How Do Caregivers Do EVV Without a Smartphone?
Federal EVV law does not require a smartphone. Caregivers can verify visits by telephony from the client's phone, a fixed device, or an agency-issued phone.
By Caregiver Scheduling Team ·
A caregiver without a smartphone can usually verify visits by calling a toll-free number from the client’s landline or registered phone (telephony, also called IVR), or by reading codes from a small fixed device kept in the client’s home. Which methods count depends on your state’s EVV system, not on federal law. Many agencies also lend a few basic smartphones. Pick one method per caregiver, record it in their profile, and watch the exceptions.
Does federal EVV law require a smartphone?
No. Section 12006 of the 21st Century Cures Act, now 42 U.S.C. 1396b(l), requires states to use EVV for Medicaid personal care and home health services. It names six data elements to verify electronically: type of service, individual receiving it, date, location, individual providing it, and start and end time. It requires the state’s system to be “minimally burdensome” and says nothing about phones.
CMS agrees. Its EVV guidance sets the deadlines, January 1, 2020 for personal care and January 1, 2023 for home health, with federal match reductions of up to 1% for states that missed them. Its May 2018 FAQ says there is no requirement to use GPS and calls Interactive Voice Response from a landline or cell phone at the individual’s home a common alternative. See what is EVV in home care.
What are the alternatives to a smartphone app?
Three, and most state systems accept at least two. Arizona’s Medicaid agency, for example, requires at least two modalities so members can choose and areas without reliable service are covered.
| Method | How the visit is verified | Where it fails |
|---|---|---|
| Smartphone app | GPS location at check-in and check-out on the caregiver’s phone | No smartphone, or no signal and no offline mode |
| Telephony (IVR) | Caregiver dials a toll-free number from the client’s registered phone; the system logs the number and time | No landline; number not registered; call made from the caregiver’s own cell |
| Fixed device (FOB) | A device in the home shows a time-based code at start and end; the caregiver records both and enters them later | Device lost or moved; codes entered late or wrong |
| Agency-issued phone | Agency lends a basic smartphone with the app installed | Cost, loss, phone left at home |
States vary on whether the caregiver may use the client’s cell phone or only a landline. Check what yours accepts in the EVV state directory.
How does telephony work day to day?
The caregiver calls a toll-free number on arrival and again on departure, from a phone registered to the client. The system uses caller ID to confirm location, so the number on file has to match. Under Arizona’s rules, for instance, a caregiver using the client’s landline must start and end the visit in the home, and the member’s phone, not the caregiver’s, is the device.
Three things go wrong: the client’s number changes and nobody updates the record, the visit ends away from home, or the caregiver calls from a personal cell. Each becomes an exception, so review telephony visits weekly.
How does a fixed device work?
A tamper-resistant device the size of a key fob is fixed in the client’s home and displays a code that changes with time. The caregiver writes down one code on arrival and another on departure, then enters both with the visit times, or the office does. Because the code is tied to the device’s clock and the device to the home, the pair proves presence and time.
It suits clients with no landline and caregivers with no phone; some states treat it as a last resort. Track every device by serial number and client, and require codes within 24 hours. See EVV exception codes.
Should you lend caregivers a phone?
For a handful of caregivers, usually yes. Pew Research found 91% of U.S. adults owned a smartphone in 2025, and 82% of adults in households earning under $30,000. In an agency of 25 caregivers, that leaves two to four who may not have one or will not use a personal phone for work. A basic phone on a prepaid line costs less per month than chasing telephony and fob exceptions.
Write a short device policy: work use only, returned on separation, loss reported the same day. Arizona’s FAQ confirms agencies may allow caregivers’ own phones and that an EVV app may work offline and sync later. See EVV GPS check-in not working.
How do you manage mixed methods without exceptions piling up?
One method per caregiver, recorded in their profile, and a weekly report of unverified visits by method. Rising telephony exceptions mean stale client phone records. Rising fob exceptions mean late code entry. Rising app exceptions mean a geofence or signal problem. Apply your state’s exception reasons the same way every time, because a Medicaid claim with an unresolved EVV mismatch is a denied claim.
How Caregiver Scheduling handles this
The caregiver app runs on the caregiver’s own iOS or Android phone, or on an agency-issued one, with geofenced GPS check-in and check-out, and check-ins are saved on the phone when there is no signal. The office sees which visits lack a verified check-in, so telephony or fixed-device records from your state’s system can be reconciled while the visit is fresh. $199/month for up to 10 caregivers or $299/month for up to 50, free for 30 days.
FAQ
Does the Cures Act require GPS or a smartphone? No. It requires six data elements to be verified electronically and says the system must be minimally burdensome. CMS has said GPS is one option, not a requirement.
Can a caregiver use the client’s cell phone for telephony? In some states, if the number is registered to the client. Others require a landline. Check your state’s EVV rules.
What happens if the fixed device is lost? Visits fall back to your state’s exception process until it is replaced, so track devices by serial number and client.
This article is general information, not legal advice. Check your state’s EVV rules and your Medicaid program’s accepted verification methods.