Open vs. Closed EVV Models: What Does Your State's Choice Mean for Your Agency?
In a closed model you must use the state's EVV vendor; in an open model any compliant system that feeds the state aggregator works. How to tell which you're in.
By Caregiver Scheduling Team ·
In a closed EVV model, every Medicaid provider must use the state’s chosen EVV system. In an open model, you can use any compliant system that sends visit data to the state’s aggregator. Many states run a hybrid: a free state system plus a list of certified alternatives. Your state’s model decides whether your scheduling app can also be your EVV, or whether caregivers carry two apps.
Why do states get to choose an EVV model at all?
Because the law requires the data, not the system. Section 12006 of the 21st Century Cures Act required states to use EVV for Medicaid personal care services by January 1, 2020 and home health services by January 1, 2023, or lose up to 1 percent of federal matching funds (Medicaid.gov).
The statute lists six things a system must verify: the type of service, the individual receiving it, the date, the location, the individual providing it, and the start and end times (42 U.S.C. 1396b(l)). It also says nothing in the law requires “a particular or uniform” EVV system. CMS reads that as a limit on CMS, not on states, so a state may still mandate one vendor (CMS bulletin, May 2018).
What are the five EVV models?
CMS described five models in that 2018 bulletin, and states still use the same vocabulary. “Open” and “closed” are shorthand for the two ends of the range.
| CMS model | Who picks the system | Who pays | What it means for you |
|---|---|---|---|
| Provider choice (open) | You | You | Pick any system that meets state standards and sends data to the aggregator |
| Managed care plan choice | Each MCO | The MCO, through capitation rates | Possibly a different app for each plan you bill |
| State mandated in-house (closed) | The state builds it | The state | One required system, often with limited scheduling features |
| State mandated external vendor (closed) | The state picks one vendor | The state | One required system, free to use |
| Open vendor (hybrid) | State system by default, alternatives allowed | State system free; alternatives at your cost | One app if you choose a certified alternative |
CMS noted that providers “may feel the most burden” under the plan choice model, because they can end up training on several systems and tying each one to payroll. Look up your state in the EVV state directory.
How do I tell which model my state uses?
Look for three things on your Medicaid agency’s EVV page: a named state vendor, an “alternate” or “proprietary” system option, and an aggregator. Here are two states that look closed at first glance but are hybrids.
Ohio provides Sandata as its state system and runs the Sandata Aggregator. It also publishes a list of certified alternate EVV vendors that “have demonstrated the ability to collect the required EVV data elements and successfully submit the data” to that aggregator, updated June 12, 2026 (Ohio Department of Medicaid).
Texas provides HHAeXchange “at no cost to program providers.” A provider may instead use an approved EVV proprietary system that exchanges data with the EVV Aggregator, after being approved as a proprietary system operator (Texas HHS EVV Policy Handbook, section 4000).
If your state’s page names one vendor and no alternative path, you are in a closed model. If it names an aggregator and a certification process, you have a choice. See third-party EVV and the aggregator.
What should I do in a closed model?
Use the state system for Medicaid visits and keep your own software for everything else. The state system verifies visits; it rarely does scheduling, private-pay invoicing or payroll well.
- Keep the schedule in one place and treat the state app as the clock-in tool for Medicaid visits.
- Decide how verified hours from the state system reach payroll each week, and who reconciles the two.
- Private-pay clients are not covered by the mandate, so their visits can run entirely in your own app. See does EVV apply to private pay?
What should I do in an open or hybrid model?
Pick one system for scheduling, EVV and payroll, and confirm it is certified for your state’s aggregator before you sign. Ask the vendor three questions:
- Are you on the state’s current certified or approved list?
- Who fixes a visit the aggregator rejects, and how fast?
- Will visits sync within the state’s deadline after collection or edit?
Then run both systems for one billing cycle before you drop the state app. Rejected visits turn into denied claims. See EVV claim denials and what is EVV in home care?
How Caregiver Scheduling handles this
Geofenced GPS check-in captures all six required data points for every visit. Timesheets, payroll export and invoices built from that same verified record are coming soon. Whether your state lets you use it for Medicaid EVV depends on your state’s model and its certification process, so check the directory first. For private-pay visits and scheduling in any state, it works from day one. $199/month for up to 10 caregivers or $299/month for up to 50, free for 30 days.
FAQ
What is an EVV aggregator? A state system that collects visit data from different EVV vendors in one format and matches it to claims.
Is a hybrid model open or closed? Open in practice. You can use the free state system or a certified alternative, as long as the alternative sends data to the aggregator.
Can my state change models? Yes. States have switched vendors and added alternate-system paths since 2020. Watch for provider notices and recertification deadlines.
Does the model affect private-pay clients? No. The Cures Act covers Medicaid personal care and home health visits. Private-pay visits are yours to run however you like.
This article is general information, not legal advice. Check your state Medicaid agency’s current EVV rules.