personal care under the state plan, under home and community-based services waivers and options (sections 1915(c), (i), (j), and (k)), and under section 1115 demonstrations, plus the home health benefit.

Medical transportation is not on that list. States cover NEMT through the separate duty to assure transportation in 42 CFR 431.53 and 42 CFR 440.170. CMS read the statute this way when it said EVV does not reach PACE, because the law does not cite that benefit.

States spell this out for providers:

State	What its EVV guidance says about rides
California	“Is EVV required if we only provide transportation to medical appointments?” No. Attendant care for medical transportation trips and appointments is not subject to EVV, and medical visits at a doctor’s office are not either (CalEVV FAQ, January 2024).
Texas	The list of personal care services that must use EVV (April 2026, version 10) names programs such as Community First Choice and Community Attendant Services. Transportation is not on it.
Minnesota	NEMT joins the state EVV law starting January 1, 2027, or on federal approval if later (section below).

Federal law sets a floor, not a ceiling. CMS says states may collect more information to fight fraud, waste, and abuse. Check your own state’s page in our state guides before you assume EVV stays off your trips.

When EVV does touch a NEMT ride

Three situations bring EVV close to your work.

You also run a home care agency. If your company bills Medicaid for personal care or home health visits, those visits need EVV. Your rides still follow the transportation rules.

A personal care aide rides with the member. CMS guidance from August 8, 2019 says EVV applies only to the part of a personal care or home health visit rendered in the home, though states may require more. It lists ways to handle a visit that starts at home and ends in the community, such as recording only “home” or “community” as the location. The aide checks in and out in the EVV system their agency uses. Your trip record lists the aide as an escort or attendant. See escorts and caregivers on NEMT trips.

A waiver service bundles personal care with rides. CMS’s May 16, 2018 FAQ says a service that includes personal care or home health is subject to EVV even when it has a different name or includes other services. If you provide a waiver service that mixes the two, ask the waiver agency which parts need EVV. See how to become a waiver non-medical transportation provider.

Minnesota adds NEMT to its EVV law in 2027

Minnesota Session Laws 2026, chapter 121, article 10, signed May 27, 2026, adds nonemergency medical transportation services to the list of services covered by the state EVV law, Minnesota Statutes 256B.073. The law also covers adult day services, recovery peer support, and several other services the federal rule does not.

Rule	What it requires	When
NEMT must follow the EVV law	Every enrolled NEMT provider must comply with section 256B.073. Public transit, volunteers, and not-for-hire vehicles are exempt.	January 1, 2027, or on federal approval if later
EVV records can serve as trip records	Only if the record holds all 14 elements in 256B.0625, subdivision 17b	January 1, 2027, or on federal approval if later
Record at the time of service	All required data is captured when the service happens, using an approved method such as a phone call, a fixed device, or a mobile app	Once EVV starts for NEMT
Manual entries do not count	A visit entered by office staff or edited afterward does not comply, and it must be confirmed through a DHS process before it can support a claim	Once EVV starts for NEMT
Claims are checked against EVV data	DHS and health plans must use EVV data to validate claims. Claims that cannot be validated may face payment or program integrity actions.	Once EVV starts for NEMT
Your choice of system	The state-provided system, which the law says must be free, or a third-party system that sends data to the state’s data aggregator, the entity that collects EVV data for DHS. If your system cannot connect, you must use the state system.	Third-party rules from January 1, 2027, or on federal approval if later
Health plans	Managed care and county-based plans must connect EVV data with their claims systems	By January 1, 2027

DHS sets the rollout schedule. In its July 2, 2026 provider notice, DHS said more services would become subject to EVV and told providers not to enroll with the state EVV vendor for them until it announces instructions.

For services already on EVV, DHS began enforcing compliance thresholds on January 1, 2026: at least 50 percent of visits, rising to 80 percent on July 1, 2026. Providers below the line get corrective action letters in their MN-ITS mailbox. Watch MHCP Provider News for NEMT instructions. Separately, Minnesota reviews fee-for-service NEMT claims before paying them, a process DHS announced in October 2025; see Minnesota NEMT prepayment review and the Minnesota state guide.

The trip checks NEMT does face

Without EVV, your rides are still verified. The duty starts in federal rules and gets its detail from states and brokers.

• Keep records that prove the ride. Every Medicaid provider agrees to keep records that show the extent of its services and to hand them to the state, HHS, or the Medicaid fraud control unit on request (42 CFR 431.107(b)).
• Brokers must watch the trips. A state’s NEMT broker must have oversight procedures to make sure rides are timely and drivers are licensed, qualified, competent, and courteous, and the state must audit the broker (42 CFR 440.170(a)(4)). Brokers pass those duties to you in their contracts.
• Owners verify, not only drivers. CMS’s NEMT booklet for providers (April 2016) says brokers and owners are responsible for confirming that services happened as documented, even when a rider signature is collected. It suggests random calls to riders and to the medical offices on the trip record.

Here is what three programs ask for on each ride:

Program	What each trip must show	Rule date
New York Medicaid	Full GPS compliance: the start point, end point, and all GPS points along the trip, sent to the broker. A driver may sign electronically if the system records pickup and drop-off coordinates with a time stamp that cannot be changed.	GPS since April 3, 2023; manual effective August 25, 2023
MTM Health, Virginia	Vehicle location tracking active for the full ride on every trip, and a performance standard of GPS tracking on more than 90.01 percent of trips. An electronic trip log with the trip ID, scheduled and actual pickup times, departure and arrival times, and the member’s signature, or the claim is denied.	Handbook approved August 10, 2026
Texas Medicaid health plans	A trip manifest with a unique ID for each leg and the signatures of the member and any attendant. Plans may verify the ride by digital signature or GPS at the origin and destination.	UMCM 16.4, effective August 1, 2021

New York’s rule asks for more location data than federal EVV does. EVV needs only where a visit starts and ends, while New York wants the whole route. For the full field list, see NEMT trip documentation and the New York state guide.

Federal reviewers are looking at these records now. HHS’s Office of Inspector General announced targeted reviews of NEMT billing on October 15, 2025, and a series of state NEMT payment audits on May 28, 2026. See Medicaid audits for NEMT providers.

How EVV’s six data points compare to a NEMT trip record

EVV and a trip record overlap, but a trip record needs more. This comparison uses Minnesota’s 14 required elements, because Minnesota will let an EVV record serve as the trip record only when it holds all of them.

EVV data point (42 U.S.C. 1396b(l)(5)(A))	The matching part of a NEMT trip record
Type of service performed	The mode or level of service, such as ambulatory, wheelchair, or stretcher
Person receiving the service	The rider’s name, and on the claim the Medicaid ID
Date of the service	The date of the ride
Location of service delivery	The pickup and drop-off addresses, or a description when there is no address
Person providing the service	The driver’s printed name or provider number
Time the service begins and ends	The pickup time and the drop-off time
Not part of EVV	Odometer readings at pickup and drop-off, the direct-route mileage and how it was found, the license plate, the driver’s signed attestation, the rider’s or medical provider’s signature, and any extra attendant’s name

The last row is why an EVV record alone will not support a mileage claim. Keep capturing odometer readings or GPS miles, the vehicle, and signatures on every trip leg. The NEMT trip log template has a column for each.

How to get your trips ready for EVV-style checks

Whether or not your state adds NEMT to EVV, the direction is the same: more electronic proof, captured at the time of the ride.

1. Collect your rules. Pull your state’s NEMT provider manual, each broker’s handbook, and your contracts. Note every required field, the tracking rule, and the signature rule.
2. Capture times and locations at the curb. Use a driver app that records the pickup and drop-off time and location as they happen. Some apps mark arrivals automatically when the van enters a geofence around the address. See NEMT GPS tracking.
3. Stop after-the-fact edits. Minnesota’s law says a visit entered by staff or edited later does not comply and must be confirmed through a DHS process before it can support a claim. New York pays only for contemporaneous records. When a correction is needed, record who made it, when, and why.
4. Tie every ride to one driver. Minnesota already requires each driver to be individually enrolled and named on the claim as the person who gave the ride.
5. Get the signature before the rider leaves. Train drivers on your state’s fallback when a rider cannot sign. See NEMT signature requirements.
6. Plan for dead zones. CMS lets states use more than one EVV method where cell service is weak. Test that your driver app keeps recording with no signal and uploads later, and carry the paper form your broker accepts.
7. Spot-check your own trips. Each week, call a few riders and medical offices from the trip records, as CMS’s booklet suggests, and fix the habit behind any gap.
8. Protect the data. Trip records and the location data tied to them identify a rider and where they get care. The EVV statute itself requires systems to follow HIPAA privacy and security rules. See HIPAA for NEMT providers.
9. In Minnesota, decide on a system early. Choose between the free state system and your current trip software. Ask your vendor in writing whether it can send data to the state’s data aggregator, and watch MHCP Provider News for the NEMT enrollment date.