Rhode Island's 85% EVV Threshold: Why Most Providers Are Still Falling Short

Rhode Island is the smallest state in the country. Its EVV compliance obligations are exactly the same size as everyone else's — and EOHHS has made clear it expects providers to treat them that way.

Where EOHHS Is Seeing Problems

In December 2023, EOHHS published a formal EVV compliance communication identifying three specific areas of concern across the provider community. The message was direct: many agencies were falling short of the 85% auto-verification threshold, and EOHHS was putting the industry on notice.

The three problem areas they called out:

First, manual entry rates. EOHHS set a target of 85% auto-verified visits — meaning visits electronically captured at the time of service via GPS or approved telephony, not entered manually after the fact. Agencies with caregivers routinely clocking in late or logging visits from memory are generating manual entries by default, and those entries don't count toward compliance.

Second, GPS location mismatches. EOHHS flagged visits recorded outside the state of Rhode Island or more than 500 feet from the member's home. Agencies are required to either document a cleared and verified exception for these visits or face claim exposure. Caregivers clocking in from their car, a nearby parking lot, or before entering the building are generating location discrepancies that show up in EOHHS's reporting.

Third, exception handling gaps. When a legitimate exception exists — a member with a different care location, a visit where GPS wasn't available — the agency is required to document and verify that exception in the EVV system. Visits where the GPS data is off and no exception is on file are a compliance liability regardless of whether the service was actually delivered.

The Home Health Layer

Rhode Island's EVV mandate for personal care and homemaker services has been active since January 1, 2021. Home health care services came under the requirement in January 2024. That means agencies delivering skilled nursing, home health aide, and therapy services at home are now in the same EVV compliance environment as personal care agencies — and many of them went live on EVV mid-2024 without the operational muscle their longer-tenured counterparts built over three years.

Home health providers that are new to EVV and struggling with auto-verification rates are especially visible to EOHHS right now, because their compliance data is fresh and the 85% benchmark applies from day one.

The Conflict-Free Case Management Complication

Rhode Island is simultaneously implementing a new Conflict-Free Case Management system as part of its broader LTSS redesign — required by CMS under a Corrective Action Plan. Under CFCM, agencies that provide direct services to HCBS participants can no longer also provide case management to those same participants. For approximately 11,000 Rhode Island HCBS participants, case management relationships are changing.

For direct service providers, this means the case manager who previously coordinated authorizations, service plan updates, and eligibility renewals may no longer be the same entity. Billing depends on accurate, current authorizations — and when case management transitions, authorization gaps are a real risk. Providers whose billing staff aren't actively monitoring authorization status during the CFCM transition are the ones most likely to bill into a gap.

What Providers Should Do Now

Pull your Sandata compliance report and identify your current auto-verification rate. For any caregiver below 85%, audit their recent visit entries for manual input patterns. Review your GPS exception log for any visits flagged outside the 500-foot threshold and confirm exceptions are documented. And for any members whose case management has transitioned under CFCM, verify authorizations are current under the new case manager before the next billing cycle.

Rhode Island's HCBS environment is compact but fully compliant with federal expectations. EOHHS has signaled it will enforce accordingly.