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EVV was federally mandated by the 21st Century Cures Act (2016) for all Medicaid-funded personal care and home health services requiring in-home visits. While EVV is not universally required for ABA today, states are actively expanding requirements — and your platform choice now will determine how painlessly you comply later.
Does EVV apply to ABA? The federal mandate covers Personal Care Services (PCS) and Home Health Services (HHCS) — ABA is not explicitly listed. However, Colorado and Florida currently require EVV for ABA, and additional states (Arizona, California, and others) are expected to follow. Practices billing Medicaid for home-based ABA should prepare now. Colorado requires EVV for behavioral therapies provided in home or community settings.
States below have active or expanding EVV requirements that affect or are likely to affect ABA providers billing Medicaid for home/community-based services.
| State | ABA EVV Required? | PCS/HHCS EVV | EVV Model | 85% Compliance Enforced? | Notes |
|---|---|---|---|---|---|
| Colorado | ✓ YES — Active | ✓ Required | Hybrid (state or provider choice) | Yes | Requires EVV for behavioral therapies in home AND community. Integrated with Sandata aggregator. Went live Aug 2020; claim edits active Feb 2022. |
| Florida (Regions 9,10,11) | ✓ YES — Active | ✓ Required | Closed/vendor (Tellus) | Yes — 85%+ | South Florida regions mandated for ABA. CentralReach integrated with Tellus. Strict enforcement ongoing. |
| Pennsylvania | PCS/HHCS only | ✓ Required | Open / provider choice | Yes — 85% from 2025 | Not yet ABA-specific but strict 85% EVV enforcement started 2025. VoIP check-ins rejected. |
| New Jersey | PCS/HHCS only | ✓ Required | Open / provider choice | Yes — 85% from 2025 | Actively enforcing 85% auto-verification benchmark as of 2025. |
| North Carolina | PCS/HHCS only | ✓ Required | Closed (state system) | Yes — 85%+ enforced | 85% compliance threshold enforced strictly. Manual edits flagged. |
| Texas | PCS/HHCS only | ✓ Required | Open (provider/state option) | Compliance reviews active | HHSC conducts EVV compliance reviews. ABA not yet mandated but strong compliance culture. EVV reason codes required. |
| New Mexico | PCS/HHCS only | ✓ Required | Open | 85%+ officially required | NM officially demands 85%+ EVV compliance. Audits increasing. |
| Ohio | PCS/HHCS only | ✓ Required | Open | Audits ramping up | Ramping up EVV audits in 2025, flagging repeat offenders. |
| Kansas | PCS/HHCS only | ✓ Required | Open | Audits ramping up | Increasing audit activity in 2025. |
| Arizona | ✓ Required | TBD | Watch | Identified as a likely future ABA EVV state. Prepare now. | |
| California | ✓ Required | Open | Watch | Large Medicaid population; ABA EVV expansion widely anticipated. | |
| All Other States | PCS/HHCS only | ✓ Required | Varies | Varies | All states required EVV for PCS by Jan 1, 2020 and HHCS by Jan 1, 2023. ABA-specific rules vary — check your state Medicaid agency. |
Before signing with any ABA platform, confirm these EVV capabilities — especially if you bill Medicaid for home or community-based services.