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Electronic visit verification is federal law. The 21st Century Cures Act requires Medicaid-funded personal care and home care services to electronically capture six data points at every qualifying visit: who provided care, who received it, what service was delivered, the location, the date, and the start and end times.
The law specifies what must be captured. It doesn’t specify how. That distinction matters, because the most common implementation approach creates a consistent operational problem.
Why Caregivers Push Back on Continuous GPS
Many EVV systems track caregiver location continuously during a visit. The data is accurate. The compliance box is checked. But continuous GPS monitoring generates pushback from caregivers at a rate that affects both recruitment and retention.
The objection isn’t unreasonable. Caregivers working in clients’ homes are in a different situation than delivery drivers or fleet vehicles. Continuous location monitoring throughout a shift feels different in a personal care context. Some caregivers decline positions because of GPS tracking requirements. Others comply but with resentment that shows up in turnover.
For agencies operating in a tight labor market, this isn’t a minor HR issue. It affects your ability to staff visits.
What EVV Actually Requires
The federal EVV requirement is to electronically verify that a visit occurred and capture the six required data points. The location data point is one of six. It requires capturing where the visit took place. It does not require monitoring the caregiver’s location throughout the visit.
This distinction is the basis for a different implementation approach: point-in-time geolocation capture.
How Point-in-Time Geolocation Works
When a caregiver clocks in for a visit, they submit a form on their phone. At the moment of form submission, the system captures their location. The same happens at clock-out. Two geolocation data points are captured per visit, corresponding to arrival and departure.
This satisfies the EVV location requirement. The system has an electronic record of where the caregiver was when the visit started and when it ended. There is no continuous tracking between those two points.
Caregivers understand the distinction immediately when it’s explained. Clocking in and out with location capture is familiar behavior. It doesn’t carry the same connotation as background GPS monitoring, and adoption rates are significantly higher.
How Knack Health Handles This
Knack Health captures geolocation through a location record action tied to form submission. When a caregiver submits a clock-in form, the system auto-captures their coordinates. The timestamp is recorded natively. No custom development is required.
See EVV workflows on Knack Health. →
The rest of the EVV workflow connects to this foundation. The six required data points are captured across the clock-in form and the caregiver’s and client’s records: service provider from the caregiver profile, care recipient from the client record, service type from the visit assignment, location from geolocation capture, and date and times from system timestamps.
After the visit, the guardian or family member logs in to review and approve the time card. The approval is logged to the visit record. Admins run the pay period and generate a CSV export formatted for payroll. The full chain from clock-in to payroll runs inside one HIPAA-compliant system.
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FAQs: EVV Without Continuous GPS
Is point-in-time geolocation actually EVV-compliant?
Yes. Federal EVV requirements specify that visit location must be captured electronically. Capturing the caregiver’s location at clock-in and clock-out satisfies this requirement. Always confirm with your state’s EVV program administrator if you have questions about state-specific requirements layered on top of federal standards.
What if a caregiver clocks in from a different location than the client’s home?
Point-in-time capture at clock-in gives you a record of where the caregiver was when they started the visit. If that location doesn’t match the client’s address within a reasonable tolerance, your system can flag it for review. Knack Health supports configurable logic for this kind of exception handling and creates an audit trail without requiring continuous monitoring.
Do caregivers need a special app for this?
No. Clock-in via form submission works in any mobile browser. Caregivers don’t need to download a dedicated app. The form can be accessed from a link, a bookmarked page, or a portal login. Location capture happens through the browser’s standard location API, which prompts the caregiver for permission on first use.
How does guardian approval work in this system?
At the end of each pay period, guardians or authorized family members log in to their portal and review time cards for the individuals in their care. They see visit history, clock-in and clock-out times, and service type for each visit. They approve the time card with a click, and that approval is logged to the record automatically. Admins then process payroll based on the approved records.
