Electronic Visit Verification (EVV) in Colorado

All states: EVV requirements map

Colorado EVV at a glance

Last verified against state sources: 2026-10-08.

How does EVV work in Colorado?

Colorado uses a hybrid EVV model, which the Department of Health Care Policy and Financing (HCPF) also calls Open Choice. Agencies can use the State EVV Solution from Sandata Technologies at no cost, or they can pay for their own EVV software, which the state calls a Provider Choice EVV System. Either way, visit records go to the Sandata Data Aggregator, and from there to the state's fiscal agent, Gainwell Technologies, to be matched against claims.

The State EVV Solution includes a mobile app, telephony and a provider web portal. An agency that picks its own system needs one that meets the federal Cures Act requirements and Colorado's requirements, and that has completed interface testing with Sandata. If the vendor is already connected in Colorado, the provider can skip interface testing. HCPF keeps a list of vendors that have connected to Sandata in Colorado, and notes that the list is not an endorsement.

Colorado's EVV mandate dates from August 3, 2020. EVV records carry the six federal data points, and visits can be recorded in the home or in the community.

Does Colorado deny Medicaid claims without an EVV record?

Yes. Since February 1, 2022, a fee-for-service claim for an EVV-required service is denied when the EVV record is missing or incomplete. The denial shows as EOB 3054, "EVV Record Required and Not Found." Before that date, the same code was informational only and claims still paid.

HCPF's EVV Program Manual lists what the claim and the EVV record have to agree on:

• The billing provider ID
• The member's Medicaid ID
• The dates of service
• The service grouping (the EVV service type the procedure code belongs to)

EVV records are sent to the fiscal agent nightly, and the Program Manual tells providers to bill the day after a visit is verified, so a claim sent the same day can miss its match. For home health agencies with branches, the EVV record needs to reflect the branch NPI that bills.

Community First Choice (CFC) is a recent source of denials. CFC became active on July 1, 2025, members move to it at their Continued Stay Review, and CFC codes (billed with the U2 modifier) still require EVV. HCPF's May 2026 EVV newsletter reported a rise in EOB 3054 denials on the new CFC codes, so it is worth checking that visits for members who have moved to CFC are recorded under the right service.

HCPF also tracks how often visits are entered or changed by hand. The Program Manual says no modification thresholds are currently set, and that thresholds do not stop payment.

Which Colorado services need EVV, and what is exempt?

EVV applies to visit-based services billed fee-for-service to Health First Colorado. That includes personal care and homemaker services, In-Home Support Services (IHSS), Consumer Directed Attendant Support Services (CDASS), home health (nursing, CNA, physical, occupational and speech therapy) and private duty nursing. HCPF publishes the full list of procedure codes and modifiers in its EVV Program Manual, and that list is the place to confirm any single code.

Some services and programs are outside the state EVV requirement:

• Capitated and non fee-for-service programs: Regional Accountable Entities (RAEs), Denver Health Medicaid Choice, Rocky Mountain Health Plan's Prime and RAE capitated behavioral health.
• Other programs: PACE, CHP+ and State SLS.
• Hospice: HCPF told hospice providers to stop collecting EVV for Medicaid billing on July 1, 2024.
• Certain outpatient therapies delivered by telehealth. This does not cover home health agencies, which still need EVV when they deliver occupational, physical or speech therapy by telehealth.

HCPF says its EVV requirement does not apply to the capitated plans. We did not find whether any of those plans sets its own visit verification rules, so check with the plan if you contract with one.

Colorado also has a live-in caregiver exemption, along with exemptions for extenuating circumstances and for reasonable modifications under the ADA. A live-in caregiver claim is billed with Place of Service 99 on the CMS 1500, or Condition Code 23 on the UB-04, and the billing provider keeps the documentation. Personal care, IHSS, home health and private duty nursing are among the services eligible.

In CDASS, the Financial Management Services (FMS) vendor chooses the EVV system, and the employer of record completes the exemption form that the FMS vendor keeps. CDASS also has a compliance protocol that expects at least 80 percent of visits to match each calendar month.

What is changing next for Colorado EVV?

As of our last check, we found no announced change to EVV for personal care, homemaker services or home health in Colorado, and no change of state EVV vendor. The one announced change is a proposed rule that would add EVV for certain therapies delivered in schools. It is not final.

HCPF has proposed amending its EVV rule to require EVV for fee-for-service pediatric behavioral therapies, physical therapy, occupational therapy and speech therapy delivered in a school setting (Place of Service 03). HCPF has said it anticipates the change taking effect in early 2027, but the rule still had to go through public rule review and the Medical Services Board when we checked, so the timing could move. If your agency delivers therapy in schools, follow HCPF's EVV page for the outcome.

The pause on submitting live-in caregiver exemptions through the Provider Web Portal is also unresolved. HCPF had not published a date for restarting it as of its July 2026 newsletter.

Colorado EVV sources

• HCPF: Electronic Visit Verification overview
• HCPF: EVV Program Manual
• HCPF: EVV solution information
• HCPF: EVV alternate vendors
• HCPF: EVV frequently asked questions
• HCPF: EVV Newsletter, July 2026
• HCPF: EVV Newsletter, May 2026
• HCPF: Community First Choice option

Related reading

• EVV Software Compatible with Sandata Aggregator
• EVV Aggregators Explained
• The Benefits of Using 3rd-Party EVV Software
• Field guide: The Omit-and-Resubmit Method for Sandata
• EVV Software Demo Checklist: What to Ask and Test Before You Buy
• EVV requirements for every state (map)

Other states that use Sandata

California, Connecticut, Delaware, District of Columbia, Hawaii, Idaho, Indiana, Maine, Massachusetts, Missouri, Nevada, North Carolina, Ohio, Pennsylvania, Rhode Island, Vermont, Wisconsin. See every state on the EVV requirements map.

Page history

• October 8, 2026: Page rewritten and checked against state sources.

This page is a reference, not legal advice. State rules change, so confirm details with the state before you act on them.

Ankota provides EVV software for Colorado home care agencies and is on HCPF's list of vendors that have connected to Sandata in Colorado. If you would like to talk through Colorado's requirements, contact Ankota or read more about Ankota's EVV software.